I am writing to express serious concern regarding any proposal allowing dental assistants to perform scaling procedures. This practice places patients, dentists, and dental practices at significant risk and should not be permitted under any circumstances.

Scaling is a clinical procedure requiring assessment, diagnosis, and professional judgment. Delegating it to an unlicensed dental assistant exposes the supervising dentist to substantial malpractice liability. If tissue damage, infection, or undiagnosed disease occurs, the dentist—not the assistant—is held responsible. No malpractice carrier supports delegating procedures outside an assistant’s legal scope.

Patient safety is also compromised. Scaling without proper periodontal evaluation can worsen active infection, damage fragile tissue, and delay necessary periodontal therapy. Registered Dental Hygienists are trained to assess pocket depths, attachment loss, bleeding, calculus type, and systemic risk factors. Dental assistants receive no formal education in periodontal disease, oral pathology, radiographic interpretation, or systemic?oral health connections. As a result, conditions such as oral cancer, abscesses, bone loss, and mucosal abnormalities may go undetected.

Equally important, billing insurance for scaling performed by a dental assistant is not legal. CDT codes for prophylaxis and periodontal therapy require that the procedure be completed by a licensed provider. Submitting claims for treatment performed by an unlicensed assistant constitutes misrepresentation and may be considered insurance fraud. Practices risk audits, refund demands, claim denials, removal from insurance networks, and disciplinary action from the state dental board.

Patients deserve care from licensed professionals trained to identify disease and protect their health. Workforce shortages should be addressed through improved support for hygienists—not by lowering clinical standards.