Thank you for your service and commitment to protecting the public.

Imagine being the patient in that chair. You are told that you are having your teeth “cleaned.” You trust that the person holding the instrument knows whether disease is present and whether the care being provided is actually the care you need.

A dental assistant can be taught the mechanics of supragingival scaling, including basic instrument selection, but performing the task does not provide the education or clinical judgment necessary to determine whether supragingival scaling is the appropriate care for that patient.

Who will make that determination? Who will assess the gingiva, measure periodontal pocketing, recognize inflammation or subtle tissue changes, and identify subgingival biofilm or calculus?

Visible tartar and stain may be what the patient notices, but the pathogenic biofilm thriving below the gumline presents the greater concern. A dental assistant trained only to perform supragingival scaling cannot complete the periodontal assessment, formulate the dental hygiene diagnosis, or provide care based on the presence and stage of disease.

Removing what is visible without evaluating what is happening beneath the gumline is like painting over water damage without checking for mold. The surface may look better, but the underlying condition remains unidentified and untreated.

This also raises a serious concern about patient autonomy, a foundational principle of the ADA Code of Ethics. Patients cannot make an informed decision unless they are clearly told that the person providing the service is not a licensed dental hygienist, that the procedure is limited to scaling above the gumline, and that it is not equivalent to comprehensive dental hygiene care. Without meaningful disclosure and documented consent, patients may leave believing they received a complete “cleaning” when the health beneath their gums was not assessed by the person providing that service.

Although the Board cannot reverse the General Assembly’s decision, it has the authority and responsibility to determine how this law will be implemented and how Virginia patients will be protected. I encourage the Board to consider the following recommendations:

• Restrict supragingival scaling to Dental Assistant II personnel under the Board’s existing oversight.

• Establish standardized education, clinical experience, hands-on training, competency testing, certification, and continuing competency requirements.
• Require a qualified clinician to assess the patient and determine that supragingival scaling alone is appropriate before the procedure begins.
• Require clear disclosure, documented patient consent, certification records, and billing standards that distinguish this limited procedure from comprehensive dental hygiene care.

Above all, our professional obligation is to do no harm. This is not simply a question of whether dental assistants can be taught to remove visible calculus. It is whether the procedure can be delivered with the assessment, judgment, transparency, and accountability necessary to protect the patient.

Our patients trust us to recognize what they cannot see. They deserve more than the appearance of "clean teeth."