I strongly oppose the delegation of scaling procedures and Class I perio patients to the DA II.

I have had the pleasure of serving with talented, knowledgeable dental assistants over the past years attending VDA task force meetings and through over thirty years of private practice and volunteer public health venues. The dental assistant is extremely important to the complete care of our patients. The DA II will be a great compliment to any office with expanded restorative functions as this is their field of training, education, and experience.

The delegation of scaling procedures to anyone other than a licensed dental hygienist appears to be in conflict with statute 54.1-2700 &2722 wherein the minimal competancy standard for rendering "dental hygiene" care stipulates the provider be a licensed dental hygienist. A class I perio patient frequently presents with recession and root exposure whether it be minimal or excessive. Any cementum removed during a scaling procedure would indeed be considered irreversible. This would also be in conflict with the law 54.1-2729.01.

Expanding professional responsibilities should be driven by sound clinical science and research and should never be motivated by economic factors. Any changes in the scope of practice should be directly and unequivocally linked to a profession's formal education and training. On the job training does not equate to the minimal competency required by a graduate of an accredited dental hygiene collegiate program.

Because it is the responsibility of the members of the Board of Dentistry to protect the health, safety and welfare of all citizens, I urge you to continue to adhere to the statutes already in place. Do not amend the law to allow for the delegation of scaling procedures to the DA II.

I appreciate each of you donating your valuable time in serving the needs of the public and thank you.