With the General Assembly’s action now enacted, my request is straightforward: the Board should open a rulemaking process to establish clear standards for implementing this new scaling assistant role. The statute created the role, but it left the details of how it will actually function in practice unresolved, and those details matter for patient safety and for the dental team members who will be expected to carry it out.
The Board already regulates assistants.

The Board has existing authority and precedent for regulating dental assistant functions, so it is well positioned  and arguably obligated to define the specifics here rather than leave them to individual practice interpretation.

Important questions the law doesn’t answer:
• Who is responsible for training? The statute doesn’t clarify whether the supervising dentist, a licensed dental hygienist, or both are responsible for training and verifying competency before an assistant performs scaling. This needs to be spelled out, including minimum training hours and documented competency checks.
• Do existing dental assisting programs need curriculum changes? If scaling is now within an assistant’s scope, the Board should clarify whether accredited assisting programs must add periodontal instrumentation training to their curricula, or whether this remains a purely employer-based certification with no standardized coursework.
• What does the certification process actually require? The law references certification “under a dentist” but doesn’t define minimum content, hours, competency evaluation, or documentation standards for that certification. Without this, certification requirements will vary widely from practice to practice.

• What ongoing oversight or renewal applies? It’s unclear whether this certification is a one-time event or requires periodic renewal, continuing education, or re-evaluation of competency.

The General Assembly clearly expected implementing regulation.
Enabling statutes like this one are routinely followed by board-level rulemaking to fill in operational detail  that’s the normal and expected next step, not an optional one. Leaving these questions unanswered risks inconsistent implementation across practices and unclear expectations for both supervising dentists and the assistants now authorized to perform this procedure.

I urge the Board to open a rule-making process addressing training responsibility, curriculum standards, certification requirements, and ongoing oversight before this new scope of practice is implemented statewide.

Conchetta Brevard RDH,BSDH,MPH