As a former ten-year Board of Dentistry member, I appreciate your dedicated service and your commitment to protecting the public.  

While the Board cannot undo the law of dental assistants performing supragingival scaling, it has the authority and responsibility to protect the public by promulgating regulations that ensure the law is clear, safe, and consistent.  

I respectfully petition the Board to initiate rulemaking addressing §54.2-3739 to clearly define clinical experience, standards of training, competency requirements, supervision, patient consent documentation, and certification.

The adoption of HB970 and SB178 (Enactment Clause 2), along with VDA's testimony in House and Senate subcommittees, affirms the General Assembly's intent for the Board to adopt regulations under its authority §54.1-2400.    The Board has previously demonstrated success with this approach of collaborating  with dentistry, dental hygiene, and auxiliary education leaders to establish standards for DA II category essential to public protection.

I oppose the delegation of supragingival scaling to dental assistants as this is unsafe, unregulated, incomplete care that devalues Virginia's quality of healthcare, unfairly exposes patient's to risk, creates the potential of fraudulent billing, and may negatively impact my malpractice insurance and career satisfaction as a licensed dental hygienist. 

To that end, I encourage the Board to consider the following recommendations:

• Restrict Supragingival Scaling to DA II Personnel:  Because the Board already exercises regulatory oversight over DA II personnel, the necessary additional training could be efficiently added to their existing certification standards.
• Maintain Board Oversight of Certification: Relegating training and certification entirely to individual dental employers shifts the critical obligation of public protection away for the Board.  Furthermore, requiring dentists to register each scaling certificate with the Board of Dentistry will ensure a clear record to the pathway of evidence for when patients experience harm and shall have recourse for damages caused by incomplete care and/or incompetent care provided.