I respectfully submit this comment regarding dental assistants performing supragingival scaling. As a dental hygienist, I believe it is important for the Board to consider not only the immediate workforce concerns surrounding this change, but also its potential long-term effects on patient care, patient understanding, and the future dental hygiene workforce.

A dental cleaning involves much more than simply removing visible calculus above the gumline. Dental hygienists receive extensive education and clinical training in periodontal assessment, instrumentation, radiography, oral pathology, anatomy, pharmacology, medical history review, patient education, and the recognition and treatment of periodontal disease within their scope of practice.

A patient who appears to need a routine preventive cleaning may have bleeding, periodontal pocketing, recession, attachment loss, radiographic bone loss, inflammation, or subgingival calculus. These findings can change the appropriate treatment for that patient. Periodontal disease does not stop at the gingival margin simply because a provider’s scope of practice does.

The role of a dental hygienist extends far beyond the mechanical removal of calculus. Scaling is only one component of comprehensive dental hygiene care. Dental hygienists are educated and clinically trained to assess periodontal health, recognize signs of disease, identify deposits above and below the gingival margin, evaluate changes in a patient’s oral condition, provide appropriate preventive and periodontal treatment within their scope, educate patients, and communicate significant findings to the dentist.

The concern is not whether a dental assistant can be taught the mechanics of removing supragingival calculus. The larger concern is whether competency in one procedure should be viewed as equivalent to the education and clinical judgment required to evaluate a patient’s overall periodontal condition and determine appropriate care.

Technical ability to perform a task and comprehensive education in the disease process surrounding that task are not the same. Dental hygienists are educated not only in how to remove calculus, but also in why it is present, where it is present, how the surrounding tissues are responding, what other clinical findings may indicate, and when a patient’s condition requires treatment beyond routine preventive care.

This distinction is particularly important because patients generally do not arrive knowing whether their calculus is limited to above the gingival margin. They rely on dental professionals to make that determination. A patient’s appropriate level of care should therefore be established through proper assessment rather than by the procedure a particular provider is authorized to perform.

For this reason, I believe there should be clear standards regarding how patients are determined to be appropriate candidates for supragingival scaling by a dental assistant. What periodontal assessment must occur first? What findings would exclude a patient? What happens when conditions outside the assistant’s scope are discovered? Who is responsible for ensuring that subgingival calculus or periodontal disease is not overlooked?

Patient transparency is equally important. Most patients understand the term “dental cleaning,” but many will not understand what “supragingival scaling” means or how it differs from comprehensive dental hygiene care. Patients should be clearly informed when their scaling will be performed by a dental assistant rather than a licensed dental hygienist. They should understand that the assistant’s scaling is limited to above the gumline and have the opportunity to make an informed decision regarding their care.

Dental assistants are valuable members of the dental team. These concerns are not intended to diminish their role or create an argument between dental assistants and dental hygienists. They are different professions with different educational requirements, clinical training, responsibilities, and scopes of practice. Those distinctions should remain clear to patients.

I also encourage the Board to consider the long-term workforce implications.

This expansion has largely been discussed as a response to a shortage of dental hygienists. Dental hygiene programs, however, continue to educate students who are investing significant time and money to enter this licensed profession. What happens as more hygienists graduate and the current shortage improves?

If practices establish staffing models in which dental assistants routinely perform portions of preventive appointments previously provided by hygienists, there may be less incentive to hire additional hygienists even when qualified hygienists become available. A measure intended to address a current workforce shortage could unintentionally become a permanent staffing model.

This could affect employment opportunities for future graduates, discourage individuals from entering dental hygiene programs, and ultimately weaken the future hygiene workforce. We should be careful not to address today’s shortage in a manner that contributes to tomorrow’s shortage.

The financial incentives associated with this model also deserve consideration. If portions of preventive services can be delegated to an employee with different compensation requirements while patient charges or insurance reimbursement remain unchanged, there may be an economic incentive to continue or expand that model even when licensed hygienists are available.

This is not an accusation against dentists. Financial incentives exist throughout healthcare and should be considered when establishing appropriate safeguards. It is reasonable to ask how these services will be billed, whether patients and third-party payers will know who performed the scaling, and whether delegation decisions will continue to be based primarily on patient need and access to care.

Workforce concerns regarding compensation, scheduling, recruitment, and retention should also remain separate from decisions regarding patient care and professional scope.

If an individual hygienist is not a good fit for a particular practice, that is an employment matter that can be addressed between the employer and employee. However, when practices across the profession experience difficulty recruiting and retaining hygienists, it is reasonable to examine the broader factors contributing to that shortage.

Compensation, appointment length, workload, staffing support, physical demands, scheduling expectations, and the ability to provide appropriate patient care are legitimate workforce considerations. Addressing those issues may be an important part of improving recruitment and retention.

Employment and workforce challenges should not determine the level of education, clinical training, or professional scope considered appropriate for patient care.

I respectfully ask the Board to consider how this change will function in everyday practice, not simply whether a dental assistant can be trained to remove supragingival calculus.

How will appropriate patients be selected? What periodontal assessment must occur beforehand? How will patients be informed in language they understand about who is providing their care and the limitations of that provider’s scope? Will patients have the ability to request care from a licensed dental hygienist? How will these services be represented to patients and third-party payers? What safeguards will help prevent financial considerations from becoming the primary reason for delegation? And what happens to this staffing model when the current shortage of hygienists improves?

Access to dental care is important, but access should not simply mean getting more patients onto a schedule. It should mean providing appropriate, comprehensive, and transparent care based on each patient’s clinical needs.

Virginia should continue working to recruit and retain qualified dental hygienists while supporting dental assistants in their valuable and appropriate roles. Workforce challenges deserve workforce solutions, but those solutions should not unintentionally diminish comprehensive dental hygiene care or weaken the profession needed to provide it.

Ultimately, decisions regarding patient care should be guided by patient safety, education, competency, appropriate scope of practice, transparency, and quality of care.

Thank you for considering these concerns.