I am a Virginia-licensed dental hygienist, and I respectfully urge the Virginia Board of Dentistry to initiate a formal regulatory process regarding the implementation of § 54.1-2729.01 and the newly authorized scaling duties for dental assistants.

While the General Assembly has already established this new scope of practice, significant questions remain regarding training, supervision, competency, documentation, patient consent, and consistent implementation. Allowing these standards to vary from office to office creates unnecessary inconsistency in a procedure that directly involves patient care.

Dental hygienists receive extensive education and clinical training in instrumentation, periodontal assessment, calculus detection, tissue response, and the distinction between supragingival and subgingival deposits. Scaling is a clinical procedure that requires not only the ability to operate an instrument, but also the ability to recognize clinical limitations and understand when treatment needs exceed the permitted scope.

The statute requires at least 20 supervised full-mouth supragingival scaling procedures, yet important details regarding how competency and supervision should be evaluated and documented would benefit from clear, uniform standards. The legislation itself expressly contemplates regulations promulgated by the Board.

I respectfully ask the Board of Dentistry to begin a formal rulemaking process and establish clear, consistent statewide standards for training, competency, supervision, documentation, and patient protections in implementing the scaling-assistant law.

Thank you for considering the concerns of Virginia dental professionals and for your continued commitment to patient safety.