I speak against delegation of Class I perio patient to the DA II, as the risks associated with the scaling procedure and the care of patients suffering from disease warrant the educational level and professional judgment making skills of those licensed to practice dental hygiene and nothing less.

I applaud the Board for collaboratively addressing change needed to provide care to a greater number of patients in the dental office.  I hope that we shall also soon see the Board create the regulatory changes needed to better serve those Virginians unable to directly access care and the private dental office.  It is exciting to witness all members of the dental team working toward positive change and hopefully, we will direct our efforts toward eradicating the #1 chronic childhood illness: pediatric dental disease.

As a former board member of ten years, I am confident  the Board will maintain and only promulgate regulations that are essential to the protection of the health, safety and welfare of all citizens.  As established by law (54.1-2700 & 2722), the minimal competency standard for rendering  "dental hygiene" care stipulates the provider be a licensed dental hygienist; therefore, delegation of scaling procedures, patients exhibiting a specified disease, or any component of the dental hygiene scope of practice goes beyond the statutory authority of this regulatory agency.   The removal of cementum and dentin during the scaling procedure on Class I perio patients exhibiting root exposure clearly demonstrates that this is not a "reversible procedure", and again conflicts with the law (54.1-2729.01).  

As a graduate of an accredited program in Dental Assisting and Dental Hygiene, educator, and practitioner, I can attest that "Direction", by either the dentist or dental hygienist,  does not substitute for the minimal competency needed to ensure that these scaling services are provided safely by anyone with less than an accredited dental hygiene education. 

Please continue the public's assurance that their total health and standard of dental hygiene care will remain protected in Virginia, by not amending 18VAC6--20-220 to allow for delegation to the registered DA II.

Thank you for your public service.