Thank you for the opportunity to provide feedback on the petition for rulemaking regading the status of dental hygiene graduates of an accredited educational program in Canada and their ineligibility for registration in Virginia.  This rule is in conflict with the concept of national credentialing particularly since the candidate was successful in the NBDHE. I would assume the regulatory body of VA is a stakeholder for the NBDHE, therefore, if the candidate is eligible  to write the exam, then she should be eligble to register in the state. In addition, the rule is in contradiction to the reciprocal agreement between CDAC and CODA; the agreement is indicating that the programs that have been accreditated by these two bodies are equivalent in their standards for entry-to-practice education.  Should the state feel that the scope of practice in dental hygiene is further advanced, then they should take the responsibilty of expoloring the differences in more depth and deciding on a path of advanced training for individual skills, such as local anesthetic delivery, rather than a flat denial of eligibility for registration.

Thank you.