Dear Members of the Virginia General Assembly and Virginia dental policymakers,
I am writing as a licensed dental hygienist and healthcare professional to express my strong concern and opposition to the expansion of dental assistant duties under HB 970/SB 178, which allows qualifying dental assistants to perform supragingival scaling and coronal polishing.
My concern is not about diminishing the important role dental assistants play in dentistry. Dental assistants are an essential part of the dental team. My concern is specifically about scope of practice, education, clinical competency, patient safety, and maintaining the professional standards expected of individuals providing irreversible or potentially harmful clinical care.
Dental hygiene is a licensed healthcare profession for a reason. A dental hygienist does not simply learn how to remove deposits from teeth. Dental hygiene education includes extensive didactic, laboratory, and supervised clinical education in areas such as:
Dental hygienists then must complete an accredited dental hygiene program and satisfy Virginia’s licensure requirements, including the National Board Dental Hygiene Examination and an accepted clinical competency examination. Virginia specifically requires dental hygienists seeking licensure by examination to graduate from a CODA-accredited dental hygiene education program and pass an accepted clinical examination. (Virginia Health Professions?)
That educational pathway exists because clinical instrumentation is not simply a technical skill. It requires the ability to recognize normal and abnormal oral conditions, assess periodontal health, understand disease processes, identify risks, adapt treatment to the individual patient, and recognize when a patient requires further evaluation by a dentist or other healthcare professional.
My concern with HB 970/SB 178 is that a limited training pathway should not be viewed as equivalent to the comprehensive education and clinical preparation required of a licensed dental hygienist.
The law requires 1,800 hours of clinical experience and additional training before a qualifying dental assistant can obtain certification to perform supragingival scaling and coronal polishing. However, hours of employment are not equivalent to hours of formal dental hygiene education. Experience performing dental assisting duties does not automatically provide the same foundation in pathology, periodontology, pharmacology, patient assessment, clinical decision-making, or comprehensive periodontal care that is obtained through an accredited dental hygiene program. (Virginia Legislative Information System?)
Patient safety must remain the priority.
There are several concerns that deserve serious consideration:
1. Recognition of disease and abnormal conditions
Patients do not always present with a simple accumulation of calculus. During an oral examination, a trained dental hygienist may identify periodontal disease, recession, suspicious lesions, inflammation, bone loss, mobility, furcation involvement, or other abnormalities requiring further evaluation.
A provider who has received limited scaling training may be able to perform an instrumentation technique without having received the same depth of education in recognizing and interpreting clinical findings.
2. Risk of treating without adequate assessment
Scaling should not be viewed as merely “cleaning teeth.” It is part of patient care that occurs within the context of an assessment and an understanding of the patient’s oral and systemic health.
Patients may have anticoagulant therapy, cardiac conditions, diabetes, immune compromise, pregnancy, periodontal disease, tissue abnormalities, or other factors that can affect treatment decisions.
3. Instrumentation requires clinical judgment
Hand and ultrasonic instrumentation require more than learning how to operate an instrument. Clinicians must understand anatomy, tissue response, calculus characteristics, root morphology, periodontal conditions, instrumentation adaptation, pressure, angulation, tissue trauma, and when treatment should be modified or discontinued.
4. Blurring professional boundaries
Virginia has established separate education, licensing, and scope-of-practice standards for dentists, dental hygienists, and dental assistants. Expanding clinical procedures traditionally associated with dental hygiene risks blurring the distinction between these professions.
If Virginia believes that there is a shortage of dental hygienists, the answer should be to increase access to dental hygiene education and the dental hygiene workforce—not to substitute a shorter training pathway for a licensed healthcare profession.
5. Patient perception and informed consent
Patients deserve to know who is providing their care, what that individual’s professional credentials are, and what education and licensure they possess.
A patient who believes they are receiving treatment from a licensed dental hygienist may not understand that the person performing the procedure is instead a dental assistant who completed an alternative certification pathway.
Transparency and informed consent should be fundamental.
6. Liability and accountability
I also believe policymakers should carefully examine what happens when a patient is injured, a condition is missed, or treatment is performed outside the appropriate level of clinical competency.
Who assumes responsibility?
What insurance coverage applies?
What happens when a dental assistant encounters a periodontal condition beyond the training they received?
What safeguards exist to ensure that patients are not placed at unnecessary risk?
These questions deserve answers before expanding clinical duties.
There is already an educational pathway.
If a dental assistant wants to become a dental hygienist and provide comprehensive preventive and periodontal care, there is a pathway for that: dental hygiene school.
I strongly encourage Virginia to invest in expanding accredited dental hygiene programs, scholarships, clinical training opportunities, faculty recruitment, and access to dental hygiene education rather than creating alternative pathways that can blur the distinction between a dental assistant and a licensed dental hygienist.
Virginia’s own Board of Dentistry recognizes dental hygiene as a licensed profession requiring accredited education, national examination, and clinical competency. (Virginia Health Professions?)
Furthermore, licensed dental hygienists are required to maintain continuing education, including clinical education and training related to patient care, legal and ethical responsibilities, risk management, and other areas relevant to professional practice. (Virginia Health Professions?)
I respectfully ask you to reconsider this approach.
Expanding access to oral healthcare is an important goal. I fully support improving access to preventive dental care and addressing workforce shortages.
However, access should never come at the expense of education, competency, professional standards, or patient safety.
Once scope of practice is expanded, it can be extremely difficult to reverse course after patients have already been affected. Policymakers should therefore exercise caution before permanently changing the boundaries between licensed healthcare professions.
I respectfully ask you to:
As healthcare professionals, our responsibility is ultimately to the patient.
We should never lower educational and professional standards simply because a procedure appears technically simple.
Dental hygiene is a licensed healthcare profession because patients deserve providers who have been comprehensively educated, clinically trained, examined, licensed, and held accountable for the care they provide.
I respectfully urge Virginia policymakers to reconsider whether this legislation truly represents the safest and most appropriate path forward for Virginia patients.
Thank you for your consideration and for taking the concerns of licensed dental hygienists and the patients we serve seriously.
Respectfully,
A Concerned Licensed Dental Hygienist