Dear Sir/Madam,

I am a Virginia licensed dental hygienist with more than four decades of clinical experience and a former Dental Assisting Program Director who wrote the curriculum, ran the clinic, and partnered with Virginia Beach Dental Public Health for the Virginia Beach City Public School's Virginia Beach Career and Technical high school program. I spent years educating dental assistants and have tremendous respect for their essential role on the dental team. My concern regarding the implementation of the new supragingival scaling law is not professional turf. It is consistency, accountability, and patient protection.

For much of my career, the Virginia Board of Dentistry has taken a cautious approach to expanding the clinical functions of dental auxiliaries. I have watched licensed dental hygienists wait years for authority to perform functions that hygienists in other states were already performing safely and professionally. The rationale was patient protection and appropriate education, training, and oversight.

The Board applied that same principle when Dental Assistant II expanded functions were authorized. Dental assistants could be trained to perform specified restorative procedures, but the qualifications of those teaching and overseeing those advanced clinical skills mattered. The Board established standards rather than simply leaving implementation to individual dental practices or educational programs.

Why should the principle be different for supragingival scaling?

The new law permits training to occur through existing dental assisting education programs. Yet supragingival scaling has not traditionally been a dental assisting competency. That creates a fundamental question: Who is qualified to teach and evaluate it?

A dental assisting instructor may be entirely qualified to teach dental assisting. That does not necessarily make that individual qualified to teach a dental hygiene procedure the instructor has not independently been educated, licensed, or authorized to perform.

Supragingival scaling may be limited to the portion of the tooth above the gingival margin, but it remains a clinical instrumentation procedure. If the Board required appropriately qualified professionals when dental assistants were taught expanded restorative functions, it should apply the same principle when they are taught a function historically performed by licensed dental hygienists.

The law leaves other important questions unanswered as well: What constitutes acceptable clinical experience? Who supervises the required full-mouth scaling procedures? What constitutes adequate supervision? Who determines competency? How is training documented? Does certification follow an assistant who changes employers?

And more critically: What must the patient be told? Autonomy is the first principle of dental ethics. Patients have the right to make informed decisions about their care, but they cannot make a truly informed decision without knowing the relevant facts.

A patient receiving supragingival scaling should be clearly informed that the person providing that service is a dental assistant authorized to perform a limited scaling function, not a licensed dental hygienist. Patients should not be expected to determine the credentials or scope of practice of the person holding an instrument in their mouth.

Without statewide guidance, one practice may provide that information clearly while another may provide little or none. Patient autonomy and informed consent should not depend upon which Virginia dental office a patient happens to enter. This is why I am disappointed that the Board has chosen not to initiate a formal regulatory process.

I am not asking the Board to undo what the General Assembly enacted, nor am I suggesting that dental assistants cannot successfully learn additional skills. As stated above, I spent a significant part of my professional career teaching dental assistants, and I know what properly structured education can accomplish.

I am asking the Board to apply the same principle it has applied before: when the scope of clinical practice expands, standards for education, instructors, competency, supervision, documentation, accountability, and patient protection should expand with it.

Access to care matters. Workforce shortages matter. But neither requires Virginia to abandon the regulatory safeguards it has considered important for decades. The standard should not change depending upon which member of the dental team is receiving an expanded function.

The standard should be patient centered. And if we truly believe in patient autonomy, informed consent requires informed patients.

Yours, in good dental health,

Antoinette Kahan, RDH, BA