It is concerning to see Boards of Dentistry across the country move forward with laws such as HB 970 and SB 178 without first clearly defining how these changes will be implemented and how the public will be protected.

I understand the economic and workforce pressures affecting dentistry. However, too often these pressures have led dentists, hygienists, and assistants to be placed against one another over wages, staffing, and scope of practice instead of working together to address the larger financial pressures affecting our profession and our patients such as insurance reimbursement models. We are all part of the same healthcare team, and patient safety and quality of care should remain our shared priority.

Workforce shortages are real, but the solution cannot come at the expense of patient safety or the standard of care.

As these laws are implemented, clear and consistent standards need to be established for dental assistants and foreign-trained dentists who will be performing scaling procedures. I respectfully ask the Board to consider the following:

• Clinical experience: What qualifies as clinical experience? This needs to be clearly defined so it is not interpreted differently from one practice or dentist to another.
• Training standards: What specific education, clinical training, and competency requirements must be completed before certification?
• Required scaling procedures: If 20 full-mouth scaling procedures are required, who will supervise them, how will competency be evaluated, and how will completion be documented?
• Patient disclosure and consent: How will patients be informed that their preventive scaling is being completed by someone who is certified but not a licensed dental hygienist, particularly during the training process?
• Competency benchmarks: Completing a certain number of procedures does not automatically demonstrate competency. What skills and knowledge must be demonstrated before someone is considered qualified?
• Certification records: Who will maintain these records, how will they be verified, and will the certification follow the individual if they change employers?
• Ongoing competency: Will there be continuing education, renewal requirements, or other measures to ensure competency is maintained?

These questions are not meant to create unnecessary barriers. They are important safeguards when expanding who is permitted to provide direct clinical care.

Respectfully, I ask the Board to clearly define the education, supervision, competency, documentation, patient-disclosure, and accountability standards before these provisions are fully implemented.

Workforce challenges may require new solutions, but patient safety and quality of care must remain the foundation of those decisions.