The legislation authorizing dental assistants to perform supragingival scaling has already been enacted. The issue before the Board now is not whether this duty should have been authorized, but how the Board can provide the clearest and safest guidance possible within the law enacted by the General Assembly.

There appears to be considerable misunderstanding about how this change occurred. This expansion of dental assistant duties was created by the General Assembly. It was not initiated by the Virginia Board of Dentistry, nor was it a decision by the Board to expand the scope of practice of dental assistants. Criticism of the Board for creating this change is misplaced.

This distinction is particularly important because dental assistants performing these duties are not licensed by the Board in the same manner as dentists and dental hygienists. The Board consequently does not have the same direct licensing and disciplinary authority over these individuals. Much of the responsibility necessarily rests with the licensed dentist who determines whether the statutory requirements have been satisfied, certifies the assistant, delegates the procedure, determines appropriate patient selection, and provides the required supervision.

That reality makes Guidance Document 60-7 especially important. The proposed addition of a single line, “Supragingival Scaling with hand and ultrasonic scalers,” with a reference to the statute does not adequately communicate the significance or limitations of this new delegated duty.

The guidance should clearly state the statutory qualifications that must be satisfied before this procedure may be delegated. It should also clearly define the limits of supragingival scaling and distinguish it from subgingival instrumentation, periodontal debridement, and periodontal therapy.

Patient selection must also be addressed. The presence of supragingival calculus does not necessarily mean that a patient is appropriate for this limited procedure. The supervising dentist should be responsible for determining that the patient’s periodontal condition is appropriate for treatment within the dental assistant’s permitted scope before scaling is delegated.

The guidance should also make the dentist’s responsibility unmistakable. Because the dental assistant is not independently licensed by the Board to provide this care, dentists need to understand their responsibility for verifying qualifications and competency, appropriate delegation, patient assessment, supervision, and compliance with the statutory limitations.

The Board did not create this expansion of dental assistant duties. The General Assembly did. The Board is now faced with the difficult responsibility of providing guidance for its implementation within the limits of the authority it has been given. For that reason, Guidance Document 60-7 should provide substantially more direction than a one-line addition to the existing table.