Dear Honorable Board Members,

  I am writing to ask the Board to consider allowing the properly trained expanded duty dental assistant (DA II) to scale and polish type I periodontal patients under the direct supervision of the dentist.  Access to care for dental patients is a growing challenge that will continue to increase in the future.  There are a number of factors that have contributed to the severity of this challenge, and it will take more than one solution to solve it.  The entire dental team – dentists, hygienist, assistants- all need to work together with our community leaders and government representatives to develop the best strategies to reach our growing underserved population.  That is why it is so distressing to see our dental team at odds over the one expanded duty of scaling a type I periodontal patient.  How is it that a DA II can be properly trained to perform reversible procedures such as carve and pack amalgam, make impressions, scale cement from crown margins, and yet they cannot be properly trained to scale visible calculus from teeth? Why is it that during this period of public comment we have not heard one negative comment about any of the other delegable duties (except scaling) from either dentists, hygienists, or concerned patients? It is clear that we are all concerned about the quality of care that we provide our patients, and it appears that this controversy over the one delegable duty of scaling indicates a lack of understanding of the urgency of the problem of access to care.  To quote Albert Einstein, "The significant problems we face cannot be solved at the same level of thinking we were at when we created them";  we need to work together and to think beyond our status quo to find solutions that meet access to care needs and maintain the quality of care that every patient should have. 

       Some solutions have already been developed and are working to meet access to care needs.  The ability of dental hygienists to work under general supervision of the dentist and to provide local anesthesia to patients has helped this valuable member of the dental team provide more services to patients, not just in the private office, but also in the public health setting.  Despite initial opposition to these delegable duties due to concern over quality of care, the entire dental team has worked together to insure that quality of care has not only maintained high standards, but this high quality of care is now reaching more patients in need.  There are a number of examples of success over the years of expanded duty assistants providing properly trained services including scaling type I periodontal patients.  These expanded duty assistants will be an invaluable asset in the private and public dental setting in helping the dental team to meet the growing needs of access to care. 

     The DA II is not meant to replace the dental hygienist.  On the contrary, a properly trained DA II will help the hygienist to provide more of his/her expertise to the growing number of periodontal patients that need the services that only they and the dentist can provide.  This in turn will help the dentist more effectively provide the restorative and surgical services that only he/she can provide.  The patient benefits from the best use of skills that the entire dental team can provide.  The ultimate responsibility for diagnosis of disease and for supervision of care rests in the hands of the dentist, and a highly functioning dental team can provide quality of care to more of those in need.  It is just one way that the dental team can help meet the needs of access to care.  Thank you for your time and considerable thought given to determining the duties of the expanded duty dental assistant.

Benita A. Miller, D.D.S.