I am submitting this comment in response to the Board of Dentistry’s proposed guidance regarding the delegation of supragingival scaling to dental assistants.

The Board’s decision to authorize this procedure without initiating a formal regulatory process is deeply concerning, particularly because Virginia does not require dental assistants to have any formal education, training, or credentialing prior to employment. This absence of baseline qualifications is central to the public safety issue at hand.

Supragingival scaling is not a clerical or purely mechanical task. It is a clinical procedure that requires knowledge of oral anatomy, recognition of pathology, safe instrumentation, and the ability to determine when a patient’s condition exceeds the limits of delegated care. These competencies cannot be assumed when the Commonwealth has no minimum educational standards for dental assistants.

Without required education, standardized training, or competency verification, the quality and safety of care will vary widely from office to office. Patient protection should not depend on the discretion of individual employers. A regulatory framework is necessary to ensure consistent training, enforceable accountability, and meaningful oversight.

Licensed dental hygienists complete accredited programs, national board examinations, clinical examinations, and continuing education. Expanding clinical duties to unlicensed personnel who are not required to meet any educational threshold creates a significant disparity in preparation and introduces avoidable risk to the public.

For these reasons, I urge the Board to establish formal regulatory requirements—including minimum education, standardized training, and competency assessment—before permitting dental assistants to perform any form of scaling.

Thank you for considering this comment and for prioritizing patient safety and professional standards in Virginia.