I strongly oppose allowing dental assistants II to scale to 3mm subgingivally or for that matter scale at all.  As  a dental hygienist and an educator I know how hard we have to work to earn the title RDH.  It requires a great deal of skill and training to properly and safely scale supra and subgingival which a dental assistant cannot obtain by learning from a dentist in an office.  Even dentists are not required to have as much training in dental school as a hygienist when it comes to scaling.  I agree that the dental assistant is a very important member of the dental team but I would no more want to take over doing their job then I would want them to do mine.  I certainly don't think any dentists would support having one of us hygienists do some of their restorative work for them because they are trying to "provide access to care."  By allowing the DA II to scale we would be doing our patients a disservice by providing less than the standard of care.  Does this mean the patient and the insurance companies will still be responsible to pay for substandard care by an untrained professional and that they would still be billed for the services that a dental hygienist should be providing?  I strongly urge the board to reconsider this language in the proposal and not allow the DA II to lower the standard of care in Virginia.  It is unfair to our patients to provide them with less than the standard of care.  

Jenifer L. Spencer RDH, BS