I strongly oppose allowing dental assistants to perform supragingival scaling and permitting foreign-trained dentists to practice dental hygiene in the United States without obtaining the proper licensure and completing accredited clinical training required by U.S. regulatory standards. Supragingival scaling is not a purely mechanical task; it is a preventive therapeutic procedure that requires comprehensive knowledge of periodontal anatomy, disease progression, infection control, medical risk assessment, and patient management. In the United States, dental hygienists complete rigorous education through programs accredited by the Commission on Dental Accreditation (CODA), followed by successful completion of national and state clinical board examinations. These standards exist to ensure patient safety, clinical competence, and consistency of care. Dental assistants, while vital members of the dental team, are not educated or licensed to assess periodontal health, identify pathology, or manage complications associated with scaling procedures. Expanding their duties to include supragingival scaling without equivalent education and licensure undermines established professional standards and may place patients at unnecessary risk. Similarly, foreign-trained dentists possess valuable education and experience; however, dental hygiene in the United States is a distinct, licensed profession with specific educational, legal, and clinical requirements. Practicing dental hygiene without completing an accredited U.S. dental hygiene program and obtaining proper state licensure circumvents regulatory safeguards designed to protect the public. Professional licensure is not merely administrative—it confirms competency within the specific scope of practice defined by each state. Patient safety, public trust, and professional accountability must remain the primary priorities in oral healthcare policy decisions. Any modification of scope of practice should require standardized education, accredited training, clinical competency assessment, and state licensure equivalent to current dental hygiene standards. For these reasons, I urge policymakers and regulatory boards to uphold existing licensure requirements and maintain clear professional boundaries to ensure the highest standard of care for patients across the United States.

I oppose as a patient and on behalf of friends who are excellent trained hygienists.

I became a registered dental hygienist ten years ago because I wanted to help and educate patients about preventive care, particularly periodontal health. Growing up, I did not understand how deeply oral health is connected to overall health. That understanding is what inspired my career, along with following in my mother’s footsteps. I was adopted and came to the United States twenty two years ago. I still vividly remember my first dental cleaning—it was shocking to me at the time because I thought my tooth was being broken, when in reality it was calculus being removed. In my home country, we only visited the dental office when we were in pain. Dentistry was focused almost entirely on restorative treatment, not prevention. What impressed me most about dental hygiene in the U.S. was how detailed, organized, and prevention-focused the profession is. Dental hygienists do far more than clean teeth—we are the backbone of the dental office and the primary link between patients and providers. We educate, assess, prevent disease, and advocate for long-term health. Not every country has the same standards of care when it comes to periodontal health and preventive dentistry. I know this firsthand because I lived and experienced care in another system. Many of my colleagues were dentists in their home countries who became dental hygienists only after completing proper training at accredited U.S. institutions and passing rigorous board examinations. Lowering standards is not fair to hygienists, dentists, or—most importantly—patients. Please do not change the law in a way that compromises the standard of care we provide. I chose this profession with pride and purpose, and I do not want to regret becoming a dental hygienist. Our patients deserve the highest level of preventive care, and our profession deserves to be protected. Thank you for your time and consideration.

Hello, my name is Hayat Eisa, and I’m a constituent from Newport News, Virginia. I’m writing message to show that I OPPOSE SB 178 and SB 282. I recognize that both of these bills are often framed as workforce or access solutions, and I think we all agree improving access to care is important. But these proposals would change who is allowed to provide preventive clinical procedures without requiring the level of education and supervised training that licensed dental hygienists complete, and that creates real patient safety concerns. Scaling is not just a technical skill. It involves evaluating periodontal health, recognizing disease, understanding how medical conditions like diabetes or heart disease influence care, preventing complications, and constantly deciding when it is or is not safe to proceed. If calculus and biofilm are left behind because a provider lacks that depth of preparation, or provides incomplete care, disease can continue or worsen. Patients may later require more invasive and more expensive treatment, visits become longer and more complicated, and the demand on fully trained providers can actually increase. I also want to be very clear that internationally trained dentists are highly educated professionals who contribute greatly to their communities. However, SB 282 does not create a pathway to practice dentistry. It grants eligibility for licensure in a different profession, dental hygiene, which has its own curriculum, competencies, and clinical training standards. Substituting one profession’s education for another weakens the safeguards patients rely on. Virginia’s licensure system exists so every patient can trust that the person providing their care has met consistent, rigorous preparation. Both of these bills lower that bar. There are ways to expand access that don’t reduce safety, like enabling hygienists to practice to the full extent of their education, improving reimbursement structures, strengthening recruitment and retention, and expanding dental hygiene education programs.

I am writing to respectfully ask legislators to vote NO on HB 970 when it comes on the House floor. Although this proposal is sometimes presented as a workforce or access solution, it would significantly change who is permitted to provide preventive clinical care to patients in Virginia without requiring the education and training currently expected of licensed dental hygienists. HB 970 would allow preventive dental assistants to perform scaling procedures after far less formal education and supervised clinical experience than hygienists complete. Scaling is not merely a technical task. It requires the ability to assess periodontal health, recognize disease, adapt treatment to complex medical histories, prevent complications, and determine when it is unsafe to proceed. Further, it proposes an incomplete procedure may result in harmful outcomes for patients. If subgingival biofilm and tartar are left behind: disease can continue or worsen patients may require more extensive and more expensive treatment later future appointments become longer and more complex the demand on the limited number of fully trained providers actually increases Virginia’s licensure standards exist so every patient can trust that the person providing their care has met consistent, rigorous preparation. This bill lowers that bar.

Please oppose these bills to maintain public health and safety.

As a licensed Dental Hygienist in Virginia, I am writing to express my strong opposition to SB 282/HB 1036 (Foreign-Trained Dentists) and SB 178/HB 970 (Preventative Dental Assistants). SB 282/HB 1036 would allow foreign-trained dentists to practice dental hygiene without adequate verification of their education or rigorous examination, lowering the standard of care in our state. SB 178/HB 970 authorizes "preventative dental assistants" to perform scaling with power instrumentation, yet these individuals are not required to have formal, accredited education, leading to risks of improper treatment. Preventative care is not just a "simple cleaning"; it is crucial for detecting oral health issues. Allowing untrained or unregulated individuals to perform these tasks poses a significant risk to patient safety. I urge you to vote NO on these bills and protect the safety of Virginia patients. Sincerely, Katherine Rosales-Velit RDH

I am in opposition of these bills. As an RDH, it undermines patient health and safety.

I strongly oppose HB970 / SB178. As a licensed dental hygienist and a voter, I am concerned that this substandard care model lowers standards and puts patient safety at risk. The dental hygiene community in Virginia and nationwide opposes this policy as a serious public health concern. Access to care should never come at the expense of quality and oversight. I urge you to oppose this legislation.

I am writing to express my opposition against HB970 Preventative dental assistants; certification and HB1036 Dental hygienist licensure; dentists eligible to practice in a foreign country or jurisdiction. Any person holding these positions should have the highest level of education, hours in the classroom, clinical hours and pass the examinations earning certifications before treating patients.

To members of the House of Delegates, I am writing as a Virginia constituent and licensed dental hygienist to respectfully urge you to veto SB 178/HB 970 and SB 282/HB 1036. Although presented as workforce solutions, these bills weaken the educational and clinical standards that protect patients. Expanding access should never mean lowering preparation requirements for professionals who provide preventive and therapeutic care. SB 282/HB 1036 would allow dental education to substitute for graduation from a CODA-accredited dental hygiene program. Dental hygiene is a distinct, prevention-focused profession with its own curriculum and supervised clinical training. Hygienists complete thousands of hours focused on periodontal assessment, radiographic interpretation, medical risk evaluation, pharmacology, infection control, and preventive therapeutic care. These competencies are not interchangeable with dental school training. The bill offers no true educational equivalent and lowers the standard for entry into a profession responsible for early disease detection, ongoing periodontal management, and treatment of medically complex patients. Removing the CODA-accredited requirement undermines consistency, portability of licensure, and public confidence in qualifications. It also sets a precedent that professional standards may be adjusted for convenience rather than patient safety. SB 178/HB 970 raises similar concerns by expanding duties without equivalent education and clinical preparation. It would allow dental assistants to perform scaling after significantly less training. Scaling requires assessment of periodontal health, evaluation of medical histories, recognition of disease progression, understanding of anatomical considerations, and clinical judgment about when treatment is unsafe or referral is necessary. Incomplete or improper scaling can allow disease to worsen, increase systemic health risks, and lead to more complex, costly care. Preventive services must be performed by providers with the education necessary to make real-time clinical decisions that protect patients. Delegating irreversible clinical procedures without equivalent standards increases liability, diminishes accountability, and erodes clarity within the care team. Virginia has long relied on nationally recognized accreditation and licensure standards to ensure consistency and public trust. Bypassing those frameworks introduces variability, creates confusion within the workforce, and ultimately places the burden of risk on patients. Once standards are lowered, restoring them becomes far more difficult and may negatively impact long-term oral health outcomes across communities. Public health policy should prioritize prevention, safety, and evidence-based practice over expediency. I support responsible workforce solutions, including expanding hygienists’ ability to practice to the full extent of their education, strengthening education programs, improving recruitment and retention, investing in community-based preventive models, and reducing administrative barriers that limit care delivery. We can improve access without compromising training requirements or public safety protections that Virginians rely upon. Protecting standards today protects patients tomorrow. For these reasons, I respectfully urge you to veto SB 178/HB 970 and SB 282/HB 1036. Sincerely, Jhonathan Rios Registered Dental Hygienist Fairfax, VA 22030

These two bills, 940 and 1036, are a detriment to quality patient care. Dental hygienists are well trained and knowledgeable professionals. You can’t replace them with individuals with unknown training and competency without compromising patient care. What practice/doctor has the time and ability to supervise and or train such individuals while they themselves are focused on providing patient care? With 40 plus years of experience as a Prosthodontist, I most certainly oppose these bills and hope you do as well. Vote NO.

My name is Breanna Ballesteros, and I am a licensed dental hygienist practicing in Alexandria, Virginia. I recently met the rigorous requirements to become licensed here after moving from another state, and I am proud to practice in a profession held to such high standards—standards that protect patients and preserve the integrity of oral healthcare in Virginia. During dental hygiene school, I had the privilege of studying alongside an international dentist from India. She shared that while she was a trained and practicing dentist in her home country, she could not earn licensure in the United States because of family commitments and the demanding process of U.S. dental education. She decided to pursue dental hygiene as an alternative path. Despite her background, she admitted that she was taken aback by the depth and rigor of our coursework—especially in head and neck anatomy, histology, and pharmacology. She often remarked that her dental curriculum abroad did not explore these scientific concepts at the same comprehensive level. She was genuinely impressed by the structure of our clinical didactics and confessed that she learned more about the scientific foundation of oral health in our dental hygiene program than she had in dental school overseas. That experience underscored for me how distinct and academically demanding dental hygiene education truly is. I am writing today to express my strong opposition to SB 282 and HB 1036, which would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA)–accredited dental hygiene program or required clinical training hours. These bills do not address the real challenges facing the dental hygiene workforce. They will not create new licensed hygienists—instead, they threaten to drive existing professionals out of the market while lowering standards of care. Dental hygiene is not a subset of dentistry. It is a separate, prevention‑driven discipline with its own body of evidence, competencies, and educational requirements. Dental school—whether in the United States or abroad—focuses primarily on diagnosing and treating disease after it has occurred. By contrast, dental hygiene education emphasizes prevention, early detection, and long‑term patient management. It demands extensive clinical training under CODA standards to ensure hygienists graduate capable of safely and independently delivering preventive care. SB 282 and HB 1036 ignore these essential distinctions. Allowing anyone, regardless of background, to bypass accredited education undermines both patient safety and the integrity of the dental hygiene license. It sends the dangerous message that professional standards can be lowered for convenience rather than upheld for competence. Advocates may claim these bills will improve access to care, but there is no evidence that weakening licensure standards achieves that goal. The most effective solution is to strengthen support for licensed dental hygienists—allowing them to practice fully within their scope, investing in accredited programs, and creating incentives for hygienists to serve in high‑need communities. Thank you for your time, service, and dedication to protecting both patients and the dental hygiene profession.

Passing these bills does not fix the dental hygiene “shortage”. This will increase periodontal disease amongst our patients. I would say 97% of my patients have subgingival calculus. Children, as young as 10years old, can have subgingival calculus. These dentists that cannot find/keep a hygienist and say there is a shortage, is not due to a shortage, but poor office environment. Doctors are not willing to pay hygienists their worth because of INSURANCE (like Delta Dental) and their poor reimbursement fees and declining OBVIOUS scaling and root planing. In my opinion, passing this bill WILL create a hygiene shortage. Because, then, hygienists will be seeing only periodontally involved patients, creating an atmosphere of overworking our bodies (wearing down the back and wrists that much more). Then we will be forced to exit career paths that we have worked very hard to obtain. Not too long ago, our profession was working toward ridding the associates degree and moving toward a bachelor’s degree being the sole path… NOW, how is it even a consideration to remove the college degree as a requirement, and some on the side training will suffice. Not to mention, an assistant can be trained on the job to be an assistant, then can also be trained to do jobs of a hygienist with only 120 hours of extra training, compared to my bachelors degree and 3000+ hours of training. **I have never even worked with an assistant who can adequately polish off all the plaque and soft deposits. I ALWAYS have to scale off plaque because they did not brush off the plaque.*** To summarize, this would be putting our patients’ health, including yourself, at risk. Because uncontrolled periodontal disease (because that is what WILL happen) leads to many systemic diseases including, but not limited to, cardiovascular disease, stroke, diabetes, certain cancers (pancreatic, oral), dementia/Alzheimer's, rheumatoid arthritis, kidney disease, and pregnancy complications like preterm. I pray that you listen to the dental hygienists that are the professionals that specialize in dental cleanings, plus more, versus a dental insurance company that does not even pay dentists what they are worth, or dentists that have no empathy for their patients’s well being or their staff. Remember, you could be one being seen by an assistant giving you a subpar cleaning, opening you up to periodontal disease and more.

We as licensed, registered dental hygienists are highly educated and qualified to do advanced instrumentation to disrupt dangerous biofilm from above and below the gum surfaces. The most dangerous bacteria thrives under the gums’ surface. An assistant, who can only clean above this tissue, is causing more harm than good, as it does not remove the most virulent strains of anaerobic bacteria. The patient will perceive the that they have had their teeth”cleaned” and be none the wiser. CODA accredited dental hygiene programs have their students log over 3,000 hours of clinical and didactic coursework. The proposed legislation is an on-the-job certification with 120 hours and no standardized instruction. Who benefits here. Certainly not the unknowing citizen. With the foreign trained dentist bill, again clinical competency is not proven. There are more than 1000 dental schools worldwide with all kinds of curriculums. Restorative care is the focus of dental schools worldwide, not preventative and therapeutic gum treatment. Even in the USA, dental students only get about 6 weeks of preventative and therapeutic gum treatment education. For these reasons, I align myself with the opposition to both of theses proposed bills. I do not support either. Thanks, Maureen McCann Sawin, RDH, BSDH 44 years of practice for the citizens of Virginia

As a dental hygienist, I have significant concerns about the Preventative Dental Assistant certification. While I fully support education and professional development within the dental team, I believe this particular certification blurs important distinctions between the roles of hygienists and assistants. Dental hygienists complete extensive accredited education and clinical training to safely perform preventive procedures such as scaling, polishing, and patient assessment. Expanding similar duties through a shorter certification pathway can feel like it diminishes the depth of training and accountability that hygienists are held to. It also risks creating confusion for patients about qualifications and standards of care. My opposition is not directed at dental assistants themselves. I value their contributions greatly. Rather, my concern is about maintaining clear professional standards, protecting patient safety, and ensuring that preventive services are delivered by providers with the comprehensive education designed specifically for that scope of practice. Thank YOU

I do not support hb970 nor hb1036. I feel these bills fail to represent the values in treatment our citizens deserve.

I'm a patient, and I do not support these bills.

I am a practicing dental hygienist of almost 30 years in this state. I was educated and continue to educate myself in a field that is continually changing. I consider it paramount when treating my patient base. These three bills would not only jeopardize current standards but they would encourage substandard care by allowing persons who have not received adequate training to work on the unsuspecting public. Hygienists receive and maintain thousands of both didactic and clinical practice hours throughout their careers. It is an essential profession at a time when access to care is difficult. Please consider the overall impact to the health of the public. This will be the thing that suffers the most if this is allowed to pass.

I oppose passage of bills allowing dental assistants to supra scaling teeth. Lack of training and non licensure is an issue. What they would be doing would be more of cosmetic than therapeutic. Registered dental hygienists have at least 3000 hours of instruction and practical experience, then take boards and receive a license. As for foreign trained dentists, their curriculum isn't the same as for dental schools in the United States and woefully in adequate. They would have no license either. Both of these bills would put the public in danger and could possibly have dire results. Only licensed professionals should perform these tasks. It could mean your life.

I am writing in opposition of HB 970 and HB 1036. I’m a Registered Dental Hygienist that has practiced for over 30 years, I’m concerned about my profession, and the quality of patient care if these bills pass in Virginia. Dental Hygienists have a degree that includes thousands of hours of classroom and clinical training, a license to practice, we have passed National and State Boards, as well as a clinical exam. In addition, we must complete yearly continuing education to maintain our license. This legislation being proposed in Virginia would allow for unlicensed people, without a degree in dental hygiene to provide Dental Hygiene patient care. In addition to undervaluing my profession, it would put the quality of patient care at risk. As licensed dental hygienists, we do not just “clean teeth”. We administer local anesthesia, provide periodontal care, know the medical/systemic link between a patient’s oral health and their overall health, provide oral cancer screenings, take blood pressure…along with countless other preventative procedures that go unnoticed. (for example, when antibiotic premeditation is necessary prior to a “dental cleaning” for certain heart conditions and joint replacements, medications and their effects on a patient’s oral health, how to lower the risk of decay through oral hygiene instruction, product recommendations and diet as it relates to the risk of decay and acid reflux) Over my career as a licensed Dental Hygienist, I have found oral cancer and sent patients to have precancerous cells (dysplasia) removed, referred patients to their physician for previously undiagnosed conditions, such as high blood pressure and heart issues. In other words I have not only “cleaned teeth”, but saved lives. Ask yourself these questions: Who would YOU rather see for your next dental cleaning, an unlicensed person with limited training and minimal oversight, or a licensed dental professional? What other professions would YOU consider it acceptable to lower standards to help with a workforce shortage? Registered nurses, teachers, engineers? The answer should be none because lowering standards puts the health and safety of others at risk. How would you feel if YOU were in the hospital and being seen by an unlicensed nurse, if YOUR child was being taught by an under qualified teacher, or if YOUR roads, bridges or buildings were constructed by someone trained on the job? Lowering standards is never an acceptable solution a workforce shortage, for us as licensed dental hygienists, or for any other profession. It just degrades the standards of education, patient care and safety. Sincerely, Mary Lewis, RDH

As a nationally certified dental assistant with over 30 years of experience and a registered dental hygienist for more than 20 years, I have seen the serious consequences that occur when dental teams are overextended and patients receive incomplete or improper care. When calculus is present above the gumline, there is always disease‑causing bacteria below it, and safe treatment requires far more than simply removing deposits. Every patient deserves a full periodontal evaluation, oral pathology screening, accurate radiographic interpretation, understanding of microbiology, assessment of airway and breathing issues, and recognition of jaw dysfunction—these are essential components of the standard of care. HB 970 and HB 1036 do not relieve the pressures on dentists or hygienists; instead, they create competition for the same clinical tasks while introducing a minimally trained provider who cannot meet the educational standards required for safe practice. Even internationally trained dentists must complete Commission on Dental Accreditation (CODA)‑approved education before treating patients in the United States, because CODA establishes the minimum level of competency needed to protect the public. Creating an OPA role without CODA‑level training undermines that standard and risks a system of supervised neglect, where patients are unaware that the care they receive is below accepted clinical expectations. A friendly personality can easily mask inadequate training, but it cannot protect patients from the oral‑systemic consequences of untreated or improperly treated disease, including diabetes, heart disease, and atherosclerosis. These bills would disproportionately impact low‑income and underserved communities, where access to fully trained providers is already limited, effectively lowering the standard of care for the very populations who need the highest level of protection. The real solution is increasing the number of dentists in underserved areas and allowing registered dental hygienists to practice to their full scope—not creating a shortcut pathway that compromises patient safety. To protect the public from sub‑standard treatment and prevent further strain on the dental workforce, I strongly urge a NO vote on HB 970 and HB 1036.

I strongly encourage the opposition of both HB970 and HB1036. HB970 would create a huge concern for patient safety, disease control, and adequate dental hygiene care. When only supragingival scaling is performed, bacteria is left to harbor below the gum-line leading to an increased prevalence of periodontal diseases. When these diseases are left undiagnosed and untreated, they continue to contribute to patient harm, irreversible bone loss, and many systemic conditions such as diabetes, hypertension, rheumatoid arthritis, and alzheimers to name a few. Supragingival scaling is not the answer. Preventative dental assistants would receive only a fraction of education that a licensed dental hygienist does; hygienists are trained through years of schooling, 900+ course hours, and 300+ clinical hours with a strict clinical educational schedule to ensure proper and adequate patient care. This cannot be replicated through the 120 hours proposed to train an assistant to do preventative work. Also, there is currently no CDT insurance code to cover "supragingival only" scaling, so not only would this be a harm to patients, but it would also be fraudulent to insurance companies and patients. Patients would leave the office thinking they got the same cleaning they've always gotten, but really, bacteria is left under the gum-line that they cannot reach themselves at home. Lastly, there would be no regulatory board for these preventative assistants as they would not be licensed-who would be responsible for regulating them? HB1036 presents similar concerns. Dentists and hygienist are trained on two separate subjects. Hygienists are prevention specialists, and dentists only receive a fraction of the training that a hygienist does when it comes to periodontal diseases and conditions. Foreign dentists are trained in dentistry, not dental hygiene, and this would create a major concern for patient safety and diagnosis of periodontal conditions. As mentioned previously, when these diseases are left unchecked and untreated, a patient can result in infection, irreversible bone loss, loss of teeth, ridge collapse, bite problems, and many more conditions within the oral cavity that are completely preventable with a licensed professional, the dental hygienist. Thank you for taking the time to read these comments, and I strongly hope you take these points into consideration when voting on these bills, A very concerned dental hygiene student

I strongly encourage the opposition of the HB 970 and HB 1036, these bills would allow dental assistants to do on the job training and foreign trained dentist to come into US and practice without licensure from an accredited dental hygiene program. This is very alarming and puts the public health at risk. We as hygienist are preventative healthcare specialist and are trained to scale below the gumline which is where the bacteria are that causes diseases such as heart disease, diabetes, and periodontal diseases. This bill would allow a dental assistant to scale below the gumline without any licensure and only 120 hrs. of on-the-job training. Where we as dental hygienist have 300+ clinical hrs. and 900+ lecture hrs. to be able to provide safe care to our patients and we have to have a national board licensure. If these bills pass, we are going to see an uprise in diseases, as oral healthcare is the systemic link to the body. Please consider your decision as you read this.

I oppose being treated by these unlicensed, unregulated, and uneducated individuals. I only want to be seen as a registered dental hygienist for my preventive dental appointments

I am a Registered Dental Hygienist who has been practicing for 21 years. I strongly oppose these bills. I will make this short and sweet as many have repeatedly outlined our concerns. We had 1000's of hours of education and training to be able to practice safely. Under this bill, dental assistants will have a mere 120 "training hours". These training hours can be completed on a mannequin. Dentists and Dental Hygienists learned to scale (above and below the gum line) on REAL people, not mannequins. We had strict supervision during school to ensure patient safety. This just one small example of how risky this bill is the current form! Why are we lowering our standards to this degree? Please oppose this bill, and we can find a safer solution for our patients. Thank you for your consideration.

Dear Members of the Virginia Legislature: I am writing on behalf of myself and the West Virginia Dental Hygienists' Association to strongly oppose HB1036 and HB970. We fully support thoughtful solutions that expand access to care. However, these bills move forward without adequate safeguards to ensure patient safety and clinical competency. We can not allow dentistry to undermine the profession of dental hygiene, claiming to be expanding access to care, while ultimately profiting from employing less qualified individuals to provided sub standard care. HB1036 allows internationally trained dentists to practice as dental hygienists without a clearly defined process to verify competency in clinical instrumentation and non-surgical periodontal therapy. Dental hygiene education is specifically designed to develop advanced scaling techniques, periodontal assessment skills, and preventive care expertise. Without objective evaluation and standardized clinical validation, there is no assurance that individuals entering hygiene practice through this pathway possess the hands-on proficiency necessary to deliver safe and effective care. HB970 would allow dental assistants to perform supragingival scaling with only on-the-job training. Scaling is not a superficial procedure. A prophylaxis requires removal of deposits from the entire tooth structure, including subgingival areas where periodontal disease begins. Fragmenting this responsibility risks incomplete treatment, delayed diagnosis of periodontal disease, and confusion in documentation and billing. These changes could unintentionally expose practices to compliance risks while lowering the standard of preventive care. The citizens of Virginia deserve access to care that is both available and safe. Adjusting scope-of-practice laws without rigorous competency standards undermines the integrity of the dental team model and places patients at unnecessary risk. We respectfully urge you to oppose HB1036 and HB970 and instead work collaboratively with dental hygiene professionals to develop solutions that expand access without compromising patient safety or professional standards. Thank you for your leadership and service. Lauren N French, BSDH, RDH, CTTS, CDIPC

As a licensed dental hygienist and dental hygiene educator, I strongly urge you to oppose HB 1036. HB 1036 does not create a pathway for internationally trained dentists to practice dentistry. Instead, it permits substitution of dental education for licensure in an entirely different profession — dental hygiene — without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dentistry and dental hygiene are separate disciplines with distinct curricula, competencies, and clinical expectations. Virginia’s licensure framework is designed so that every patient, in every community, can trust that providers have met uniform and rigorous standards. Allowing one profession’s education to replace another’s — or reducing preparation for complex preventive procedures — changes that expectation and weakens an important safeguard for the public. Please stand up for our dental patients health and educational standards/proper licensure. Please oppose HB 1036 . Respectfully, Kendra Horton, MSDH,RDH

As a patient and a mother I and my children only want to be treated by a registered dental hygienist for our dental needs. I oppose being treated by an unlicensed, unregulated, and uneducated individual.

Good morning as a clinician and educator of dental hygienist and dental assistance I want to express my concern for the two above bills. I do teach foreign dentist and I must say that they’re training is very different and that we need to be careful on the instruments they’re using because I’ve had students that could not differentiate between an exploratory instrument and an actual instrumentation instrument. We’re putting our citizens at risk to try to fill avoid that is not there. The void is due to not having the dental hygiene programs being able to open because of the strict accreditation I have just been honored to be chosen to be the program Director for a new dental hygiene school here in Richmond and I must say I am honored to be able to teach these future dental hygienist. I do believe that if these bills are passed, we’re going to see an increase of workplace accidents and malpractice suits for all of Virginia dental care. I am open to talking to anyone about this and express my concern. Being in the dental field for over 30 some years and being in Virginia, this is absolutely heartbreaking as it will diminish our whole profession. Thank you for taking the time to read this and I hope that you make the right decision.

Please OPPOSE, as a patient I want a certified dental hygienist that went to school to perform any cleaning. A dental assistant does not have the education to be able to perform cleanings. That is why they are given the title “assistant”. I appreciate your time in the matter! Respectfully yours Buffie Dennis

Just like nurses, this is a profession. People want experience and knowledge for their care.

After attending the Health and Human Services sub-committee meeting on 2/5/2026, it was clear there was misunderstanding of the concepts of dental hygiene education and practice for the committee members. There are foundational differences in the education of dentists and dental hygienists - dental hygiene is not a subset of dentistry, it is its own entity. Dentists are primarily responsible for diagnosing oral disease and restoring hard tissue, with other specialities addressing more niche applications such as oral surgery and orthodontics. Dental hygienists are primarily responsible for the prevention and treatment of oral disease related to the periodontium (the gum tissue and supporting bone). Dental hygienists receive a thorough education to assess, diagnose, treat, and evaluate oral health conditions such as gingivitis and periodontal disease. This education includes courses in dental anatomy, radiology, pharmacology, theory and practices, ethics, pathology, oral anesthesia, dental materials, and a large number of clinical hours spent practicing dental hygiene care. Dental students at VCU receive education on dental hygiene instrumentation in one lecture, one lab session on a student partner, and one simulation model before performing cleanings on their restorative patients. Dental hygienist students spend their entire 2 years dedicated to this study after 2 years of pre-requisite courses. The skills required for scaling teeth effectively are very different from those required to prepare teeth for restorations such as fillings and crowns. I am in no way discounting the difficulty and skill level of dentists; however, I am saying that the skills they have are not interchangeable with the skills that dental hygienists have worked for years to hone. The conversation of the delegates quickly strayed from what this bill is actually about. The bill related to foreign trained dentists is not a problem of immigration or workers - it is a problem because dentists are not trained to be dental hygienists. Avenues to allow foreign trained dentists to be dentists would be more appropriate, as that is the speciality they were trained in. In summary, dentists treat the teeth, hygienists treat the gums – they are two very important and different aspects of your mouth that contribute to your oral health. I urge the legislators to do their duty by opposing this bill. Listen to the experts on periodontal oral health prevention, the dental hygienists, and make informed decisions that protect public safety.

I am in extreme opposition of both hb 970 and hb 1036. I am a registered dental hygienist with 19 years experience and it is completely negligent to know what we know about preventative dentistry these days and be ok with this. It would be like taking a step backwards and everyones’s (including yours) oral health will decline. We will likely see an increase in periodontal disease (gum disease) and that will only allow for more money in the greedy insurance company’s pockets. I spent $60,000 on my education and it is a complete slap in the face tha this is even being considered! Think with your heads and not your pockets!

No to assistants doing rdh job without full college degree

As a member of the general public, these bills make me worry about my health and safety surrounding my oral health. I watched my daughter go through the trials of dental hygiene school and understand the importance of her job. Unfortunately, my dentist does not always have a dental hygienist at his office. I can tell the difference between a dentist and a dental hygienist providing oral care. A dental hygienist role solely focuses on prevention. If my daughter had tissue damage on her boards exam she automatically failed. Who is going to assess these new providers skill set before they see patients. Dental hygienist practice on dummy’s and other students before seeing a patient. Who will an OPA practice on? Foreign trained dentist do not share the same standards of education in the United States. Many countries do not provide preventative dentistry. They see a dentist as someone you go to once you’re in pain. The reality is dental pain and gum disease is preventable by licensed, board-certified providers. This bill lowers the standards of people who can provide this care, potentially risking public health and dental hygiene.

As a member of the general public, these bills make me worry about my health and safety surrounding my oral health. I watched my daughter go through the trials of dental hygiene school and understand the importance of her job. Unfortunately, my dentist does not always have a dental hygienist at his office. I can tell the difference between a dentist and a dental hygienist providing oral care. A dental hygienist role solely focuses on prevention. If my daughter had tissue damage on her boards exam she automatically failed. Who is going to assess these new providers skill set before they see patients. Dental hygienist practice on dummy’s and other students before seeing a patient. Who will an OPA practice on? Foreign trained dentist do not share the same standards of education in the United States. Many countries do not provide preventative dentistry. They see a dentist as someone you go to once you’re in pain. The reality is dental pain and gum disease is preventable by licensed, board-certified providers. This bill lowers the standards of people who can provide this care, potentially risking public health and dental hygiene.

As a member of the general public, these bills make me worry about my health and safety surrounding my oral health. I watched my daughter go through the trials of dental hygiene school and understand the importance of her job. Unfortunately, my dentist does not always have a dental hygienist at his office. I can tell the difference between a dentist and a dental hygienist providing oral care. A dental hygienist role solely focuses on prevention. If my daughter had tissue damage on her boards exam she automatically failed. Who is going to assess these new providers skill set before they see patients. Dental hygienist practice on dummy’s and other students before seeing a patient. Who will an OPA practice on? Foreign trained dentist do not share the same standards of education in the United States. Many countries do not provide preventative dentistry. They see a dentist as someone you go to once you’re in pain. The reality is dental pain and gum disease is preventable by licensed, board-certified providers. This bill lowers the standards of people who can provide this care, potentially risking public health and dental hygiene.

Dear Legislator, I am writing to express my strong opposition to SB 178/HB 970, which would allow dental assistants with on-the-job training to perform tasks that belong within the scope of licensed dental hygienists under the proposed “Preventative Dental Assistant” model. This legislation is a significant step backward for oral healthcare in Virginia because it does not prioritize patient safety or the educational and clinical competencies required for safe, evidence‑based dental hygiene practice. Scaling requires advanced instrumentation skills, assessment, and critical clinical judgment. These competencies are taught exclusively in Commission on Dental Accreditation (CODA)–accredited dental hygiene programs and performed by licensed dental hygienists. Allowing unlicensed personnel to perform these procedures jeopardizes patient safety and undermines the integrity of the dental hygiene profession. Beyond clinical concerns, SB 178 and HB 970 introduce serious insurance, billing, and legal risks. Because “Preventative Dental Assistants” cannot perform a complete prophylaxis, clinics would be unable to bill using the D1110 code. Instead, they must rely on the D1999 “unspecified preventive procedure” code, which requires narrative justification and is reimbursed at a significantly lower rate. This creates financial pressure that may lead to improper coding, misrepresentation of services, or billing for incomplete care. Such scenarios expose practices to insurance disputes, audits, and potential allegations of fraud. When unlicensed personnel perform procedures outside their legal scope, any resulting claim submitted to insurers—including Medicaid—may be considered inaccurate or misleading. This puts supervising dentists and practice owners at risk of violating the False Claims Act, which carries severe civil penalties, repayment obligations, and reputational harm. These risks are well documented by the American Dental Hygienists’ Association and should not be overlooked. If enacted, SB 178 and HB 970 would reduce professional standards, compromise patient safety, and expose Virginia dental practices to unnecessary legal and financial liability. The most effective and evidence‑based way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope and to invest in proven strategies that strengthen the existing dental workforce. The “Preventative Dental Assistant” model introduces risk without delivering meaningful benefit. As a dental hygienist, I see firsthand how deeply this issue affects our profession and the patients we serve. I urge you to oppose SB 178/HB 970 and ensure that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your service and consideration. Sincerely, Matilda Minassian

As a member of the general public, these bills make me worry about my health and safety surrounding my oral health. I watched my daughter go through the trials of dental hygiene school and understand the importance of her job. Unfortunately, my dentist does not always have a dental hygienist at his office. I can tell the difference between a dentist and a dental hygienist providing oral care. A dental hygienist role solely focuses on prevention. If my daughter had tissue damage on her boards exam she automatically failed. Who is going to assess these new providers skill set before they see patients. Dental hygienist practice on dummy’s and other students before seeing a patient. Who will an OPA practice on? Foreign trained dentist do not share the same standards of education in the United States. Many countries do not provide preventative dentistry. They see a dentist as someone you go to once you’re in pain. The reality is dental pain and gum disease is preventable by licensed, board-certified providers. This bill lowers the standards of people who can provide this care, potentially risking public health and dental hygiene.

Oppose all of these bills!! I want a coda accredited licensed dental hygienist providing my care!!

I am writing to express my strong opposition to HB970, which aims to permit preventative dental assistants to practice without the comprehensive training currently required, and HB1036, which allows foreign-trained dentists to become eligible for dental hygiene licensure. These measures pose significant risks to patient safety and the effectiveness of dental hygiene care. First and foremost, dental hygiene education in the United States is a rigorous process that typically spans two to four years, encompassing a wide array of critical subjects such as microbiology, anatomy, pharmacology, pathology, and much more. This extensive curriculum equips future dental hygienists with the essential knowledge and skills necessary to provide safe and effective patient care. The hands-on clinical experience gained during this training is paramount, as it allows students to perfect their skills in a supervised environment. This vital training cannot be adequately replaced or condensed into a mere 120-hour program, as proposed in HB970. Such a reduction in training time not only endangers patient safety but also increases the risk of developing or worsening dental diseases among vulnerable populations. Moreover, while foreign-trained dentists may have varying degrees of expertise in their home countries, they do not receive the same quality of education and training as those who complete dental hygiene programs in the United States. If foreign-trained dentists wish to pursue a career in dental hygiene, they should be required to enroll in and complete an accredited dental hygiene program. This approach would ensure that all dental hygienists, regardless of their background, possess the necessary training and knowledge to provide high-quality care to patients. To address the apparent shortage of dental professionals, rather than diluting the standards of education and practice, we should focus on increasing access to dental hygiene education by opening more dental hygiene schools. This approach would not only maintain the integrity and safety of patient care but also cultivate a new generation of qualified dental hygienists who are prepared to meet the demands of our communities. In conclusion, I strongly advocate against HB970 and HB1036. It is vital that we maintain high educational standards for dental hygiene practice to ensure the safety of patients and the quality of care they receive. I urge you to reconsider these bills and focus on sustainable solutions that uphold the integrity of dental hygiene education. Thank you for your attention to this important matter.

As a member of the general public, these bills make me worry about my health and safety surrounding my oral health. I've had a dental hygienist provide preventative care and maintenance to my teeth my whole life. This bill lowers the standards of people who can provide this care, potentially risking overall public health and dental hygiene.

As a member of the general public, these bills make me worry about my health and safety surrounding my oral health. I've had a dental hygienist provide preventative care and maintenance to my teeth my whole life. This bill lowers the standards of people who can provide this care, potentially risking overall public health and dental hygiene.

Opposing HB970/SB178, HB1036/SB282 Registered Dental Hygienists (RDH) receive a thorough education to assess, and treat oral health conditions, such as gingivitis & periodontal disease. This education includes courses in dental anatomy, radiology, pharmacology, nutrition, microbiology, anatomy & physiology, ethics, pathology, & many clinical hours spent practicing dental hygiene instrumentation. There is a clear misconception that some scaling above the gum line is better than no scaling. It is harmful to the patient to only have supragingival (above the gum line) deposits removed. Data shows that over 75% of American adults have some form of gum disease, while over 60% of older teens have gingivitis. The ADA standard of care for healthy patients is a dental prophylaxis by definition-scaling above the gum line; while patients diagnosed with gingivitis & periodontitis require therapeutic, subgingival (below the gum line) scaling. Based on this data, this Bill is designed to address ONLY approximately 25% of adults and teens. When buildup is removed above the gum line, the tissue begins to heal & tighten around the tooth, trapping the remaining calculus deposits & bacteria below the gum line, with risk of forming a periodontal abscess. Periodontal disease has been linked to systemic health conditions, e.g. premature delivery in expectant mothers, low birth weight, coronary artery disease, Alzheimer’s disease. It exacerbates diabetes; when there is infection in the periodontium, glucose levels may become elevated, which in turn slows the healing process with potential to lose bone, a vicious cycle. Without proper subgingival instrumentation to remove calculus deposits & bacteria, these patients WILL lose teeth. Putting our patients in the hands of someone who is not Board licensed is completely unacceptable. For example, an Oral Preventive Assistant (OPA) will not have the wherewithal to take pause while reviewing medical history when the patient reports having had a recent heart attack, a heart valve replaced, or a recent knee or hip replacement. Did you know that there are specific guidelines set forth to protect patients from harm in these instances? The OPA may cause permanent damage to tooth structure by using the hand instruments & ultrasonic scaler incorrectly. Did you know that root surface is SEVEN times softer than enamel? The OPA model has the potential to lead to higher rates of undiagnosed oral disease, negatively impact systemic health in many individuals, lead to higher rates of tooth loss, & put the public in harm's way. Quite frankly, I believe, there may be more malpractice lawsuits against the dentists for the failure to assess, diagnose & treat periodontal disease to the standard set forth by the ADA. Dentists who believe these auxiliaries will save them money in salaries, & boost production; may potentially spend more on malpractice premiums & potentially attorney fees. The OPA will not be licensed by a Board, and likely to not hold malpractice ins. I urge the legislators to do their duty by opposing this bill. When was YOUR last dental prophylaxis? Who would YOU rather have treating you, your spouse, your children? A Board licensed RDH with over 3000 hours of education, that includes extensive hands-on training, often totaling over 600 to 800+ hours of direct patient care in a clinic setting? OR, an OPA with approximately 120 hours of on-the-job training? If you pass this legislation, be prepared for subpar.

I vehemently oppose HB 970 as it will lower the safe standards of care for all dental patients in the Commonwealth of Virginia. I vehemently oppose HB 1036 as it will lower the safe standards of care for all dental patients in the Commonwealth of Virginia. I vehemently oppose SB 178 as it will lower the safe standards of care for all dental patients in the Commonwealth of Virginia. I vehemently oppose SB 282 as it will lower the safe standards of care for all dental patients in the Commonwealth of Virginia.

I strongly oppose SB 178 / HB 970 and SB 282 / HB 1036, which significantly lower the standards of care for preventive dental services in the Commonwealth of Virginia. It comprises patient safety and puts their overall health at risk if bacteria is not removed from below the gum line. Dental providers should all be held to the same standards and have to pass the same boards. As a patient, would you want someone with little knowledge of how to use sharp instruments scrape under your gums? Dental hygienist have to take many didactic courses to understand the mouth/ body connection even before they pick up an instrument. We have to have over 120 clinical hours of supervised practice and take clinical and written boards before we can safely see a patient. It is absurd we are holding other dental professionals to sub standards. Everyone should have to take a written and clinical boards to ensure patient safety. Lowering professional standards does not solve access issues. It has not increased access to care in Arizona as research shows. It compromises care, increases long-term healthcare costs, and erodes public trust. Patients deserve care provided by educated, licensed, and board-certified dental hygienists—anything less is unacceptable. I have spoken to my patients in regards to this bill and they strongly oppose it as well. They want a licensed professional and understand the value a dental hygienist can provide. We do not just “clean” teeth. We take vitals, review medical history, take radiographs, do an external and internal oral cancer screening, take accurate gum measurements to determine bone levels, scale, polish, provide oral hygiene instructions, discuss caries prevention, write necessary referrals, provide preventative fluoride/curodont/ sealant treatments, manage chronic inflammatory gum disease, and lower overall bacteria levels to prevent heart attack/stroke, Alzheimer’s/dementia, low birth weight/preterm birth, cancer, etc. The bacteria in the mouth is connected to the rest of the body. If not treated properly we are putting patients more at risk for these diseases. It isn’t even about teeth anymore, but patients’ overall health.

My name is Emily Jones, and I am a current dental hygiene student at Wytheville Community College. I am writing to you regarding bills HB970 and HB1036. It would be in the best interest of public health to oppose this legislation. The bills state that Preventive Dental Assistants will be able to scale supragingivally on patients after a training period. If preventative dental assistants are performing supragingival scaling only, they will leave plaque, calculus, and bacteria below the gumline. Periodontitis, a disease that I have tediously studied over my years in dental hygiene school, is caused by leaving plaque, calculus, and bacteria below the gumline. This allows for the growth of the foreign substance, which will cause a deep pocket to form between the gums and tooth. These periodontal infections will continue to spread and will lead to bone loss. Additionally, leaving foreign substances in the pockets, but allowing the most coronal portion of the tissue to readapt to the tooth surface, can lead to periodontal abscesses due to the trapped bacteria. “A periodontal abscess forms when bacteria from your mouth invade the space between your teeth and gums.” One could oppose my argument by saying that the dentist will follow behind the preventative assistant to provide the subgingival (below the gumline) scaling to patients; however, dentists would have to schedule less restorative work to have the time to make this work and provide patients with complete care. Many dental school curricula only require dentists to spend three weeks learning what a dental hygienist spends at least two years specializing in. In either scenario, the preventative dental assistant or dentist would be providing a disservice to the patient. It is unethical and seems monetarily motivated. If the bill really was created due to the shortage of dental hygienists, then why would we lower educational requirements and put patients in danger rather than provide more funding to dental hygiene programs to produce more hygienists for the workforce? Perhaps it's because it would cost us less to pay someone to do a lesser job. Once again proving that this is unethical and monetarily motivated. Your support in opposing these bills would be extremely valuable to me, those in my profession, and the general public as a whole. Thank you for your time and consideration. Emily Jones

There is a standard of care expected and deserved by the citizens of Virginia and this does not meet it. Foreign trained dentists should have to prove they have the same education and clinical skill set as US trained dentists to obtain their dental license. Once obtaining their dental license, they are dentists! They can perform cleanings! Still help the alleged shortage! Why isn’t this about them getting their dental license? Why is it so they can do dental hygiene only? Is it out of concern that their training wasn't actually good enough?Stop and think: if it sounds too risky to fast-track them into being dentists, why would we do it at all? This is lowering the quality of dental care and is a disservice to patients. Standards have to be set and upheld, regulations in place to ensure safety for patients. If we are substituting any doctor license for any other doctor license, it’s kind of like: having your cardiologist do your colonoscopy; having your dogs veterinarian doing your lasik; having your gynecologist do your joint replacement; or having your psychiatrist do your plastic surgery. The job may “get done”. But what is the aftermath going to look like? I strongly opposeHB 1036 They are dentists there, They can become dentists here. Follow the necessary steps instead of cutting corners. They are not hygienists and therefor should not be substituting for hygienists. Hygienists should be licensed and CODA trained professionals.

I strongly oppose SB 178 / HB 970 and SB 282 / HB 1036, which significantly lower the standards of care for preventive dental services in the Commonwealth of Virginia. Lowering professional standards does not solve access issues. It compromises care, increases long-term healthcare costs, and erodes public trust. Patients deserve care provided by educated, licensed, and board-certified dental hygienists—anything less is unacceptable.

Honorable Committee Members: As the Coordinator of a Dental Hygiene Program in Virginia, I’m submitting this on behalf of the dental hygiene students. At their first SADHA (Student American Hygienists’ Association) meeting, their first item of business was advocacy. Please view the link to watch the video they created for all legislators voting on HB 1036 (SB 282) which would allow foreign trained dentists who do not receive CODA-accredited education and training to practice dental hygiene. Thank you for your time and consideration. https://youtu.be/KRAMH92mDHA

I am urging you as a Registered Dental Hygienists to oppose said bills allowing dental Assistants to scale teeth. It doesn't serve the public oral health without educated licensed professionals like Hygienists. This bill will not solve long time to be seen for cleanings. According to the VDA plan DA will clean above the gums but requires scaling below the gums they will need a second appointment. Many patients will not come back. This will increase periodontal disease. I am aRDH practicing for 32 years. Please reconsider moving forward on these bills.

I am writing to respectfully, but strongly, oppose HB 1036, which would allow internationally trained dentists to practice as dental hygienists in Virginia without a clearly defined mechanism to verify competency in clinical instrumentation and non-surgical periodontal therapy. Access to care is an important and urgent goal; however, expanding the workforce at the expense of validated clinical competence poses a substantial risk to patient safety and standards of care. I am a dental hygienist with over 30 years of clinical experience, a doctoral degree, and more than a decade of service as an ADEX examiner. In that role, I have repeatedly observed internationally trained dentists struggle with fundamental principles and techniques of scaling and periodontal therapy, including failure on manikin-based examinations designed to assess minimal clinical competence. If an individual cannot demonstrate safe and effective instrumentation on a manikin under controlled conditions, it is deeply concerning to consider the implications for treatment on live patients with complex periodontal needs. As a dental hygiene educator for the past 10 years, I have participated in graduating students who are minimally competent only after more than 400 hours of combined didactic and supervised clinical education in periodontal assessment, instrumentation, and non-surgical therapy. That level of focused preparation is foundational, not optional, for safe delivery of periodontal care. In many international dental curricula, general dentists do not receive an equivalent depth or duration of periodontal training; unless they pursue specialty education, their exposure is often significantly less than that of a U.S.-trained dental hygienist. Allowing individuals to function as hygienists without documented equivalency in education, clinical hours, and demonstrated competence effectively creates a two-tier standard of care for Virginia patients. Periodontal disease remains heavily underdiagnosed and undertreated, and hygienists are often the first line in identifying, managing, and co-diagnosing these conditions. Permitting providers to perform scaling and root debridement without robust understanding of disease etiology, risk assessment, staging and grading, and evidence-based non-surgical therapy is not simply a workforce issue; it is a public safety issue. A poorly executed periodontal assessment or instrumentation sequence can contribute to disease progression, missed diagnosis of systemic risk, and increased long-term cost and burden of care for patients and the healthcare system. If the Commonwealth is seeking strategies to address workforce shortages and improve access, there are safer, evidence-informed avenues available. Many states, including Maine and Colorado, have successfully expanded the scope and practice settings of licensed dental hygienists—who already possess validated training in periodontal therapy—to enhance access in underserved communities. Leveraging and appropriately expanding the role of hygienists, rather than lowering the threshold for entry into hygiene practice, would better protect the public while advancing access to care. For these reasons I urge you to oppose HB 1036 in its current form and instead, consider policies that both safeguard the public and fully utilize the expertise of licensed dental hygienists in Virginia. Respectfully submitted, Dr. Joy Void-Holmes, DHS, BSDH, RDH

I opposed both bills. This is not a solution. This will not only affect patient care negatively, but this will also be a huge liability for the dentist. We as dental hygienist have extensive training with a written board examination and clinical board examination. I strongly oppose both bills!

As a patient & licensed practicing dental hygienist I strongly OPPOSE HB970 & HB1036. I have read over many of the comments already provided and have not seen one that supports the bill. My vast experience of practicing clinical dental hygiene in various settings throughout the state of Virginia has afforded me a unique perspective of the challenges of operating a dental office and providing care for those who come for treatment. Challenging is an understatement. So the question should be "How can we best care for our patients?" This bill is NOT the answer. Dental practices are extremely busy, with little down time. I am so disappointed that some associated with the VDA think that this bill will actually address the issue of a "dental hygiene workforce issue." Perhaps they do not fully understand the concept of what a dental hygienist actually does due to the limited dental hygiene education provided during their education in dentistry. Please keep in mind that dentists perform "restorative" treatment and dental hygienists perform "preventive" treatment. Dental school education does not provide the extensive skills and knowledge that a CODA dental hygiene education does. In the offices that I have been employed, the dentist and dental hygienist have different clinical roles. The dentist is the "fixer" and the dental hygienist is the "preserver/preventer." My gut feeling (I've been practicing over 46 years) tells me that this bill stems from a greater issue within the dental and healthcare community - insurance reimbursement. Over the years, insurance seems to have undermined our healthcare and at the same time, creeped more and more into healthcare practices. It's more about the money than the care of the patient. This is disturbing to me as a hygienist and as an (aging) patient. I do not want a foreign trained dentist who has not met all CODA dental hygiene criteria and passed written and clinical competency tests to provide my care, nor do I want this individual to provide care to any of my family, friends, patients or YOU! I respectfully ask that you OPPOSE HB970 & HB1036 and protect the citizens in this great Commonwealth of Virginia.

I am in complete opposition of these propositions. I am a registered dental hygienist and I know that a degree in dental hygiene is necessary to provide adequate oral health care. I have been in the dental field for over eight years now and I firmly believe these bills will set us back and cause irreversible damage. Please do not pass these bills.

To Whom it May Concern, My name is Karyn Carr Porter and I am a dental hygienist from Maryland with 16 years of clinical practice experience in the profession of dental hygiene. I work in public health in Maryland and see mainly medically compromised patients. My 1000+ hours of education through the University of Maryland School of Dentistry Dental Hygiene Baccalaureate program has prepared me for treating these medically compromised patients safely for their dental hygiene needs. Allowing HB970 to be passed would allow dental assistants to do scaling similar to my job without the formal education and hours of training that dental hygienists are held to. This on-the-job training puts the patient’s health at risk, increases the risk of gingival injury to the patient and systemic health risk. Also, allowing HB1036 to pass would lower the educational and training standards to allow foreign trained dentists to preform dental hygiene services without the same formal education and clinical training standards of a US program. I urge you to realize that increasing access to care should not come at an increase to the public’s health and safety during that care. Please vote no for HB970 and HB1036. Thank you!

I am writing to express my strong opposition to SB 178/HB 970, which would allow dental assistants with on-the-job training to perform tasks that belong within the scope of licensed dental hygienists under the proposed “Preventative Dental Assistant” model. This legislation is a significant step backward for oral healthcare in Virginia because it does not prioritize patient safety or the educational and clinical competencies required for safe, evidence‑based dental hygiene practice. Scaling requires advanced instrumentation skills, assessment, and critical clinical judgment. These competencies are taught exclusively in Commission on Dental Accreditation (CODA)–accredited dental hygiene programs and performed by licensed dental hygienists which takes a total of four years to complete (two years obtaining the necessary pre-requisite classes and two years in specified dental hygiene classes). Allowing unlicensed personnel to perform these procedures jeopardizes patient safety and undermines the integrity of the dental hygiene profession. It is a disservice to your constituents. Beyond clinical concerns, SB 178 and HB 970 introduce serious insurance, billing, and legal risks. Because “Preventative Dental Assistants” cannot perform a complete prophylaxis, clinics would be unable to bill using the D1110 code. Instead, they must rely on the D1999 “unspecified preventive procedure” code, which requires narrative justification and is reimbursed at a significantly lower rate. This creates financial pressure that may lead to improper coding, misrepresentation of services, or billing for incomplete care. Preventative Dental Assistants cannot clean under the gum line - which is where the majority of the bacteria lies in my patients. Not removing calculus(tarter) under the gum line will also lead to severe periodontal conditions and will lead to tooth loss. With continued research showing a direct link to chronic periodontal infections to poor glucose regulation, heart disease, premature birth rates, the underserved who may not have access to quality medical care would also suffer due to lack of quality and proper dental care with these proposed "providers". The most effective and evidence‑based way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope and to invest in proven strategies that strengthen the existing dental workforce. The “Preventative Dental Assistant” model introduces incredibly high risk without delivering the standard of care that your Virginia constituents receive now. You would be taking giant leaps backwards. I am writing to express my opposition to SB 282/HB 1036, Dental hygiene is not a subset of dentistry—it is a distinct, prevention-focused profession with its own body of knowledge, competencies, and clinical training requirements. The core responsibilities of a licensed dental hygienist are not equivalently taught or emphasized in dental school curricula, whether domestic or international. There is no evidence that weakening licensure standards improves access or outcomes. The most effective and evidence-based way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope, invest in CODA-accredited education programs, and remove unnecessary barriers that prevent hygienists from serving high-need populations.

Please, please vote no on allowing assistants and untrained individuals to scale above the gumline. Everything that causes medical problems for patients is *below* the gumline. Allowing assistants to scale above the gumline *only* serves to enrich doctors who would rather pay an assistant than an actual, trained hygienist. Your constituents deserve good dental care, and they will *not* benefit from this. They will be *harmed*. I'm a dental hygienist. I've been in this field for 8 years, and I promise you that lowering the standard of care is not the answer. What we need is *more hygienists*. Please vote no, and instead advance funding for more hygienist training programs. Thank you.

I am writing to respectfully ask you to vote NO on HB 970, arguing that the bill would allow preventive dental assistants to perform scaling procedures without the level of education and clinical training required of licensed dental hygienists. The concern is that scaling is not simply a technical task but requires clinical judgment, disease assessment, and the ability to manage complications. Incomplete or improperly performed procedures could worsen disease, increase long-term costs, and place greater strain on fully trained providers. Virginia’s licensure standards protect patient safety and public trust and should not be lowered. Instead, alternative workforce solutions, such as allowing hygienists to practice to the full extent of their training, improving reimbursement, strengthening education programs, and supporting innovative care models. I am writing to respectfully ask you to vote NO on HB 1036 when it comes before you on the House floor. I acknowledge that internationally trained dentists are skilled professionals and supports creating legitimate pathways for them to contribute in Virginia. However, I oppose HB 1036 because it would allow these individuals to obtain dental hygiene licensure without completing a CODA-accredited dental hygiene program. Dental hygiene is a distinct, prevention-focused profession with its own specialized education and competencies, and that licensure standards exist to ensure consistent, safe patient care. Lowering those standards could weaken public protections. A vote against HB 1036 does not reject workforce solutions but instead supports maintaining evidence-based licensure requirements while pursuing alternative strategies to expand access safely.

Assistants should not be allowed to do what us Dental hygienists due. We have put in the hours and time to do what we do. Assistants should not be granted this right since they have significantly less training than we do. This will be a huge detriment to our patients care. The patients will suffer.

I vote NO! Firstly : Why has not the public been made aware of these harmful bills? Secondly: Has the VA legislation researched the extensive education that dental hygienist have? Thirdly : who is profiting from these radical bills? While scrolling through these bills, it seems as though quality healthcare is the enemy . Why would anyone think that uneducated or undereducated person be considered qualified to render any care to paying dental patients? Dental care is costly. Insurance is costly . Who will be responsible if a patient is hurt which undeniably will occur when sharp instruments and drills are used by unprofessional, uneducated and un licensed persons are permitted to work in a very sensitive portion of the body? Will you the Legislators take responsibility and pay out malpractice claims? I VOTE NO

I am opposed to these bills being passed. We should have licensed hygienist who know what they are doing. Therefore that requires someone who has been to school and learned how to handle certain situations accordingly.

As a registered dental hygienist with 13 years of experience, I strongly oppose HB970 and HB 1036. Both bills reduce the standard of care and are dangerous for our patients and their oral health and overall systemic health. This undermines the importance of proper preventative care and will increase dental disease.

I’m opposed to these bills being passed due to my safety as a patient.

Hello, my name is Kerrie Reaves. I am a Registered Dental Hygienist in Halifax County, Virginia, and have been practicing for almost 3 years. If House Bills 970 and 1036 are passed, a great risk to my patients’ safety, as well as patient safety in general, will arise across the board. Years of education and clinical practice has allowed me to become very familiar with the oral cavity and disease progression, as well as providing ways to aid patients in preventing the possibility of developing periodontal disease. If “preventive assistants” become normalized for patient treatment, patients will not receive optimal care due to assistants only being provided “on the job” training. If this proceeds, patients will be at a greater risk of developing oral disease due to the neglect of subgingival treatment. As a clinician who values her profession and the health and well-being of my patients, I am opposed to both HB970 and HB1036.

Both bills are often framed as workforce or access solutions. However, each would significantly change who is permitted to provide preventive clinical care without the education and supervised training currently required of licensed dental hygienists. HB 970 would allow preventive dental assistants to perform scaling procedures after far less formal education and clinical experience. Scaling and periodontal therapy are not simply technical tasks; they require the ability to assess periodontal health, recognize disease, interpret radiographs, integrate complex medical histories, prevent complications, and determine in real time when treatment is safe to provide. Partial scaling above the gumline only With PDAs is substandard care and will worsen systemic conditions. HB 1036 similarly does not create a pathway for internationally trained dentists to practice dentistry. Instead, it permits substitution of dental education for licensure in an entirely different profession — dental hygiene — without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dentistry and dental hygiene are separate disciplines with distinct curricula, competencies, and clinical expectations. Virginia’s licensure framework is designed so that every patient, in every community, can trust that providers have met uniform and rigorous standards. Allowing one profession’s education to replace another’s — or reducing preparation for complex preventive procedures — changes that expectation and weakens an important safeguard for the public.

Hello! My name is Lisa Brown, I graduated dental hygiene school from VCU in 2010. I oppose both of these bills based on the following : HB 1036 would allow internationally trained dentists to obtain licensure as dental hygienists. Without a dedicated training program strictly for didactic clinical skills, this is a disservice to public health. As a dental hygienist, I see patients from all across the world and have the opportunity to see what kind of dentistry is being done in other countries. I can tell you with certainty that all foreign dentists are not created equal. I clean behind dentists of foreign dentists as well as ones here- ALL the time. They do not train in scaling for more than a couple of hours!! We need to mandate specified dental hygiene training for a minimum of 6 months to a year, followed by board exams and proper licensure. HB970 is absolutely reckless. It is suggesting to train people on the job for duties that belong within the scope of a practice of a dental hygienist, without any background knowledge or medical training. There is no certification, and therefore no way to prove which persons have been trained, or in what capacity. People can say they’ve been trained on the job, but let’s say that dentist retired and they have no one to vouch for them. How is the next employer to know? I can tell you with certainty that what I knew as a dental assistant, was covered in the first two weeks of dental hygiene school. Putting scalers in the hands of untrained workers WILL result in gingival trauma, periodontal conditions running rampant and going undiagnosed, pathology including potential oral cancers not being acknowledged. I’ve seen many comments from other dental hygienists saying that patients being seen by these supragingival scaling assistants will absolutely end up in a periodontist’s chair in a few years. The suggestion of dental hygienists “popping in” to do the subgingival scaling is absolutely never going to happen, because that takes at least 15-20 minutes of a dental hygienist’s time IF there is little to no tarter present! I beg of you to oppose these bills as I do for the sake of public health.

I oppose HB 970 and HB 1036 ! Please vote no . I only want my preventive dental care performed by a licensed Dental Hygienist. Licensed Dental Hygienists have the education and skill to give me the full care that I need . Please vote no. Thank you .

Chair and Members of the Committee, My name is David Wein, and I am a licensed dental hygienist practicing in the Commonwealth of Virginia. I am here today to state, unequivocally, my strong opposition to HB970 and HB1036. These bills are not solutions. They are dangerous shortcuts that place patients at risk, erode professional standards, and undermine a workforce that is already trained, available, and underutilized. HB970: Lowering the Standard of Care HB970 proposes allowing dental assistants—with a fraction of the education and clinical training of dental hygienists—to perform supragingival scaling. Let me be very clear: Scaling is not a simple task. It is not cosmetic. It is not entry-level care. Supragingival scaling requires: Knowledge of oral and systemic disease The ability to recognize pathology, inflammation, calculus complexity, and early periodontal disease Clinical judgment to determine when scaling is unsafe, incomplete, or contraindicated Dental hygienists complete years of accredited education, hundreds of supervised clinical hours, national and regional board examinations, and continuing education requirements to perform this procedure safely. HB970 replaces this rigor with minimal training and supervision, effectively saying: “Good enough is good enough for Virginia’s patients.” That is unacceptable. If access to care is the concern, then why are we lowering standards instead of removing outdated restrictions on the professionals already qualified to provide this care?! HB1036: Devaluing an Entire Profession HB1036 allows foreign-trained dentists to obtain dental hygiene licensure without completing an accredited dental hygiene program. This bill fundamentally misunderstands and disrespects—the dental hygiene profession. Dental hygiene is not a consolation prize for those unable to practice dentistry. It is a distinct, prevention-focused profession with its own philosophy, curriculum, competencies, and licensure standards. This bill: Undermines educational parity and fairness Circumvents the standards every licensed hygienist in Virginia was required to meet Sends the message that dental hygiene education is optional or interchangeable If Virginia wishes to support foreign-trained dentists, then it should establish transparent and appropriate pathways to dental licensure, not dismantle hygiene standards in the process. The Real Issue: Underutilization, Not Shortage Virginia does not have a shortage of capable providers. It has a shortage of modern policy. Licensed dental hygienists are fully trained, highly regulated, and ready to serve—yet are held back by unnecessary supervision requirements and legislative reluctance to grant autonomy. Instead of empowering hygienists to practice to the full extent of their education, these bills: Shift care to less-trained providers Lower public expectations of safety and quality Create confusion for patients Weaken trust in the oral healthcare system Conclusion HB970 and HB1036 are not progressive. They are regressive. They prioritize convenience over competence, speed over safety, and cost-cutting over patient protection. Virginia’s patients deserve high standards, not watered-down care. Virginia’s hygienists deserve respect, not replacement. And Virginia’s legislature should be advancing healthcare—not cheapening it. REJECT HB970 and HB1036. Thank you. Respectfully, David Wein, RDH Licensed Dental Hygienist, Virginia

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care!!

As an RDH, I oppose SB 178 / HB 970 and SB 282 / HB 1036, which significantly lower the standards of care for preventive dental services. For HB970, why is legalized malpractice acceptable? We will have an even larger deficit of dental hygienists leaving the field if these go through. We already have hygienist at our location, deciding to leave the field because they are tired of not being heard. This is unacceptable. As for HP 1036 It may be acceptable if they have an organized program with all the same competencies on the instruments, osha and infection control protocols and clinicals on patients to make sure that they are on the same standard as American licensed dental hygienists. I have cleaned patients who had foreign dentists “clean” them within the past year and there was heavy subgingival tarter on the radiographs that looked like it had to be there for over 5 years. Their gums were so unhealthy with very heavy bleeding. Not every country teaches the same and some don’t even go over dental hygiene. Overall, SB 178 / HB 970 (oral preventative assistants) should not be acceptable. The dental hygiene program at VCU is against it also. They know how horrible this bill is. Every single patient I have spoken to refuses to let anyone but a dental hygienist do hygiene treatment on them. My patients are shocked and disappointed in how low these dentists are lowering the standard of care. There has got to be a way where dental Hygienists can be asked how to fix this deficit. Please do not consider these bills.

Dental assistants should not be allowed to scale, Supragingival or subgingival. Dental hygienists go through 2 full years of very intense, one on one, hands on training to use the tools and instruments in your mouth, both above your gums and below. It is unethical and a huge safety concern letting an untrained or improperly trained dental assistant provide services that previously required so much training. This should not be passed.

This bill is proposed by VDA dentists in this state because they have a direct interest in the financial gain from it. To fill the "gap in the workplace shortage of dental hygienists" they are proposing lesser trained assistants or foreign "dentists" with less credentialing than a US hygienist take the job of college-trained (at least a bachelors degree in credits) health care professionals to allow more access to care.  This claim of "workforce shortage" will only embolden dentists the excuse to allow sub-standard care to unknowledgeable patients. As you know, as a professional in every field you study specifics and minute details that the public typically is not aware of. The public will not understand the hazard to their health that this bill and "new clinician" it causes. Gum disease is a health condition that has ramifications in the detriment to overall health. Gum disease bacteria has been studied and linked to cancers of the mouth, lungs, pancreas and heart attacks. When a layperson who is trained for 120 hours to "clean" a sub-standard version of a dental hygienists cleaning they are not reaching the most harmful bacteria under the gum. They are merely "scraping the icing off of the cake." In my career as a registered dental hygienist for 20 years, I have seen dentists cut corners to save pennies that would astound you. It is all at the patient's expense to line the dentist's pockets, and this is one more way to achieve this goal. I believe dental hygienists have a duty to be an impartial voice and now is the time I need to speak up. Bills were passed in the past years that allow 4 hygienists to work under one dentist, how is this dentist going to now supervise an assistant on tartar and plaque removal of a patient that has gum disease. There is no way that dentists can do their job of drilling and filling while serving the needs of potentially 5 other patients. Would you want yourself or your family treated in this substandard manner? There is alot more to dental hygienists and what we do and look for as clinicians. We ARE the INITIAL eyes on a patients oral health and we find cancers, sexually transmitted disease growths, tumors, infections, and so much more. Please DO NOT PASS THIS BILL.

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care!!!

This bill is proposed by VDA dentists in this state because they have a direct interest in the financial gain from it. To fill the "gap in the workplace shortage of dental hygienists" they are proposing lesser trained assistants or foreign "dentists" with less credentialing than a US hygienist take the job of college-trained (at least a bachelors degree in credits) health care professionals to allow more access to care.  This claim of "workforce shortage" will only embolden dentists the excuse to allow sub-standard care to unknowledgeable patients. As you know, as a professional in every field you study specifics and minute details that the public typically is not aware of. The public will not understand the hazard to their health that this bill and "new clinician" it causes. Gum disease is a health condition that has ramifications in the detriment to overall health. Gum disease bacteria has been studied and linked to cancers of the mouth, lungs, pancreas and heart attacks. When a layperson who is trained for 120 hours to "clean" a sub-standard version of a dental hygienists cleaning they are not reaching the most harmful bacteria under the gum. They are merely "scraping the icing off of the cake." In my career as a registered dental hygienist for 20 years, I have seen dentists cut corners to save pennies that would astound you. It is all at the patient's expense to line the dentist's pockets, and this is one more way to achieve this goal. I believe dental hygienists have a duty to be an impartial voice and now is the time I need to speak up. Bills were passed in the past years that allow 4 hygienists to work under one dentist, how is this dentist going to now supervise an assistant on tartar and plaque removal of a patient that has gum disease. There is no way that dentists can do their job of drilling and filling while serving the needs of potentially 5 other patients. Would you want yourself or your family treated in this substandard manner? There is alot more to dental hygienists and what we do and look for as clinicians. We ARE the INITIAL eyes on a patients oral health and we find cancers, sexually transmitted disease growths, tumors, infections, and so much more. Please DO NOT PASS THIS BILL.

I would also like to comment on the proposed bill that would allow foreign-trained dentists to practice dental hygiene in Virginia without completing formal dental hygiene education in the United States. As a recent graduate of a rigorous two-year dental hygiene program, I completed extensive coursework, clinical training, and passed three examinations to demonstrate my competency and ability to safely treat patients. Those standards exist to protect the public and ensure consistent, high-quality care. I want to speak from my own educational experience specifically. At the dental school I attended, dental students only spent about two weeks learning dental hygiene instrumentation. That limited exposure is simply not comparable to the depth of education hygienists receive, which includes thousands of clinical hours focused specifically on preventive care, periodontal assessment, medical considerations, pharmacology, and careful removal of bacterial deposits above and below the gumline. I also had a personal experience during school where a dental student performed a cleaning on me using an ultrasonic scaler, and it was quite uncomfortable. I don’t share that to criticize the student — they were working within their training — but it reinforced for me how much skill, practice, and specialized education dental hygiene procedures actually require. We also don’t fully know or regulate what dental hygiene education standards look like in other countries. There is a reason foreign-trained dentists must complete additional accreditation before practicing dentistry in the United States — patient safety and standardized care matter. It seems reasonable that similar consistency should apply when performing dental hygiene procedures. I worked very hard to earn my dental hygiene credentials, and like many hygienists, I entered this profession because I care deeply about prevention, patient comfort, and safety. I respectfully urge legislators to carefully consider maintaining strong, consistent educational and licensure standards for anyone providing dental hygiene care in Virginia. I strongly oppose HB1036!

HB 970: I am writing to respectfully ask you to vote NO on HB 970 when it comes before you on the House floor. Although this proposal is sometimes presented as a workforce or access solution, it would significantly change who is permitted to provide preventive clinical care to patients in Virginia without requiring the education and training currently expected of licensed dental hygienists. HB 970 would allow preventive dental assistants to perform scaling procedures after far less formal education and supervised clinical experience than hygienists complete. Scaling is not merely a technical task. It requires the ability to assess periodontal health, recognize disease, adapt treatment to complex medical histories, prevent complications, and determine when it is unsafe to proceed. Further, it proposes an incomplete procedure may result in harmful outcomes for patients. If subgingival biofilm and tartar are left behind: disease can continue or worsen patients may require more extensive and more expensive treatment later future appointments become longer and more complex the demand on the limited number of fully trained providers actually increases Virginia’s licensure standards exist so every patient can trust that the person providing their care has met consistent, rigorous preparation. This bill lowers that bar. HB1036: I am writing to respectfully ask you to vote NO on HB 1036. HB 1036 does not create a pathway to practice dentistry. Instead, it grants eligibility for licensure in an entirely different profession, dental hygiene, without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused discipline with its own curriculum, competencies, and clinical training model. The daily work of a dental hygienist involves far more than performing a technical procedure. It requires comprehensive periodontal assessment, risk evaluation, radiographic interpretation, infection control expertise, medical history integration, and constant clinical judgment about when treatment is safe and appropriate. These skills are developed through years of education that is specific to dental hygiene. Licensure standards exist to ensure that every Virginian receives safe, consistent care regardless of where they live or who provides their treatment. Allowing individuals to bypass those standards creates a different threshold for entry into the profession and weakens the protections patients rely on. This is not about professional turf. It is about maintaining an evidence-based framework that prioritizes public safety. A “no” vote on HB 1036 does not close the door on workforce solutions or on the contributions of internationally trained providers. It simply says that changes to healthcare licensure should not occur by substituting one profession’s education for another’s. Dental hygienists are eager to identify workforce solutions as well. There are proven strategies that can expand access while maintaining patient safety and reducing long-term burden, including: enabling hygienists to practice to the full extent of their education allowing direct reimbursement improving recruitment and retention of providers who have left clinical practice strengthening and expanding dental hygiene education programs supporting innovative delivery models in rural and underserved areas

I'm writing to oppose HB 970 and 1036, along with SB 178 and 282. As a dental hygienist in Virginia, I have seen first hand the neglect and damage a scaling technician can cause. The military utilizes prophy techs for the same purpose, to scale above the gums and polish, all while supposedly being overseen by a dentist. Most of these individuals that come in for their first non military dental care have bone loss, sub gingival deposit, and active periodontal disease due to years of supervised neglect. We cannot subject Virginia's to this same treatment. We also should not allow foreign trained dentists whose education may be lacking in preventative care to be able to treat patients with dental hygiene services without first going through a CODA accredited program. Education can vary greatly from country to country, and to allow someone to practice dental hygiene simply because they hold a title in their home country does not mean they are qualified by US standards. I urge you to reconsider passing any of these legislative measures for the greater good of the commonwealth and her inhabitants. These bills will directly effect those in the lowest socioeconomic levels who rely on free dental clinics, by exposing them to dangerous, and sub par care. Again, please reconsider these bills and do not pass them. Thank you.

I am a radiation therapist and this worries me. Being in healthcare myself we all have trained rolls snd things we went to school to do. We all specialize and learn different things in school. If someone has cancer they aren't treated by an LPN. They are treated by the radiation therapists. If you need foot surgery you don’t go to the dentist. This is more than ridiculous and only a gimmick for more money. This is going to cause more harm than good and who will be held liable then? All this undiagnosed disease then what? The fortunate will be the first to suffer next will be the elderly population as they don’t know whats going on. They will think they are “being treated” when they aren’t. Disease are going to continue to be exacerbated and the public won’t even know whats going on until it’s too late.

Dear Members of the Voting Committee, As a Dental patient in Virginia I strongly oppose HB 970, SB 178, HB 1036, and SB 282. If enacted, these bills would fundamentally alter existing dental care standards in Virginia by compromising patient health. Watching my wife go through Dental Hygiene School, at a local University, I saw firsthand the amount of education and studying that went into this profession. I gained a new respect for the profession. By passing these Bills it would undermine the profession and put the patients at risk for substandard and preventative care. The idea of training a Preventative Dental Assistant (PDA) with on the job training for 120 hours is absurd as compared to the Licensed Dental Hygienist with a degree worth of education. I am not for this Bill and do not support! As for the Foreign trained Dentist, I will not pay for services of a Dentist that has not gone through the same rigors as a Licensed Dental Hygienist trained in the US. These Bills, if passed, will eventually breakdown the fundamental care that is expected of a dental patient by putting a "Band-Aid" on a current so called "Shortage" of Dental Hygienists. I propose funding additional Dental Hygiene programs at local Universities and Community Colleges in Virginia. This will fill the void as well as keep the high standard that we all, as patients, expect from Dental Hygienists throughout our communities of Virginia. Thank you for your time, attention, and commitment to serving the people of Virginia. Sincerly, Scott Schulz Dental Patient and Resident of Virginia

I worry about myself, my friends, family and yours. Non-trained foreign dentists and dental assistants should NOT be cleaning teeth. More harm will be done than good and who will be held responsible. The population of patients without disease or bleeding gums will simply increase thus making the lists even longer to be seen. Not all dental practices are backed up. Huge corporate offices are backed up. My office is not backed up and if it is we step in to help. Only money hungry dentists would want these bills to pass to make more $$ for their offices!

Oppose the bill

I strongly oppose this bill. I have worked in the dental field for 15 years and am currently a dental hygiene student. The amount of training and licensure required to become a dental hygienist is completely different than the training a dentist receives. Before going to hygiene school, I managed a dental office for 7 years. I watched overworked, underpaid, highly educated dental hygienists become burned out. They are generally working with no benefits and under the scope of a dentist. There is not a shortage of hygienists, there is a shortage of respect and value for what the hygienist brings to the practice of dentistry. I am in hygiene school to one day provide ethical, evidence based care to the community. Passing this bill and allowing foreign dentists to provide hygiene care to patients without CODA accredited training and licensure is unethical.

These bills are not safe. This will be detrimental to patient care. Hygienists are licensed, college educators providers. This is not an effective solution for the dental hygienist shortage. If this bill passes there will be an increase in gum disease in the general public! no individual should be able to scale teeth without attending an accredited dental hygiene!

My wife is a hygienist and this worries me. I do not want for my safety or my families to have a dental assistant or an unlicensed foreign dentist cleaning my teeth. If they’re unlicensed to practice in the United States, why would we want them to clean our teeth. That doesn’t make any sense and they are not certified. Dental assistants have no idea what they are doing! Whats going to happen when they cut up someone gum tissue or hurt someone who is liable? Dentists in the US can step up and clean teeth if they need to but unlicensed and uneducated people should not be doing the job of those who went to college for 2-4 years to learn how to scale teeth and all it entails.

I oppose being treated by these unlicensed, unregulated, and uneducated individuals. I only want to be seen by a registered dental hygienist for my preventive dental appointment.

Hello! My main concern is HB970. I truly cannot wrap my head around how this can be beneficial to patient care. Before I state why, I want to make sure those reading understand what a hygienist does during their hour with a patient - coming from a current working hygienist: 1. Thoroughly review medical history to ensure there are no contraindications to care or medications that have side effects that could manifest in the mouth. We also take blood pressure to make sure it’s a safe reading where the patient is stable in the chair prior to starting the appointment. This was taught in my “‘Med Comp” or “medically compromised” class in hygiene school, as well as reiterated in several hours of clinical practice under the supervision of faculty. You would be shocked to know how many medical conditions affect my work 2. Extra Oral and Intra Oral examination - Checks for oral cancers or even cancers that could appear on the head and neck (such as melanoma). Being able to identify things abnormal was taught in my pathology class and also reiterated in clinical practice. We are seeing more and more cases of tonsil, esophageal, and tongue cancers 3. Perio charting - Screens for different degrees of gingivitis or periodontal disease. This is done by putting a probe UNDER THE GUMS and measuring how far down it can go on six sites per tooth. Identifying different levels and variations of gum disease was taught in my Periodontics class and reiterated in clinic practice 4. The Prophy/Cleaning - After reviewing the perio chart data, bleeding sites, tartar build up, and plaque build up, we determine the degree of cleaning they need. The tricky part about tartar is that you typically do not know it’s under the gums unless you put an instrument under there in the first place and use tactile senses to find and remove it. It only shows up on X-rays once it is very moderate or severe, in which case they typically need a deep cleaning or scaling and root planing. Patients typically build up most tarter inbetween their teeth under their gums (because who likes flossing?!) Even my healthiest patients still get tartar under the gums. For example, out of the eight patients I saw today, only 1 did not have tarter under their gums. With the understanding of how much critical thinking, diagnosing, and didactic training goes into our hygiene appointments, I hope you can understand why we are concerned about this bill. We are concerned more things will get missed and untreated. Poor instrumentation can lead to root gouging or permanently remove gum tissue. Oral cancers could be missed. Systemic diseases could be missed. Subgingival tartar will definitely be missed, leading to high amounts of untreated periodontal disease. Patients may even feel rushed or confused on the difference in their cleanings So please consider all of this when making your decision. Who would you rather have clean your teeth? A registered dental hygienist, or a speedily on-site trained oral preventative assistant? As for HB1036, I feel it is only fair the foreign trained dentists would have to pass a written and clinical board exam, just as registered dental hygienists do. Thank you for your time and consideration Warmest regards, Missy Vandenesse

I oppose being treated by these unlicensed, unregulated, and uneducated individuals. I only want to be seen by a registered dental hygienist for my preventive dental appointment.

HB 970/1036 Oppose the aforementioned bills of training dentals assistants for supragingival scalings, and foreign trained dentist providing hygiene care. Lowering the standard of care for patients is unacceptable. The public comes to their registered dental hygienist (RDH) with the trust of competency and receiving comprehensive hygiene therapy. This includes: reviewing medical histories and blood pressures, full periodontal evaluation, laser therapy, full mouth supra AND subgingival scaling to remove calciferous deposits which can encourage infection, as well as the “feel good cleaning,” of polishing and flossing, fluoride therapy. While any dental professional can provide several of the duties above, a RDH can provide the perio evaluation, supra/sub gingival scaling, and laser therapy (not to mention administer local anesthetic, and nitrous oxide.) There is a fine line between supra/sub gingival scaling just as there is millimeters of “working” field with any specialized medical discipline ( surgery, neuro, cardio, anesthesia, OB/GYN to name a few.) RDHs work within a few millimeters to provide periodontal therapy to patients and a lot of our work is determined as we progress through our work. For example, there are times when working on a patient, the patient is more involved than initially assessed. A skilled RDH can congruously provide therapy befitting the patient. This will not be the case with these bills being passed. Patients will lose standard of care as they are misled by bills propositioned in the guise of helping to serve the public by providing more “cleaners” when it is really to make money by still being able to charge a “prophy” which is fraud and can lead to malpractice. Please reconsider passing these bills. If these bills do pass, consider how effective your next hygiene therapy will be!

II strongly oppose bills HB970 / SB178 and HB1036 / SB282. Please consider the long-term ramifications of passing these bills. Oral health and systemic health go hand in hand. At a dental appointment, a trained and licensed professional should be completing the patient’s care. Dental hygienists are trained to assess oral health and to screen for abnormalities and disease, including periodontal disease, which is linked to conditions such as heart attack, diabetes, Alzheimer’s disease, and rheumatoid arthritis. These bills are not in the public’s best interest. Instead, I believe it would be best to look into establishing larger dental hygiene programs to improve access to care while maintaining high professional standards and protecting patient safety.

I strongly oppose any bill that lowers the standard of care that the public receives. This is dangerous to the public and other solutions to the shortage should be considered like expanding dental hygiene scope of practice. Allowing untrained, uneducated assistants to perform incomplete duties will lead to the reintroduction and increase of disease in healthy patients.

I am strongly opposed to HB1036. A dentist from another country may be a fine dentist but not qualified to do the duties of a dental hygienist. There are plenty of hygienists available but dentists don’t want to pay them commensurate with their abilities.

I am writing to respectfully ask you to vote NO on HB 970 when it comes before you on the House floor. Although this proposal is sometimes presented as a workforce or access solution, it would significantly change who is permitted to provide preventive clinical care to patients in Virginia without requiring the education and training currently expected of licensed dental hygienists. HB 970 would allow preventive dental assistants to perform scaling procedures after far less formal education and supervised clinical experience than hygienists complete. Scaling is not merely a technical task. It requires the ability to assess periodontal health, recognize disease, adapt treatment to complex medical histories, prevent complications, and determine when it is unsafe to proceed. Further, it proposes an incomplete procedure may result in harmful outcomes for patients. If subgingival biofilm and tartar are left behind: disease can continue or worsen patients may require more extensive and more expensive treatment later future appointments become longer and more complex the demand on the limited number of fully trained providers actually increases Virginia’s licensure standards exist so every patient can trust that the person providing their care has met consistent, rigorous preparation. This bill lowers that bar. I am writing to respectfully ask you to vote NO on HB 1036 when it comes before you on the House floor. I want to begin by acknowledging something important: internationally trained dentists are highly educated, skilled professionals. Many bring tremendous value to their communities, and I support thoughtful, legitimate pathways that allow them to contribute their talents within the Commonwealth. However, HB 1036 does not create a pathway to practice dentistry. Instead, it grants eligibility for licensure in an entirely different profession, dental hygiene, without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused discipline with its own curriculum, competencies, and clinical training model. The daily work of a dental hygienist involves far more than performing a technical procedure. It requires comprehensive periodontal assessment, risk evaluation, radiographic interpretation, infection control expertise, medical history integration, and constant clinical judgment about when treatment is safe and appropriate. These skills are developed through years of education that is specific to dental hygiene. Licensure standards exist to ensure that every Virginian receives safe, consistent care regardless of where they live or who provides their treatment. Allowing individuals to bypass those standards creates a different threshold for entry into the profession and weakens the protections patients rely on. This is not about professional turf. It is about maintaining an evidence-based framework that prioritizes public safety. A “no” vote on HB 1036 does not close the door on workforce solutions or on the contributions of internationally trained providers. It simply says that changes to healthcare licensure should not occur by substituting one profession’s education for another’s.

I STRONGLY oppose bills HB970 and HB1036. As a licensed practicing hygienist in a rural area of Virginia, I see first hand the amount of periodontal (gum) disease that is present in the population I treat. Implementing a “preventive dental assistant” OR allowing a foreign trained dentist to treat these type of patients is a major risks to the public. It is impossible to treat these patients by only scaling supragingival (above the gum line). Registered dental hygienists are trained through a four year accredited program. A program that includes learning about correct instrumentation, pharmacology, managing medial emergencies, pathology and histology, periodontics, radiology, dental anatomy, nutrition, head and neck anatomy, dental materials, and much more. Registered dental hygienists also have to pass not one, not two, but THREE board exams to be able to practice in Virginia. Allowing an assistant or a foreign trained dentist to do what is in the scope of a RDH is a major risk to the public. Anyone receiving preventive oral care should be licensed. If passed, periodontal disease will run rampant resulting is an increase of alzheimer’s, cardiovascular diseases, pre term pregnancies, and tooth loss. Please oppose these bills!!

I oppose both of these bills STRONGLY. It is critical to those reviewing these bills that they understand they are not a method to help the workforce shortage. The patrons of these bills have been convinced by people who are financially invested (dentists) in their practices because they refuse to examine the real reasons for workforce shortages or address/take ownership over their own shortcomings. On the job training for dental assistants is not a feasible model for the workforce, and will lead to long term complications for patients like untreated gum disease, tooth loss, long term overall health conditions being compromised, amongst so much more. Not to mention there is a significant shortage of dental assistants as it is, they are already undervalued, underpaid, overworked, and many do not wish to have additional tasks put on them. Internationally trained dentists may receive some training but only having them take the board exams does not account for standardized dental hygiene education. Multiple countries do not teach preventative education nor periodontal (gum and bone disease/health) management of care in their dental curriculum. There are countries whose international dental education are not accepted via application to dental programs here stateside because their dental education programs are so poor in comparison. To allow them to simply take the board exam and minimize the qualifications of becoming a dental hygienist to just that diminishes the quality and safety of care that patients will receive. To sum this up, it is astonishing to me that legislators would be willing to trade patient safety and a standard of dental healthcare to appease dentists who have had their thumb on the dental hygiene profession controlling it since the beginning of time. The better solutions would be to invest in the universities/community college budgets to fund their clinic spaces being increased, allow them to hire more faculty so they can increase their class sizes, and buy more instruments/equipment. In addition, consider giving autonomy to dental hygienists and governance of their own profession so they can grow their own profession and not under someone else.

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care

As a former dental assistant, a current licensed dental hygienist of 22 years, a dental hygiene educator of 10 years, a dental hygienist in goring dental offices, and a dental patient, I STRONGLY URGE you to OPPOSE HB 970 and HB 1036, SB 178 and SB 282! Dental assistants will not have the training needed for the challenging tasks of using very sharp instruments around delicate tissues. A "partial cleaning" from a Preventative Dental Assistant (PDA) will aid in bacterial growth from food, tartar, and plaque left untouched below the gumline to fester, causing bad breath, increased infection, disease that leads to bone loss, pain, and even tooth loss. These bills will allow such limited education and training that put your mouth and dental patients in VA at risk. Working in Germany as a dental hygienist, I realized that the assistants were doing a type of "partial cleanings" and missing/causing disease because they were only using ultrasonic instruments and never hand scaling below the gumline. The patients didn't even realize that bacteria and disease was left in their mouths because above the gumline "felt clean". This is unethical! The infection control in Germany was shocking and extremely disappointing! I watched a dentist use the same gloves in 2 patient's mouths! I watched several dentists not even use gloves, not use masks, and touch counter tops, drawers, and everything in the office with contaminated gloves and/or gloves. Germany is one of the better countries in dentistry and they are still very far from the high standards we practice in the United States. Dentists are NOT dental hygienists and I feel this is the biggest misconception in this entire conversation about internationally trained dentists working as dental hygienists. What is the extent of their training OUTSIDE the U.S. when the extent of a dentists training in a U.S. dental school covers VERY LITTLE preventative education. A dental hygienist is 100% preventative education and 3000-3500 hours of education. The bills for PDA state ONLY 120 hours of training on a mannequin! That is unethical and must be stopped. OPPOSE HB 970 and HB 1036, SB 178 and SB 282!

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care

I strongly oppose both of these bills. As a Licenced Registered Dental Hygienist of 30 years in the State of Virginia and the last 4 years working in the Community Health setting, I can assure you there is NOT a Dental Hygiene shortage. There is a Dental Health shortage in general. We have over a 800 person wait list just to be seen in the Dental department (eithert to see a Dentist or Dental Hygienist). This goes to show you that in SW VA we are in a great need of Dentist as well. If you were to call almost any Dentist is in SW VA you will be told they are not accepting New Patients (to see the Dentist or Dental Hygienist). The Dentist, by Virginia Law can only oversee 3 Hygienist per One Dentist. So how will this law be affected by these bills ???Change this law so the Dentist can Supervise as many Registered Dental Hygienist as he/she wishes. Or change Virginia Law so WE as Registered Dental Hygienist can practice without Direct/Indirect Supervision of a Licensed Dentist. Let us own our own Practice of Dental Hygiene without placing patients Dental Health care in jeopardy. We are Licensed Dental professionals that has attended/ Graduated from accredited Dental Hygiene schools and passed rigorous State and National Boards. Placing Virginia residents in Medical/Dental jeopardy should be a crime and every citizen should know how this bill is being pushed through just the name of the word "shortage " WHICH IS NOT TRUE!!!" PLEASE each of you do your research. DO NO HARM TO OUR CITIZENS OF OUR COMMONWEALTH/STATE OF VIRGINIA.

HB 970 would allow preventive dental assistants to perform scaling procedures after far less formal education and supervised clinical experience than hygienists complete. Scaling is not merely a technical task. It requires the ability to assess periodontal health, recognize disease, adapt treatment to complex medical histories, prevent complications, and determine when it is unsafe to proceed. Further, it proposes an incomplete procedure may result in harmful outcomes for patients. If subgingival biofilm and tartar are left behind: disease can continue or worsen patients may require more extensive and more expensive treatment later future appointments become longer and more complex the demand on the limited number of fully trained providers actually increases Virginia’s licensure standards exist so every patient can trust that the person providing their care has met consistent, rigorous preparation. This bill lowers that bar. I am asking you to prioritize patient safety and uphold the integrity of healthcare licensure in our Commonwealth. A vote against HB 970 is a vote to ensure that changes to scope of practice are made cautiously and with a full understanding of the risks to the public. Dental hygienists are eager to identify workforce solutions as well. There are proven strategies that can expand access while maintaining patient safety and reducing long-term burden, including: enabling hygienists to practice to the full extent of their education allowing direct reimbursement improving recruitment and retention of providers who have left clinical practice strengthening and expanding dental hygiene education programs supporting innovative delivery models in rural and underserved areas HB 1036 does not create a pathway to practice dentistry. Instead, it grants eligibility for licensure in an entirely different profession, dental hygiene, without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused discipline with its own curriculum, competencies, and clinical training model. The daily work of a dental hygienist involves far more than performing a technical procedure. It requires comprehensive periodontal assessment, risk evaluation, radiographic interpretation, infection control expertise, medical history integration, and constant clinical judgment about when treatment is safe and appropriate. These skills are developed through years of education that is specific to dental hygiene. Licensure standards exist to ensure that every Virginian receives safe, consistent care regardless of where they live or who provides their treatment. Allowing individuals to bypass those standards creates a different threshold for entry into the profession and weakens the protections patients rely on. This is not about professional turf. It is about maintaining an evidence-based framework that prioritizes public safety. A “no” vote on HB 1036 does not close the door on workforce solutions or on the contributions of internationally trained providers. It simply says that changes to healthcare licensure should not occur by substituting one profession’s education for another’s. Dental hygienists are eager to identify workforce solutions as well. There are proven strategies that can expand access while maintaining patient safety and reducing long-term burden, as mentioned in my statement about HB 970

I oppose being treated by these unlicensed, unregulated, and uneducated individuals. I only want to be seen by a registered dental hygienist for my preventive dental appointment.

I have been a dental hygienist in private practice for just over a decade, and it is so disheartening to see my profession treated like a joke. Our role in oral healthcare cannot simply be replaced by Oral Preventive Assistants (OPAs) or foreign-trained dentists. A CODA-accredited dental hygiene education is rigorous and intense, and it is important for the work we are called to do. There is no shortcut to gaining the required skills and knowledge. Among other things, registered dental hygienists are specifically trained in preventing and treating periodontal conditions. OPAs, with the passage of HB 970/SB 178, would be certified to perform supragingival scaling and coronal polishing. This type of care is not what our patients deserve, as this type of cleaning is not preventative - it is cosmetic. Simply put, if the biofilm (and thus bacteria) are not removed from under the gum-line, even the healthiest of patients are put at risk for conditions such as periodontal disease. In fact, according to NIH, almost 50% of US adults have some form of periodontal disease, and these patients would definitely not be receiving adequate care. With the passage of HB 1036/SB 282, foreign-trained dentists would be allowed to work as dental hygienists, even though their training may not have measured up to the standards of our accredited programs. Without a way to compare their training with that of a formal CODA-accredited education, we are just hoping they have the scope of knowledge and level of expertise to adequately care for our patients. I urge you to consider the long-term costs to public oral health. These bills propose a shortcut to solving a dental hygiene shortage, but they are only creating more problems by depriving the public of the care they need.

I oppose HB1036. I have been a registered dental hygienist for 26 years. Every dentist I have ever worked for has agreed that they do not have the proper training to provide dental hygiene care. Furthermore, I work with a foreign trained dentist currently. He has told me that he did not have dental hygiene training! This foreign dentist recently graduated from VCU dental program (he had to do 2 years of dental school here in The USA after being a dentist in Egypt). He said his first hygiene patient he ever treated was at VCU! Leave the dental hygiene care to properly trained, educated and licensed RDHs. We do more than clean teeth- we provide oral health care, treat gingivitis, treat periodontal disease, educate patients on the body mouth health connection. I can’t tell you how many patients have told me over the years that they come to see me - the RDH- at the office not the dentist. These patients value their oral health care and know that a good RDH is a valuable asset.

I oppose to being treated by these unlicensed, unregulated, and uneducated Individuals. I only want to be seen by a registered dental hygienist for my preventative dental appointments.

I am writing to respectfully express my strong opposition to the proposed legislation that would allow Oral Preventive Assistants (OPAs) to provide preventive dental services without formal education and training equivalent to licensed dental hygienists. While I understand the intention of improving access to care, this proposal would ultimately jeopardize patient safety and the quality of care delivered. Allowing individuals without comprehensive formal education and clinical training to perform preventive services does not address the root causes of access issues. Instead, it lowers the standard of care for the very patients this legislation claims to help. The supervising doctors would not have adequate time within their schedules to thoroughly examine each patient, assess the quality of preventive services performed, complete any unfinished or subjective aspects of the cleaning, and simultaneously manage their restorative workload. Dentistry is not simply a checklist of tasks it requires clinical judgment, critical thinking, and the ability to recognize subtle signs of disease. These are skills developed through extensive formal education and hands-on training. Patients deserve comprehensive, high-quality care delivered by properly educated and licensed professionals. Dental hygienists receive in-depth education in preventive techniques, periodontal assessment, medical history review, infection control, and patient education. Eliminating or reducing this level of expertise removes a critical layer of protection for patients. It also deprives them of the individualized education and preventive counseling that licensed hygienists are specifically trained to provide. Lowering standards does not solve workforce challenges. It risks creating a two-tiered system of care where some patients receive less-qualified services. That is not equitable, and it is not in the best interest of public health. I respectfully urge you to oppose these bills and support solutions that maintain patient safety, uphold professional standards, and genuinely improve access to high-quality dental care. Thank you for your time and consideration. Kim Herndon RDH

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care. Troy Clark

As a dedicated dental hygienist, I’m proud to be a frontline provider of preventive oral care that keeps our communities healthy and out of pain. Dental hygiene isn’t just “cleaning teeth” — it’s about assessing gum health, educating patients on disease prevention, and helping detect issues early, all backed by rigorous clinical training. Recent legislation raises concerns about simplifying this role and risking quality of care by allowing less-trained providers to perform tasks hygienists are specially trained for. Supporting dental hygienists means supporting high-quality, preventive care, better outcomes for patients, and a profession built on expertise and trust. I strongly oppose both of these bills.

I oppose

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care

Dear Delegates, As a Dental Hygienist, former dental assistant and dental patient I urge you to oppose HB 970 and HB 1036 so the health of all dental patients can be protected. Dental hygienists in Virginia are deeply concerned about recent legislative efforts supported by the Virginia Dental Association to expand the provision of dental hygiene services by individuals who do not meet the current education and licensure standards required of hygienists. These proposals were advanced without meaningful input from the hygienist community, despite hygienists being the professionals primarily responsible for preventive oral healthcare. This exclusion undermines collaborative healthcare decision-making and raises concerns about patient safety, workforce equity, and professional integrity. No area of healthcare should ever risk the lives of the public by lowering standards, as the bills aim to do. These bills are unethical. Ask yourself, are you okay accepting incomplete care...your family receiving incomplete care...know that the public will receive incomplete dental care that will increase risk of stroke, heart attack, cancer, lung disease, and so many more medical conditions? Science has proven the link of oral pathogens to systemic complications, why must it be challenged at the expense of the public? Please have a heart and do what is right, because many may lose their's if these bills become law. Thank you for your time. Respectfully, Angela Jordan, BSDH, RDH Chesapeake, VA

Dental Hygienist are mid-level providers that are hard to replace because we do the hard work that the dentist doesn’t want to do and is not skilled to do if so they would do it. If dentist really cared about their patients, they would provide hygiene services because ultimately they are a practicing licensed dental provider just like a registered Dental Hygienist is they would respect the profession that was created to assist them in providing care for all patients regardless of demographics, sexual orientation, color, religion, etc., etc.. Allowing an untrained, dental assistant or a foreign Doctor Who can’t even get licensed in the United States without proper training education, educational degree written in clinical boards and a successful passing of their national board exams is a danger to every patient who they will see in the United States. There is a reason why foreign doctors who seek a dental degree in the United States cannot just apply for a dental degree or licensure here in the United States because their training is not comparable to the education and skilled training ,critical, thinking skills , medical terminology and knowledge that it takes to diagnose as a registered Dental Hygienist or a dentist in the United States of America. As a registered Dental Hygienist and the owner of a consulting business related to dental hygiene and dentistry in general, it is against my recommendation that these bills be passed because I have taken an oath to do no harm to any patient and these bills would do just that harm our patients. There are other ways to address the shortage concerns in the United States for registered Dental Hygienist. Self regulation of our industry would be one expanded functions, and reciprocity between states would be two and three solutions, allowing Dental Hygienist to own their own practices and provide services two patients with a partnering dentist or medical doctor, providing tele dentistry services are just of the solutions that we offer Dentist and Dental companies. A final solution would be finally to pay a registered Dental Hygienist the recommended profit sharing as an incentive for helping to prove deuce the overall revenue for the companies in which we are employed. I highly recommend it against the continuance of pushing these bills. They will honestly do more harm than good just like in 2020 when we seen a massive decrease in the profession of dental hygiene. We will see another massive decrease because the current population of registered Dental Hygienist will leave the profession seek other professions in which are educational backgrounds easily transfer us into positions where we would be appreciated and acknowledged, respected and properly compensated.

I oppose

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care Wendy Clark

Honorable Committee Members: My name is Tina Gauldin, a Registered Dental Hygienist licensed in the Commonwealth of Virginia and the Dental Hygiene Coordinator and educator at Danville Community College, I am writing to express my strong opposition to HB 1036 (SB 282). I have been a licensed dental hygienist for more than 30 years. I spent the first 26 years providing clinical dental hygiene care in private practice, and the past seven years in dental hygiene education. I would like to share a professional experience that underscores why dental hygiene-specific education matters. During my career, I worked in an office as the first dental hygienist to provide care to patients who had previous received “hygiene” services exclusively from a U.S.-trained and licensed dentist for more than 30 years. Despite this dentist’s extensive education and experience in dentistry, most of these patients presented significant sub-gingival calculus deposits that had gone undetected and untreated, resulting in periodontal (gum) disease. This experience reinforced for me that dental hygiene care requires focused, repetitive, and competency-based training in preventive and periodontal therapy – training that is central to CODA-accredited dental hygiene programs but not the primary focus of dental education. Instead, the primary focus of education in dentistry is restorative care. The Commission on Dental Accreditation (CODA) Standards for Dental Hygiene Education Programs explicitly require that dental hygiene programs provide education that prepares graduates to competently assess, diagnose, plan, implement, evaluate, and document dental hygiene care within the scope of practice. These standards exist to protect public health and ensure Virginians receive safe, effective care. While dentists and dental hygienists both play essential roles in oral health, their preparation and scope of practice are distinct and focused on different competencies. Dental hygiene is not a subset of dentistry; it is a distinct profession with its own standards, competencies, and public protection requirements. Additionally, a dental degree is NOT equivalent to the CODA-accredited dental hygiene education that ensures proficiency in preventive care and patient management in the community setting. Dental hygienists are preventive oral health professionals who complete a rigorous, competency-based education focused specifically on dental hygiene. This education includes accredited didactic coursework, extensive hands-on clinical training, and national and regional board examinations that are designed to ensure patient safety, infection control proficiency, and evidence-based preventive care. As you consider your vote on HB 1036 (SB 282), I respectfully encourage you to reflect on this important question: Would you prefer your dental hygiene care to be provided by a foreign-trained dentist whose educational focus that is not standardized and one that is focused on restorative dentistry, or by a licensed dental hygienist who has completed rigorous, accredited training and demonstrated clinical competency in preventive dental hygiene care? I respectfully ask that you oppose HB 1036 (SB 282) and support policies that maintain high standards for licensure, protect patients, and respect the integrity of Virginia’s oral healthcare workforce.

I am writing to oppose this bill. As a hygienist who has gotten their license, this is a disservice to our patients and our community.

Neither foreign trained nor US trained dentists are NOT dental hygienists. Dentistry and dental hygienists are 2 different arms of dentistry. We, hygienists are the preventive specialist, and trained accordingly. Dentists fix disease. Even in the US, dentists get very minimal education in dental hygiene. Foreign trained dentist should go through a CODA accredited dental hygiene program and pass a clinical board exam to become a dental hygienist in the US.

I respectfully urge you to oppose HB 970 and HB 1036 and to uphold policies that prioritize quality patient care, legal compliance, professional standards and direct access to comprehensive services provided by licensed dental hygienists. These bills undermine our profession and value and put patients and dental offices at significant risk. No one benefits here! We are licensed healthcare professionals; why did we even earn a degree if the regulators of our profession do not recognize its legitimacy, choose not to uphold the standards of care and suddenly change the rules of the game? I’m appalled that we’re even having this discussion, frankly, but given that the field of dental hygiene is predominantly female, it doesn’t surprise me. It’s very much a man’s world we’re living in and this is yet another example of this sad truth. There is simply no logic behind these bills and what’s being proposed is woefully shortsighted. I have been a RDH for over 31 years and I strongly oppose these bills and suggest you do the same. The public deserves better from their legislators and their dental office and so does every licensed dental hygienist in the state of Virginia. The integrity of the profession of dental hygiene is at stake here and if you think there is a shortage now, wait until the trust in the standards of care are eroded and the value of earning a degree in the field of dental hygiene is no longer respected or desired. That’s when we’ll have a far more serious healthcare crisis on our hands. Please do not support these ill conceived proposals, rather, create ways in which to support all licensed healthcare professionals in order to address access to care issues safely, legally and ethically without essentially undermining the value of licensure. Thank you for your careful consideration. Donna Hamilton, RDH

Please vote NO. Virginians deserve quality dental care

I strongly oppose HB970 and HB1036 because it is a safety issue to the public. These bills intend to solve the "shortage" of dental hygienists, however I believe passing these bills will create harm to the public by allowing untrained individuals to only scale supra gingivally with only 120 hours of on the job training. Registered dental hygienists do more than just clean teeth and a weekend course for dental assistants to complete will result in subpar care. As a RDH, I completed 3000+ hours of clinical, lab, and didactic training under supervision to become the clinician I am today. In addition I passed THREE national board examinations including a clinical exam and must completed 15 hours of continuing education to uphold my licensure. Patients not only entrust us with their oral health care but also our oral cancer screenings, oral hygiene instruction, periodontal assessment, removing tarter above AND below the gum line and a friendly face they can trust with disease prevention. Passing these bills poses a huge risk to the public and purely puts financial profit over community health. Frankly, there is not a hygienist shortage, but rather an increase in dental student spots at VCU who pay more tuition than hygiene students and therefore slow eliminating hygiene spots has been an ongoing trend. Money, time, and efforts should be placed on increasing dental hygiene student placement at VCU and increasing the number of dental hygiene institutions in the sate of Virginia to truly solve this so called shortage issue. Registered Dental Hygienists are dental professionals that deserve recognition for what they do on a daily basis, and not to be passed over because dentists want an increased turn over in oral health for profit.

As a concerned citizen I oppose HB 970 HB 1036 SB 282 SB 178 I only want a licensed CODA accredited dental hygienist providing my care

HB 970 : Allowing preventative dental assistants to practice is unethical. Scaling without proper assessment of a patients periodontal health could lead to untreated or worsening disease in a large portion of the general population. Diseases of the periodontium have been linked to other systemic illness, so it is crucial that these diseases be recognized and properly treated by an EDUCATED professional. HB 1036: Dental hygiene is preventative focused care, while dentistry is often restorative care. These two scopes are very different. If dentists educated within the United States are not allowed to practice dental hygiene, the same standard should apply to dentists trained outside of the United States. Proper education for the dental hygiene practice should be enforced before licensure can be granted. This means graduating from a CODA accredited dental hygiene program! Lowering healthcare standards is NEVER the solution!

HB970 Assistant scaling is absolutely foolish. Why would we lower healthcare to the citizens of Virginia? Allowing above the gum-line scaling is not going to increase workforce. This will only act as a Segway for dentist to increase restorative revenue while neglecting the disease process associated with perio disease. There has been so much research showing the direct link between oral and system health. How can we take this new research and go backwards? HB 1036 I oppose this bill for foreign dentist to enter the dental hygiene workforce! They do not receive the proper education to perform scaling nor do they emphasize preventative care in other countries. I’ve had patients that were foreign trained dentist that are unable to read their own radiographs in my dental chair. There should be a clinical and written board exam at the very least prior to practice.

My name is Kelly Schulz, I strongly oppose HB970 and HB1036 I started my career in dentistry as an airman in the United States air force 29 years ago. I attended dental hygiene school using GI bill and practiced dental hygiene for 21 years in addition to adjunct faculty in a Virginia dental hygiene program for the past 16 years. I was a Prophy tech for 2 of my 4 years in the service. I was not prepared nor qualified to provide such procedures. It is impossible to do a prophy and not scale below the gum line. The skills learned in dental hygiene school made me realize just how dangerous the military model was. It was designed for medical readiness of our troops not as a public health program. This is not the answer to a dental hygiene shortage, it would be supervised neglect and we will see in increase systemic disease leading to a decline in the health of the patients.

I am dismayed that once again profit takes precedence over quality care for patients. Allowing minimally trained assistants to perform the duties of professional hygienists who have been educated in general healthcare, dental practices, and have been trained for 3000+ in person patient hours would only lower the quality of services rendered. Competition for dental program is highly competitive, ensuring on the best enter, complete, and become board certified to practice oral health care. Permitting foreign dentists and hygienists who have not been trained in the standards of care for the United States of America puts patients at risk as well. Without passing a board to practice here in the USA, how would we be able to assess the knowledge level to determine if they are as competent as their counterparts trained here? We already face communication barriers in the medical field where doctors form foreign countries speak with heavy accents or are not able to be understood at all and now you want to allow that to infiltrate a field where many people already enter the office in a heightened state of anxiety? By passing these bills and allowing untrained/uncertified people to practice, you devalue the hard work, effort, and financial investment that has been made by dental hygienists and dentists, and that is morally wrong. The insurance companies who pay for the services don’t care who does the work, they pay by codes, so it’s up to the dentists to lead with integrity and not with greed since the difference in salaries will line their pockets. Please consider a vote of NO on these two bills and stand up for the hygienists and dentists and stand up for the oral health of your constituents and fellow humans-it affects everything in the body! Thank you.

I am writing to respectfully ask you to vote NO on HB 1036 when it comes before you on the House floor. I want to begin by acknowledging something important: internationally trained dentists are highly educated, skilled professionals. Many bring tremendous value to their communities, and I support thoughtful, legitimate pathways that allow them to contribute their talents within the Commonwealth. However, HB 1036 does not create a pathway to practice dentistry. Instead, it grants eligibility for licensure in an entirely different profession, dental hygiene, without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused discipline with its own curriculum, competencies, and clinical training model. The daily work of a dental hygienist involves far more than performing a technical procedure. It requires comprehensive periodontal assessment, risk evaluation, radiographic interpretation, infection control expertise, medical history integration, and constant clinical judgment about when treatment is safe and appropriate. These skills are developed through years of education that is specific to dental hygiene. Licensure standards exist to ensure that every Virginian receives safe, consistent care regardless of where they live or who provides their treatment. Allowing individuals to bypass those standards creates a different threshold for entry into the profession and weakens the protections patients rely on. This is not about professional turf. It is about maintaining an evidence-based framework that prioritizes public safety. A “no” vote on HB 1036 does not close the door on workforce solutions or on the contributions of internationally trained providers. It simply says that changes to healthcare licensure should not occur by substituting one profession’s education for another’s. Dental hygienists are eager to identify workforce solutions as well. There are proven strategies that can expand access while maintaining patient safety and reducing long-term burden, including: enabling hygienists to practice to the full extent of their education allowing direct reimbursement improving recruitment and retention of providers who have left clinical practice strengthening and expanding dental hygiene education programs supporting innovative delivery models in rural and underserved areas

When I go to the dentist, I expect to be examined by a professionally trained dental hygienist. Please vote No!! I don't know why someone would even propose otherwise.

These bills are ridiculous I wouldn’t want an unlicensed medical professional working on me. When this gets out to the public that will not help the workplace shortage. Dental hygienists are trained with college degrees and pass a state board as well as continued education required to maintain a license. Why should we give the public substandard care by now not requiring this?? Its ludacris. Dental hygienist should not be governed by dentists to begin with that would help the workplace shortage alone. Let hygienist have reciprocity amongst states. There are plenty I know that are licensed in other states and live in Virginia but cannot practice without passing another board. Why is that a law?? But then now let’s let assistants scale? It is not that easy I fact hygienists are the ones who teach dentists this in dental school as I was once one of them.

I urge you to oppose this bill as a practicing dental hygienist of 15 years. I’ve seen the importance of public health and safety for accredited and licensed RDH to be the only ones who should be doing periodontal therapy and prophylaxis due to our education and strict standards of care. Please protect the public and the dental hygiene profession by opposing this bill.

Please vote no! These bills are not a solution to workforce outcomes and put the public health at risk.

I strongly oppose. I’m a dental assistant for 15 years and dental hygienist for last 18 years. 120 hours of training is a joke. Don’t downgrade my education that i worked so hard to obtain and paid a lot of money for! Also this will not ease the shortage. There is also a shortage of dental assistants!! This is about money period!

If you vote YES to either one of these bills, you will putting the health of your constituents at risk. It takes many months, if not years to gain the skills to properly clean teeth to prevent periodontal disease. If either of these bills pass, it will be a matter of time and your constituents who are being treated by a dental assistant or a foreign dentist without proper training to get periodontal disease. This infection of the gums can also lead to many other health conditions. Diseases such as heart disease, Alzheimer’s, premature births, etc, are all associated with periodontal disease. There are better options to fix the dental hygiene shortage than jeopardizing the health of your constituents. Please vote NO to both of these bills.

Strong opposition to these bills HB970 and HB1036. We as practitioners need to protect the safety of our patients.

As an educator and practicing clinician in the Commonwealth of Virginia, I strongly and unequivocally oppose the passage of HB1036, introduced by Kathy Tran. This legislation, which would allow dentists eligible to practice in a foreign country or jurisdiction to obtain dental hygienist licensure in Virginia without completing a CODA-accredited dental hygiene program, represents a serious threat to professional standards, patient safety, and the integrity of dental hygiene practice in our state. Dental hygiene is not a fallback credential or a subset of dentistry—it is a distinct, prevention-focused profession with its own clearly defined scope of practice. Licensure standards established by the Virginia Board of Dentistry under the authority of the Virginia Department of Health Professions exist to ensure that every licensed hygienist has met rigorous, competency-based educational and clinical requirements. HB1036 would effectively create a separate and unequal pathway to licensure. Foreign-trained dentists, regardless of prior education, have not necessarily been trained or formally assessed in the clinical hygiene competencies required in Virginia. Dental hygiene programs in the United States require documented and repeated evaluation of non-surgical periodontal therapy, advanced instrumentation techniques, patient-centered preventive care, and strict compliance with U.S. infection control standards. These are not assumed skills—they are measured, calibrated, and validated. Infection control alone presents a critical concern. U.S. standards are highly regulated and demand precise adherence to federal and state guidelines. If applicants are not required to complete accredited hygiene training with formal clinical evaluation, there is no reliable mechanism to ensure competency in these protocols. Patient safety cannot and must not be compromised in the name of convenience. Passing HB1036 would undermine the credibility of Virginia’s licensed dental hygienists, devalue accredited educational programs, and send a dangerous message that established standards are negotiable. It would create a two-tiered licensure system that is inherently unfair to those who have fulfilled every educational and clinical requirement mandated by the Commonwealth. The responsibility of legislators and regulatory bodies is to protect the public—not to dilute professional standards. For the sake of patient safety, public trust, and the integrity of dental hygiene practice in Virginia, this bill should not pass.

I am writing to express my strong opposition to HB 1036, which would allow foreign trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA) accredited dental hygiene education and required clinical hours and training. These bills do not address the gap in the dental hygienists workforce because they will not produce any new licensed dental hygienists, and could drive some licensed hygienists out of the market. This legislation represents a significant step backward for patient safety, professional standards, and evidence-based oral healthcare in the Commonwealth. Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused profession with its own body of knowledge, competencies, and clinical training requirements. The core responsibilities of a licensed dental hygienist include comprehensive periodontal assessment, scaling and root debridement, preventive therapy, patient education, and risk-based clinical judgment. This is not equivalently taught or emphasized in dental school curricula, whether domestic or international. Dental education primarily centers on diagnosis and restorative treatment after disease has occurred, while dental hygiene education is built around prevention, early intervention, and long-term disease management. These competencies are developed through extensive, supervised clinical education within CODA-accredited, entry-level dental hygiene programs and reinforced through rigorous clinical courses and labs designed specifically to assess safe and competent hygiene practice. HB 1036 disregards these essential distinctions. Allowing individuals, regardless of prior dental training, to bypass these requirements lowers the standard of care, places patients at significant risk, and undermines the integrity of the dental hygiene license. It also creates a dangerous precedent: that professional licensure standards may be relaxed, not based on evidence or outcomes, but on workforce convenience. Proponents may argue that HB 1036 expands access to care. However, there is no evidence that weakening licensure standards improves access or outcomes. The most effective, ethical, and evidence-based way to expand access to preventive oral healthcare is to support licensed dental hygienists and invest in CODA-accredited education programs. HB 1036 introduces risk without benefit—jeopardizing patient safety while failing to address the real workforce challenges facing Virginia. As a licensed dental hygienist in Virginia, I see firsthand the importance of rigorous education and clinical preparation in protecting patients and improving public health outcomes. I respectfully urge you to oppose HB 1036 and to uphold policies that prioritize patient safety, professional accountability, and the highest standards of care for Virginians. Thank you for your time and consideration. Sincerely, Melanie Bartlam, RDH

Please oppose these bills as they pose a significant risk to public health. Thank you for your time.

My comments were: I oppose both of these bills based on the following : HB 1036 would allow internationally trained dentists to obtain licensure as dental hygienists. Without a dedicated training program strictly for didactic clinical skills, this is a disservice to public health. As a dental hygienist, I see patients from all across the world and have the opportunity to see what kind of dentistry is being done in other countries. I can tell you with certainty that all foreign dentists are not created equal. We need to mandate specified dental hygiene training for a minimum of 6 months to a year, followed by board exams and proper licensure. HB970 is absolutely reckless. It is suggesting to train people on the job for duties that belong within the scope of a practice of a dental hygienist, without any background knowledge or medical training. There is no certification, and therefore no way to prove which persons have been trained, or in what capacity. People can say they’ve been trained on the job, but let’s say that dentist retired and they have no one to vouch for them. How is the next employer to know? I can tell you with certainty that what I knew as a dental assistant, was covered in the first two weeks of dental hygiene school. Putting scalers in the hands of untrained workers WILL result in gingival trauma, periodontal conditions running rampant and going undiagnosed, pathology including potential oral cancers not being acknowledged. I’ve seen many comments from other dental hygienists saying that patients being seen by these supragingival scaling assistants will absolutely end up in a periodontist’s chair in a few years. And then how will we address the shortage of periodontists? Shall we give dental hygienists license to perform surgery? Of course I am being sarcastic, but these are true concerns. I beg of you to oppose these bills as I do for the sake of public health.

Oppose this bill.

Oppose HB970 and HB 1036 and SB282 SB178 Please oppose legislation that will let an undereducated person provide dental hygiene care. I want a licensed CODA accredited dental hygienist!!

My name is Kristen Hooper, and I am a licensed dental hygienist practicing in the Commonwealth of Virginia. I am writing to express my strong opposition to HB 970 and HB 1036. As a trained and licensed dental hygienist, I completed rigorous education, clinical training, national board examinations, and state licensure requirements to ensure I provide safe, evidence-based care to patients. These standards exist to protect the public. Expanding the scope of clinical dental duties to individuals who do not meet these same educational and licensure standards compromises patient safety and lowers the quality of care Virginians deserve. Dental hygiene is not simply “on-the-job” training. It requires extensive knowledge of oral anatomy, pathology, pharmacology, infection control, systemic disease interactions, and medical emergency management. Every day, hygienists identify early signs of oral cancer, periodontal disease, uncontrolled diabetes, and other serious health conditions. Without comprehensive education and licensure oversight, patients are at increased risk for missed diagnoses and preventable complications. While I understand the goal of addressing workforce shortages and improving access to care, lowering professional standards is not the solution. We should be investing in expanding dental hygiene education programs, supporting licensure pathways, and incentivizing providers to serve underserved communities — not replacing licensed professionals with lesser-trained individuals. As your constituent and a healthcare provider dedicated to the well-being of Virginians, I urge you to reconsider and oppose HB 970 and HB 1036. Patient safety, public trust, and professional standards must remain the priority. Thank you for your time and consideration.

Please vote No!

I strongly oppose HB 970 and HB 1036 as these undermine the dental hygienist profession. All professional and medical disciplines require certification demonstrating an ability to provide adequate and appropriate care. Removing or softening this requirement from the dental hygienist profession not only undermines dental care, but endangers patients.

I am opposed to HB970 and HB1036.

I oppose both of these bills based on the following : HB 1036 would allow internationally trained dentists to obtain licensure as dental hygienists. Without a dedicated training program strictly for didactic clinical skills, this is a disservice to public health. As a healthcare worker know that not all countries educate to the same level. I have peers that are licensed dental hygienist who have seen first hand the difference in care. In order for others to practice in this country Virginia needs to mandate specified dental hygiene training for a minimum of 6 months to a year, followed by board exams and proper licensure. HB970 is absolutely reckless. It is suggesting to train people on the job for duties that belong within the scope of a practice of a dental hygienist, without any background knowledge or medical training. There is no certification, and therefore no way to prove which persons have been trained, or in what capacity. People can say they’ve been trained on the job, but let’s say that dentist retired and they have no one to vouch for them. How is the next employer to know? As a professional I can imagine turning over this level of care to untrained workers. I thought of the potential impact as I held my daughter hand in the dental chair this week. I can’t imagine the life long implications of a dental error could have on her life. She has already gone through so much as a child who started dental care at 2 and had a permanent injury to an adult tooth at age 5. Putting scalers in the hands of untrained workers WILL result in gingival trauma, periodontal conditions running rampant and going undiagnosed, pathology including potential oral cancers not being acknowledged. I understand that there is a shortage but the answer is not to sacrifice care. Staffing is not just a lack of skill workers but rather professional leaving due to burn out. The lower reimbursement rates from insurance companies and larger groups buying up small practices has put a greater focus on profits and less focus on quality of care. I beg of you to oppose these bills as I do for the sake of public health.

I am opposed to HB 970/SB 178 and HB 1036/SB 282. It is important to me that the person providing my oral care is a licensed professional.

Certification as hygienist in America is a safety concern for me. Heart disease can cause infection that could go through your veins and kill you. Therefore a Certificate is what I will look for when someone works on me and or there will be a lawsuit in the works if not.

I OPPOSE both of these bills based on the following (as written by my Dental Hygienist): HB 1036 would allow internationally trained dentists to obtain licensure as dental hygienists. Without a dedicated training program strictly for didactic clinical skills, this is a disservice to public health. As a dental hygienist, I see patients from all across the world and have the opportunity to see what kind of dentistry is being done in other countries. I can tell you with certainty that all foreign dentists are not created equal. We need to mandate specified dental hygiene training for a minimum of 6 months to a year, followed by board exams and proper licensure. HB970 is absolutely reckless. It is suggesting to train people on the job for duties that belong within the scope of a practice of a dental hygienist, without any background knowledge or medical training. There is no certification, and therefore no way to prove which persons have been trained, or in what capacity. People can say they’ve been trained on the job, but let’s say that dentist retired and they have no one to vouch for them. How is the next employer to know? I can tell you with certainty that what I knew as a dental assistant, was covered in the first two weeks of dental hygiene school. Putting scalers in the hands of untrained workers WILL result in gingival trauma, periodontal conditions running rampant and going undiagnosed, pathology including potential oral cancers not being acknowledged. I’ve seen many comments from other dental hygienists saying that patients being seen by these supragingival scaling assistants will absolutely end up in a periodontist’s chair in a few years. And then how will we address the shortage of periodontists? Shall we give dental hygienists license to perform surgery? Of course I am being sarcastic, but these are true concerns. I beg of you to oppose these bills as I do for the sake of public health.

As an RDH of 28 years, i strongly oppose both of these bills. Please do not dilute the excellence of our profession with unschooled and uneducated eyes to asses and treat oral health, disease, or abnormalities. Instead, please use your powers for good and help establish more and larger dental hygiene programs that are associated with universal knowledge and skill set, and the passing of a board exam. The passing of these bills is unethical, iatrogenic, and supervised neglect.

In alignment with the Virginia Dental Hygienists’ Association, I am writing to express my strong opposition to HB 970 and HB 1036. HB 970 would allow unqualified dental assistants to perform procedures that fall within the scope of licensed dental hygienists under the proposed “Preventive Dental Assistant” model. This model permits individuals without dental hygiene education or licensure to perform scaling, a procedure that requires advanced clinical assessment and instrumentation skills taught exclusively in CODA-accredited dental hygiene programs and performed by licensed dental hygienists. Allowing unlicensed personnel to perform partial scaling jeopardizes patient safety and undermines the integrity of the profession. HB 970 also introduces significant insurance, billing, and legal risks, including improper coding, reduced reimbursement, increased audits, greater malpractice exposure, and potential False Claims Act violations. Similarly, HB 1036 would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA)–accredited dental hygiene education program or the required clinical training hours. This bill undermines patient safety and professional standards by treating dental hygiene as interchangeable with dentistry, despite dental hygiene being a distinct, prevention-focused profession with specialized education and clinical training developed through CODA-accredited programs. Allowing individuals to bypass these requirements lowers the standard of care, weakens licensure integrity, and sets a dangerous precedent based on convenience rather than evidence. There is no proof this approach improves access to care; meaningful solutions come from supporting licensed hygienists practicing at the top of their scope and investing in accredited education. Together, these bills represent a step backward for oral healthcare in Virginia. They compromise patient safety, weaken professional standards, and fail to address the dental hygiene workforce shortage—producing no new licensed hygienists while potentially driving existing ones out of practice. These proposals introduce risk without benefit and do not address Virginia’s real workforce challenges. As a supporter of the dental hygiene profession, I am deeply concerned about the harm these bills could cause to the citizens of the Commonwealth. I would not want my parents, children, grandchildren, or friends to receive care under these models. These proposals cannot become the norm and threaten both patient safety and professional liability. I respectfully urge you to oppose HB 970 and HB 1036 and to uphold policies that prioritize quality patient care, legal compliance, professional standards, and direct access to comprehensive services provided by licensed dental hygienists. Thank you for your time and consideration

People have the right to have their preventive dental care performed by educated, registered, and licensed individuals The safety and well being of people of all ages depends on it

Having an unlicensed person clean my teeth when I have HBP and Diabetes is just unreal. I have to be stable to have someone clean my teeth and if they are unlicensed they wont check my health history they will just clean and move on to make the most money for the dentist. You wouldn't have an unlicensed doctor do surgery on your body would you???

I am writing you as a registered dental hygienist of 6 years. I currently work in private practice, and I know the immense stress offices are under on a daily basis. The lists of patients never ends, and the space to put them is limited. The stress on the hygienists and dentists is overwhelming sometimes. But, we do the best we can daily to provide the best care to our patients. I am concerned with the bills current in the process of being passed, HB970 and HB1036, specifically HB970. As a dental care provider, I would have never imagined these types of bills would be considered. In my humble opinion, this is not a solution. Allowing someone with minimal or foreign training, holding no state licensure, is negligent. Neither of these bills have the best interests of the patients in mind. Those who come to the dental office to get treatment expect to see someone who is fully educated, fully licensed, and fully competent to provide their care. If these laws are passed, I feel they would be doing a disservice to the patients we care so much about. Who will diagnose disease if a skilled professional is not seeing the patients and doing the cleanings? Who will educate the patient on their oral health conditions, or offer recommendations on the best researched products to use to reduce their bacterial load? Who truly has the best interests of the patients in mind? Someone who has trained for 120 hours? Or someone who worked themselves to death just to make it through hygiene school? Who studied and practiced to pass the clinical, state and National board exams? I feel this is an injustice to our beloved patients, as well as to our registered dental hygienists, who want nothing more than to see our patients healthy and well taken care of. I am urging you to not pass these bills. The amount of undiagnosed disease we will see will sky rocket. The residual subgingival calculus and bacteria will remain, continuing to accumulate, until the patient who was once a “normal cleaning” now needs periodontal treatment. Patients will end up feeling like they were not treated to the best of our ability. I can not stand idly by and watch out dental health care system go down the drain. Please, consider the well-being of our patients. Please consider how you would want you, or your family, to be treated. Would you choose a licensed professional who trained, studied and practiced for hundreds of hours? Or someone who trained a minimal 120 hours, and is now able to use dangerous instruments in the mouth? It is not fair to offer a bandaid for a wound that requires surgery. Please consider expanding dental hygiene education access, or creating bridges for professionals who want to practice as dental hygienists. Both fully licensed, and fully educated. Please do not vote to offer subpar care to our patients. Thank you.

These proposed bills (HB970 and HB1036) are compromising patient care and lowering standards that directly affect oral health. As a Registered Dental Hygienist, I have had extensive training. I had to pass a National Written Board exam, as well as a Regional Clinical exam to become licensed to practice in VA. In addition, continuing education credits to keep my license valid. Training assistants on the job with no regulations for competency is not something I support.

Dental hygienists are licensed healthcare professionals who complete rigorous, accredited education and pass national and clinical board examinations to ensure they are prepared to recognize disease, prevent complications, and protect overall health. Proposed legislation currently under consideration in the Virginia General Assembly would allow individuals with significantly less standardized education and training to perform dental hygiene procedures. While access to care is important, it must never come at the expense of patient safety or quality of care. Our students are the future of oral healthcare, and they are asking for your support. We respectfully urge legislators to oppose the Senate bills 178 & 282 and House bills 970 & 1036 quickly moving through the legislative process. These bills will lower educational and clinical standards for dental hygiene services. Safe care requires the right education. Patients deserve qualified, licensed dental hygienists.

As a practicing registered dental hygienist, these bills will increase patients risk of harm and likely increase the statistics for periodontal disease. To become a dental hygienist, you have to graduate from an accredited program for a reason. There is a lot more to our job than just “scaling.” In addition, who will be training these individuals? Cause personally, I do not want the liability of training someone who will receive substandard education and training. I don’t believe increasing harm to patients via substandard education and training is the answer, in fact it’s far from that. Hygienists would likely stay in their career longer if we had our own autonomy. We are our own licensed individuals and can treat patients accordingly based on our education. In addition, there are many toxic dental practices that leave us feeling stressed and unmotivated to do our job. Having our own autonomy would allow us to treat our patients accordingly .. that’s why we went to school. If I could create my own schedule and not wait on an exam all day I could probably see many more patients in a work day as not everyone needs “just an hour.” Once again this would require individual autonomy over our own practice. It’s easy to make a decision when you’re not entirely educated so I sincerely request you listen to the hygienists advocating for their patients. Just food for thought. Thank you

Please do not allow foreign trained dentists to be permitted to perform dental hygiene services! We need standardized CODA care. All countries are different and it is dangerous to patients. I am a retired dental hygienist with a Bachelor of Science in Dental Hygiene.

I am writing in opposition of both bills. My father was a well respected dentist who practiced for over 40 years and always put patients first. Two of his hygienists worked for him virtually his entire career. He respected the role they played in treating patients and I know he would NOT stand behind these bills. I worked in his practice and I am married to a dental hygienist, who is also an educator. These bills are not the answer and after speaking to several local dentists they know there is going to be a lot of abuse of these roles as it relates to patient care. Most dentists are not going to follow the guidelines listed in these bills. They are going to just let the assistants and foreign trained dentists just go to work and not fully understand the lack of care they are giving the patients. Please take a step back and read comments on social media, the local media articles and you will see from patients, hygienists (both domestic and foreign), and yes even assistants, the majority of them don’t support these bills either. Dental assistants and foreign trained dentists need to go through the proper training from a CODA accredited program. Please do not pass these bills. Follow the other states that realize patient safety.

Dental Hygienist and Dentists should only be the ones to perform cleaning teeth. Patient care is compromised when you have a person who doesn’t have the years of training required. This could cause irreparably harm to patients

I oppose being treated by unlicensed, unregulated, and uneducated individuals. I only want to be seen by a registered dental hygienist for my dental appointment.

DENY THESE BILLS!!!!

I very much oppose being treated by individuals who are not educated, unlicensed, and unregistered for my preventive dental care. I only want to be seen by licensed and registered hygienist

I'm a very concerned patient. It is not a very good idea to place people in a position that needs much more training. Dental Hygienist have to have 3,000 hours of training to clean, scale, examining, look at your gums, tongue and overall health of your mouth. They also can identify cancer and periodontal disease and sleep apnea, diabetes, high blood pressure, tooth decay and infection. The dental assistants and international dentist will not be trained to look for the most important issues a hygienist can observe. Please oppose this bill!

As a Dental Hygienist, I went through thousands of hours of didactic and clinical training from a CODA accredited dental hygiene program. CODA accreditation exists to ensure consistency, rigor, and patient safety across all programs. Bypassing that standard creates an alternative and lower threshold for entry into the profession. Licensure requirements are designed to ensure that every Virginian receives safe, consistent, and evidence-based care. Allowing individuals to enter the profession without completing a CODA-accredited dental hygiene program weakens that uniform standard and introduces variability in preparation that may compromise patient protection. Dental hygiene is not a subset of dentistry. It is a DISTINCT, prevention-focused healthcare discipline with its own educational standards, defined competencies, and clinical training model. The daily responsibilities of a licensed dental hygienist extend far beyond performing a technical procedure. They include comprehensive periodontal assessment, risk evaluation, radiographic interpretation, integration of complex medical histories, infection control expertise, and continuous clinical judgment regarding when treatment is safe, appropriate, or must be modified. This is not about restricting opportunity, it is about protecting patients. When licensure standards are bypassed, the uniform protections that safeguard public health are weakened. Any erosion of those standards carries consequences not just for the profession, but for the health and safety of the communities we serve.

Dear Delegate Tran, I am writing in opposition of HB 1036. Thank you for hearing my concerns; and possible solutions. As a dental hygiene educator for over 25 years and a director of 3 dental hygiene programs in 3 different states for over 15 years, I have witnessed foreign trained dentists who enrolled in our dental hygiene programs. These students are not prepared in any aspect of dental hygiene clinical education. The theory of preventive care and implementation of such care is a different profession than that of dentistry. Dental hygiene students spend 3000 hours of both class and clinical education and attend an accredited program by the Commission on Dental Accreditation (CODA). These students are the future of my profession; the profession of PREVENTION. Dentistry is NOT focused on prevention but restoration after the disease. Dental hygienists focus on prevention to avoid disease. The students that were international dentists during and after their program would say how unprepared and did not realize the extent of education dedicated to the art and science of the dental hygiene profession. Some countries (Most) do not even have a dental hygiene profession. For these reasons, I oppose HB 1036. Furthermore, this bill is an example of supervised neglect- supervised neglect occurs when the standard of care is not met, regardless of delegation rules. The result of these providers will not be more access to quality equitable care, it will be the initiation of substandard care and more disease. Regarding the international dentist I suggest an accelerated dental hygiene program whereby these dentists can be fully immersed in dental hygiene education for 12-18 months so they are comparable to US trained hygienists, and sit successfully for their boards. In Florida, many of these international dentists fail these exams miserably and must repeat them more than once-having an accelerated program would provide the accredited education toward successful board examination results. As an educated, boarded and licensed and practicing dental hygienist for 43 years, I urge you to OPPOSE this bill in the best interest of the highest ethical standards of care that is deserved by all of our citizens. Anything else, is misleading, false and substandard. Respectfully, Marion C. Manski, MS, RDH

I oppose being treated by these unregulated, unregistered and uneducated in dental hygiene individuals. I only want to be treated by a registered dental hygienist for my complete preventative care appointments.

I am writing as a Virginia constituent and a licensed dental hygienist with 18 years of clinical experience to express serious concerns regarding HB1036, particularly provisions that expand clinical duties related to dental hygiene under alternative training pathways, including those involving foreign-trained dentists. I wish to be clear: foreign-trained dentists who seek to practice in Virginia are required to complete licensure and testing, which is an important safeguard and far more rigorous than the minimal training proposed for dental assistants in HB970, under related legislation. However, licensure as a dentist does not equate to education or competency in the practice of dental hygiene. Dentistry and dental hygiene are fundamentally different professions, with distinct educational models, clinical philosophies, and outcomes. Dental hygiene is one of the only healthcare professions rooted almost entirely in prevention—preventing disease progression before surgical or restorative intervention is required. When prevention fails, dentistry intervenes. The professions are complementary, not interchangeable. Dentists, including those trained internationally, are educated to diagnose and treat disease once it exists. They are not trained to function as dental hygienists, whose education centers on periodontal assessment, disease prevention, biofilm management, patient education, and long-term maintenance of oral and systemic health. These skills require thousands of hours of focused education and clinical repetition specific to hygiene practice. This distinction is especially important when considering international training models. In many countries, the preventive dental hygiene model does not exist at all, or exists in a limited or non-autonomous capacity. Individuals trained in such systems may have never been educated in what comprehensive dental hygiene care entails, how prevention alters disease trajectory, or how to manage periodontal health longitudinally. Allowing individuals—regardless of their dental credentials—to assume hygiene-level preventive responsibilities without formal hygiene education raises serious patient-safety concerns. It asks clinicians trained to treat disease to suddenly manage prevention when disease has not yet occurred, without the foundational education that hygiene programs provide. The result is not improved access to care, but increased risk of mismanagement, underdiagnosis of periodontal disease, and delayed intervention, all of which carry downstream public-health and fiscal consequences. Periodontal inflammation is directly associated with cardiovascular disease, diabetes complications, and systemic infection. Failures in prevention increase Medicaid costs, emergency department utilization, and long-term healthcare expenditures for the Commonwealth. Public policy should recognize that scope of practice must align with education and competency, not convenience. Workforce solutions that dilute professional standards ultimately harm patients and expose providers—and the state—to unnecessary liability. I respectfully urge you to consider these distinctions carefully and to oppose legislation that compromises preventive care, patient safety, and evidence-based healthcare delivery in Virginia. Thank you for your time and for your commitment to the health of Virginians.

I have been living in Virginia since 2016. I am an internationally trained dentist and currently working as a dental assistant. I also hold an active Florida dental hygiene license after clearing the NBDHE and CDCA examinations. Virginia needs practical workforce solutions to improve access to dental care. Legislation such as HB 970 and SB 282 helps strengthen the dental workforce while maintaining professional standards and patient safety. I STRONGLY SUPPORT THESE BILLS.

I only trust my preventive dental appointments to registered dental hygienist. I oppose being treated by unlicensed, unregulated, uneducated/untrained individuals.

I oppose being treated by unlicensed and unregulated individuals. I only trust my preventive dental care to registered dental hygienist.

I am a licensed dental hygienist practicing in Virginia, and I am writing to respectfully express my opposition to HB970, HB1036, SB178, and SB282. Preventive dental care is not a single mechanical task such as supragingival scaling. Effective prophylaxis requires periodontal assessment, subgingival evaluation, interpretation of tissue response, and the ability to recognize early disease patterns that are often clinically silent. Licensed dental hygienists complete accredited education programs and must pass national written examinations and clinical competency assessments specifically designed to evaluate proficiency in preventive and periodontal care. HB970 and SB178 propose expanding scaling duties to dental assistants after a significantly abbreviated training pathway. This introduces a tiered preventive model that separates scaling from comprehensive periodontal evaluation and risks lowering the standard of preventive care delivered to Virginia patients. HB1036 and SB282 would allow foreign-trained dentists to practice as dental hygienists. My concern is not about the dedication or ability of these individuals. It is about maintaining consistent licensure standards. If a practitioner is going to perform the duties of a licensed hygienist, they should meet the same written and clinical examination requirements required of every other hygienist licensed in the Commonwealth. Uniform standards protect patients and ensure fairness across the profession. If access to care and workforce sustainability are the concerns, policy solutions should preserve training rigor while addressing insurance reimbursement challenges, expanding public health hygiene models, and supporting retention of licensed preventive providers — rather than creating alternative pathways that bypass established competency benchmarks. Virginia constituents deserve preventive care that prioritizes early detection, comprehensive periodontal evaluation, and long-term oral health outcomes. Thank you for your time and consideration. Respectfully, Alyssa Persinger Registered Dental Hygienist

I believe it is 100% And careless to approve these bills to allow uneducated and trained dental assistance to play the role of a dental hygienist! Being a Dental hygienists is not just an act of care but also a knowledge or oral health from A to Z! I would hate to have my autistic son seen by someone who did know go through the proper schooling and years of training to keep the public safe and healthy! It’s SO DIDAPPOINTING that these bills made it this far in legislation! This is disgusting as a Virginian and nowhere near close to being a solution for lack of Dental hygienists. As a cosmetologist this is just as disturbing as the hours that were lowered to be licensed! At this point I don’t believe you all care about Virginians as human beings, but more a piggy banks. Please consider you’re own family, loved ones, and special needs individuals who cannot obtain safe care and can experience first hand life altering effects from this greediness because it won’t effect y’all with money, connections and status! I PRAY y’all really think HARD about this monstrosity. If these bills are passed, it’s evident that Virginians safety is y’all’s upmost priority and should be considered a crime.

As a dental hygiene educator and licensed dental hygienist, I have unique experiences to share, including the attached testimony from internationally trained dentists who are now licensed dental hygienists after completing accreditation education. I want to begin by acknowledging something important: internationally trained dentists are highly educated, skilled professionals. Many bring tremendous value to their communities, and I support thoughtful, legitimate pathways that allow them to contribute their talents within the Commonwealth. However, HB 1036 does not create a pathway to practice dentistry. Instead, it grants eligibility for licensure in an entirely different profession, dental hygiene, without completion of a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused discipline with its own curriculum, competencies, and clinical training model. The daily work of a dental hygienist involves far more than performing a technical procedure. It requires comprehensive periodontal assessment, risk evaluation, radiographic interpretation, infection control expertise, medical history integration, and constant clinical judgment about when treatment is safe and appropriate. These skills are developed through years of education that is specific to dental hygiene. Licensure standards exist to ensure that every Virginian receives safe, consistent care regardless of where they live or who provides their treatment. Allowing individuals to bypass those standards creates a different threshold for entry into the profession and weakens the protections patients rely on. This is not about professional turf. It is about maintaining an evidence-based framework that prioritizes public safety. A “no” vote on HB 1036 does not close the door on workforce solutions or on the contributions of internationally trained providers. It simply says that changes to healthcare licensure should not occur by substituting one profession’s education for another’s. Dental hygienists are eager to identify workforce solutions as well. There are proven strategies that can expand access while maintaining patient safety and reducing long-term burden, including: enabling hygienists to practice to the full extent of their education allowing direct reimbursement improving recruitment and retention of providers who have left clinical practice strengthening and expanding dental hygiene education programs supporting innovative delivery models in rural and underserved areas

To me, a citizen with concern, this bill represents a huge negligence in care. To me, this is the equivalent of having a pilot waltz in and become an air traffic control personnel. Completely different fields and knowledge but hey, they seem similar enough. Let alone the fact that dentists dont even know how to properly scale teeth. In dental schools across country the previous hygienists that are in dental school are the ones doing the scale checks. Not the dentist instructors. Why doesn't this bill transfer dentist to dentist? Oh right, because they aren't certified or qualified to do their own practice in the United States! So lets just put them in a completely different scope of practice, one that they don't even take seriously in other countries. Sounds like the US is falling to their standard of care, what a shame you all are a part of that. The fact that it's okay to allow this misrepresentation of care all because delta dental and the dentists are handing you all money. I am ashamed that this bill has gotten this far. Let alone the fact that the "care" provided will be neglectful and allow build-up subgingival to go untreated willingly. I wonder what the lawyers will think of this when they understand the medical negligence this bill has provided. I hope you reconsider this bill. It's a disgrace.

VOTE NO on HB 970 and HB 1036 when they come to the House floor. I recognize that both of these bills are often framed as workforce or access solutions, however they do not address true workforce issues, risk patient safety and health, and lower standards for Virginians. Dental hygienists complete two years of prerequisite education followed by two years of rigorous dental hygiene curriculum in a Commission on Dental Accreditation-accredited program. Over 3000 didactic and clinical hours are completed for a dental hygiene degree as well as passage of licensure examinations. This is critical as dental hygiene requires evaluating periodontal health, recognizing the presence and severity of disease, understanding how systemic conditions like diabetes or heart disease affect treatment, preventing complications, and constantly making decisions about when it is or is not safe to proceed. HB 970 would allow dental assistant I and IIs to provide incomplete treatment with only 120 hours of training on a mannequin or human. Not only is this training insufficient, it proposed incomplete care that is detrimental to patient health. If tartar and biofilm are left below the gums, disease worsens including chronic conditions, patients will require more invasive and expensive treatments later, future appointments become more complex, and the strain on preventive care worsens. I also want to say clearly that internationally trained dentists are highly educated and bring tremendous value to their communities. However, HB 1036 does not create a pathway to practice dentistry. It allows dentists to practice an entirely different profession, dental hygiene. Further, it lacks safeguards to ensure standardization in education before licensure in Virginia. It does not require accredited education, unrestricted licenses with similar standards, active practice requirements, clean disciplinary and criminal history, and much more (compare to HB 1026, a same scope-to-same scope bill with many more safeguards in place). Both of these bills risk patient safety, oral health, and overall health as a way for dentists to make more money disguised as access to care and workforce solutions. Organized dentistry is telling half truths to get this through. Dental hygienists have offered solutions to address workforce challenges, including adding benefits to dental hygiene practice (yes, most have no medical benefits, sick leave, PTO, retirement), increased insurance reimbursement rates, lessened supervision restrictions to allow dental hygienists practice at the top of their scope and access more patients, and much more. I respectfully ask the Delegates on the floor to prioritize patient protection and vote NO on both bills, HB 970 and HB 1036.

I am a Registered Dental Hygienist and Registered Dental assistant. cDA and DAII in the state of Virginia. I oppose these two bills from passing through. Please take deep consideration to oppose these two bills from passing through. Thank you!

I believe it is 100 percent careless and neglectful to approve these bills to allow uneducated dental assistances to play a dental hygienist role! Dental hygienist is not an act or as much as it is knowledge of the care provided from A to Z! I would hate to have my Autistic son seen by someone who did not go through the proper schooling and years of training to keep the public safe and healthy! It is SO DISAPPOINTING that this even made it this far in legislature! This is disgusting to Virginians and nowhere close to being a solution for the lack of dental hygienists. As a cosmetologist it is the same as the necessary hours that used to be mandated to take a state board. At this point I don’t believe you all care about Virginians as human beings at all. Please think about your own family members, loved ones, and special needs individual who can not obtain safe health care and can experience life altering effects from y’all’s greediness because it won’t effect y’all with the money and status y'all have. I pray y’all REALLY think HARD about this. If these bills are passed, there is no hope for Virginians safety and ultimately should be looked at as a crime.

I think it's absolutely Unthinkable that you would allow someone that is not trained or certified to work in someone's mouth with instruments that they're not qualified to use. The more people that find out about this the better. You are asking people to put their faith in someone that should not be allowed to do this kind of work and not be certified.

I oppose both of these bills based on the following : HB 1036 would allow internationally trained dentists to obtain licensure as dental hygienists. Without a dedicated training program strictly for didactic clinical skills, this is a disservice to public health. As a dental hygienist, I see patients from all across the world and have the opportunity to see what kind of dentistry is being done in other countries. I can tell you with certainty that all foreign dentists are not created equal. We need to mandate specified dental hygiene training for a minimum of 6 months to a year, followed by board exams and proper licensure. HB970 is absolutely reckless. It is suggesting to train people on the job for duties that belong within the scope of a practice of a dental hygienist, without any background knowledge or medical training. There is no certification, and therefore no way to prove which persons have been trained, or in what capacity. People can say they’ve been trained on the job, but let’s say that dentist retired and they have no one to vouch for them. How is the next employer to know? I can tell you with certainty that what I knew as a dental assistant, was covered in the first two weeks of dental hygiene school. Putting scalers in the hands of untrained workers WILL result in gingival trauma, periodontal conditions running rampant and going undiagnosed, pathology including potential oral cancers not being acknowledged. I’ve seen many comments from other dental hygienists saying that patients being seen by these supragingival scaling assistants will absolutely end up in a periodontist’s chair in a few years. And then how will we address the shortage of periodontists? Shall we give dental hygienists license to perform surgery? Of course I am being sarcastic, but these are true concerns. I beg of you to oppose these bills as I do for the sake of public health.

Please oppose these bills as I only want a licensed dental hygienist providing my care!! I do not want someone that has limited training providing my care!!! Oppose these bills!!

The Virginia Dental Association is bringing forth to the legislature that aims to train dental assistants to perform dental hygiene duties on the job and let foreigner trained dentists provide dental hygiene services with NO UNBIASED TESTING. I strongly OPPOSE this legislation as dental hygienists must graduate from a CODA accredited program, must pass a regional clinical board and must pass a national exam. This is extensive education that is then evaluated by regional and national teams not associated with the school system. In Virginia, there is no requirement for a dental assistant I to have any formal training. This means one day they could be working as a waitress and the next day sitting beside a dentist handing the dentist instruments or trying to sterilize a room for the next patient.  Dentists by nature of their training are focused on diagnosis and restorative treatment. Their training is minimally focused on prevention. Dental hygienists are the prevention specialists on a dental team. The training proposed for dental assistants is minimal and not sufficient to provide appropriate care for a patient. Moreover, there is no oversight and evaluation of the training by an impartial objective evaluator.  When you go to the dentist and see your hygienist for an adult prophylaxis (cleaning/check up), the hygienist must go below the gum line in order to appropriately remove calculus (tartar). No one likes to floss so in order to go in between your teeth the hygienist must go under the gum line to clean between your teeth. The proposal of a dental assistant providing a supra (above gum line) procedures renders inadequate care for patients. This inadequate care leads to periodontal disease (gum disease). The patient is unaware they are receiving substandard care. Just remember, you would NOT want a CNA to provide care delegated to an RN. You definitely do not want a dental assistant to provide the duties delegated to a registered hygienist. PROTECT THE PUBLIC OPPOSE THIS LEGISLATION!!!

I am writing to express my strong opposition to HB 1036, which would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA)–accredited dental hygiene education program or the required clinical hours and training. These bills do not meaningfully address the dental hygiene workforce shortage, as they would not produce new licensed dental hygienists and may instead drive currently licensed hygienists out of the profession. This legislation represents a significant step backward for patient safety, professional standards, and evidence-based oral healthcare in the Commonwealth. Dental hygiene is not a subset of dentistry; it is a distinct, prevention-focused profession with its own body of knowledge, competencies, and clinical training requirements. The core responsibilities of licensed dental hygienists—including comprehensive periodontal assessment, scaling and root debridement, preventive therapy, patient education, and risk-based clinical judgment—are not equivalently taught or emphasized in dental school curricula, whether domestic or international. Dental education is primarily centered on diagnosis and restorative treatment after disease has occurred. In contrast, dental hygiene education is built around prevention, early intervention, and long-term disease management. These competencies are developed through extensive, supervised clinical education in CODA-accredited, entry-level dental hygiene programs and reinforced through rigorous clinical courses and laboratories designed specifically to evaluate safe and competent hygiene practice. HB 1036 disregard these essential distinctions. Allowing individuals—regardless of prior dental training—to bypass these requirements lowers the standard of care, places patients at risk, and undermines the integrity of the dental hygiene license. It also establishes a concerning precedent that professional licensure standards may be relaxed based on convenience rather than evidence, competency, or patient outcomes. Proponents may argue that HB 1036 would expand access to care. However, there is no evidence that weakening licensure standards improves access or quality of care. The most effective, ethical, and evidence-based way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope, invest in CODA-accredited education programs, and remove unnecessary barriers that prevent hygienists from serving high-need populations. HB 1036 introduce significant risk without delivering meaningful benefit—jeopardizing patient safety while failing to address the real workforce challenges facing Virginia. As a licensed dental hygienist in the Commonwealth of Virginia, I see firsthand the importance of rigorous education and clinical preparation in protecting patients and improving public health outcomes. I respectfully urge you to oppose HB 1036 and to support policies that uphold patient safety, professional accountability, and the highest standards of care for Virginians.

PLEASE listen to license registered dental hygienists who oppose HB 1036. My letter explaining my opposition is attached to this link. Thank you for your thoughtful consideration of Virginians oral health.

Strongly OPPOSE HB970 / SB178 and HB1036 / SB282. Protect Patient Safety As a dental hygienist residing in Virginia, I am writing to urge you to oppose HB970 / SB178 and HB1036 / SB282. These constitute a severe reduction in the standard of care. My opposition is based on the following: Public Safety Risk: Dental hygienists undergo rigorous CODA-accredited education, including thousands of clinical hours, to safely remove tartar from above and below the gum line. As well as training on the oral systemic connection for health and prevention of disease. Access to care is a valid concern, but it should not be solved by jeopardizing patient safety and lowering the professional standard of care in Virginia. I strongly request that you vote NO on HB970 / SB178 and HB1036 / SB282. Sincerely, Megan Cobb, RDH

I'm writing to oppose HB970 / SB178 and HB1036 / SB282. Please consider my clinical expertise and thoughts on the following. I'm a licensed hygienist, having had to pass three board examinations in order to practice; a national board, a state and a clinical board. My accredited program and its accrediting body, the Commission on Dental Accreditation (CODA), are necessary steps in ensuring safe patient care. Practicing as a dental hygienist is so intricate that I carry liability insurance because I could be sued in the event of negligence or malpractice. Dental hygienists are at the forefront of recognizing and treating periodontal disease. Periodontal disease is linked to preterm labor, heart attack, stroke, diabetes and Alzheimer's. "On the job" training is dentist dependent and doesn't replace the hours I spent in college courses on pharmacology, oral pathology, physiology, and so forth. The Standard Occupational Classification (SOC) by the United States Office of Management and Budget has classified hygienists as Healthcare Diagnosing or Treating Practitioners, the same category as dentists. Can education and practice so significant be replaced? Virginia's population is placed at risk for greater health complications, both orally and systemically, when conditions are unrecognized and untreated. Employment shortages must be addressed through expansion of existing accredited programs; patient care should not be placed in jeopardy. I personally would not consider a move to a state authorizing "on the job" training, and Virginia might lose hygienists as a result of HB970 / SB178 and HB1036 / SB282 being approved. In my time as a dental hygienist, I've seen "on the job" trained assistants do unacceptable things, including actions that place their own health at risk, such as reaching bare handed into an ultrasonic cleaner to pull out dirty instruments. Have you seen the video of a dentist on a hoverboard while extracting teeth? Thankfully he was caught and charged. However, the unfortunate reality is that dentists are just people too that can make errors in judgement (and thus also training). Dentistry is hard physically on your body. My education also covered how to prevent long term musculoskeletal disorders. Who's going to be looking out for those that will need disability in a few years as they are practicing physically unsafe ergonomics? Medical assistants can not receive training through non-accredited means in order to fulfill Registered Nurses workforce shortages; the same should be true for Registered Dental Hygienists. I would never dream of having non-accredited training in order to make crowns or perform fillings on patients. Accrediting bodies ensure dentists provide safe care to their patients and the same should be said for patient hygiene care. My biggest fear for Virginia is for patients who do not know what is and is not safe and are relying on those in trusted healthcare positions. Please keep the oral health care of Virginia's citizens safe. Please oppose HB970 / SB178 and HB1036 / SB282. Respectfully, Sarah J French Linthicum, RDH

HB 970 and HB 1036 are bills disguised as "access to care" but the bottom line is about profit. Each bill will put Virginians at risk with their periodontal health. The mouth is linked to many systemic diseases and these bills will make these health risks sky rocket. These bills will be the end of the profession of Dental Hygiene and associated dental hygiene programs in Virginia. Basically, we are lowering the standards set forth by accrediting bodies in the name of profit. Virginia didn't lobby to let CNAs and LPNs have expanded duties to cover the RN nursing shortage. I don't see how you can, in good conscience, vote to lower the standards of Dental care for the state.

I oppose all bills in favor of assistants scaling supraginivally. It is extremely harmful to all patients. Assistants do not have the scope of practice as a dental hygienist. Most dentist are too busy to perform intra and extra oral pre cancer screenings. Only the hygienist does is most offices. This is something an assistant is not trained or certified in. Not only that, a supra gingival cleaning is basically brushing your teeth. Not an actual thorough PREVENTIVE dental cleaning. If there is no sub gingival cleaning the patient will SUFFER and go further into periodontal disease causing more systemic issues!. I also oppose foreign dentist becoming hygienist WITHOUT proper dental hygiene accredited education. IT IS NOT THE SAME AS DENTAL SCHOOL. Dentist will not inform you of that. Dentist are trained in restorative work, not preventive cleanings as the dental hygienists. Please, dont be fooled by the supposedly hygiene shortage. No office is actually telling patients its a 12 to 18 month wait for dental cleanings. My office i saw new patients the day they called. Hygienist graduate from all over VA every year. There is no shortage. Hygienist move on to other and better offices because they are mistreated and not treated as the providers they are. Thank you for your time!

I am writing to express my strong opposition to SB 178/HB 970, which would allow dental assistants with on the job training to perform tasks that belong within the scope of licensed dental hygienists under the proposed “Preventative Dental Assistant” model. This legislation is a significant step backward for oral healthcare in Virginia because it does not prioritize patient safety or the educational and clinical competencies required for safe, evidence‑based dental hygiene practice. Scaling requires advanced instrumentation skills, assessment, and critical clinical judgment. These competencies are taught exclusively in Commission on Dental Accreditation (CODA)–accredited dental hygiene programs and performed by licensed dental hygienists. Allowing unlicensed personnel to perform these procedures jeopardizes patient safety and undermines the integrity of the dental hygiene profession. Beyond clinical concerns, SB 178 and HB 970 introduce serious insurance, billing, and legal risks. I worry about my friends, family, yours as well. Because “Preventative Dental Assistants” cannot perform a complete prophylaxis, clinics would be unable to bill using the D1110 code. Instead, they must rely on the D1999 “unspecified preventive procedure” code, which requires narrative justification and is reimbursed at a significantly lower rate. This creates financial pressure that may lead to improper coding, misrepresentation of services, or billing for incomplete care. Such scenarios expose practices to insurance disputes, audits, and potential allegations of fraud. When unlicensed personnel perform procedures outside their legal scope, any resulting claim submitted to insurers—including Medicaid—may be considered inaccurate or misleading. This puts supervising dentists and practice owners at risk of violating the False Claims Act, which carries severe civil penalties, repayment obligations, and reputational harm. These risks are well documented by the American Dental Hygienists’ Association and should not be overlooked. If enacted, SB 178 and HB 970 would reduce professional standards, compromise patient safety, and expose Virginia dental practices to unnecessary legal and financial liability. The most effective and evidence‑based way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope and to invest in proven strategies that strengthen the existing dental workforce. The “Preventative Dental Assistant” model introduces risk without delivering meaningful benefit. As a dental hygienist in Virginia, I see firsthand how deeply this issue affects our profession and the patients we serve. I urge you to oppose SB 178/HB 970 and ensure this does not pass. This is only going to cause more harm than good and more disease will go undiagnosed.

These bills are going to SEVERELY impact the health of our patients here in the great commonwealth. I feel uniquely qualified to discuss this topic as a former dental assistant of 8 years and now a registered dental hygienist of almost 7 years, what I learned in school far surpassed the assisting knowledge I acquired in years of on the job training, this is not the solution! This is a bandaid over a bleeding arty and it truly will only hurt our patients who we have vowed to take care of.

I am writing to express my strong opposition to HB 1036, which would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA)–accredited dental hygiene program. As a current dental hygiene student at VCU and an alumna of Germanna Community College, I earned my CDA certification in 2021 and CDAII certification in 2022. My educational journey has reinforced the necessity of standardized, accredited training pathways for all healthcare providers. This legislation presents a troubling double standard: internationally trained dentists cannot practice dentistry in the United States without completing a CODA-accredited dental program, yet HB 1036 would allow them to practice dental hygiene without meeting the same rigorous standards. If we require standardized CODA accreditation for dentists to protect patient safety, why abandon that principle for dental hygienists? This inconsistency is indefensible and dangerous. Dental hygiene is not a subset of dentistry—it is a distinct, prevention-focused profession with its own body of knowledge, competencies, and clinical training requirements. Core responsibilities of a licensed dental hygienist—comprehensive periodontal assessment, scaling and root debridement, preventive therapy, patient education, and risk-based clinical judgment—are not equivalently taught in dental school curricula, whether domestic or international. Dental education centers on diagnosis and restorative treatment after disease occurs, while dental hygiene education is built around prevention, early intervention, and long-term disease management. These competencies are developed through extensive, supervised clinical education within CODA-accredited entry-level programs. HB 1036 disregards these essential distinctions and the importance of standardized educational requirements. These bills will not address the workforce gap because they will not produce new licensed dental hygienists and could drive current hygienists out of the market. Allowing individuals to bypass rigorous educational requirements lowers the standard of care, places patients at risk, and undermines the integrity of the dental hygiene license. Proponents may argue HB 1036 expands access to care. However, there is no evidence that weakening licensure standards improves access or outcomes. The most effective way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope, invest in CODA-accredited programs, and remove barriers preventing hygienists from serving high-need populations. Standardized educational requirements exist to ensure every licensed professional meets the same competency standards, regardless of background. HB 1036 introduces risk without benefit—jeopardizing patient safety while failing to address real workforce challenges. As a dental hygiene student who has witnessed the rigor of accredited dental hygiene education, I see firsthand the importance of these standards in protecting patients and improving public health. I respectfully urge you to oppose HB 1036 and uphold policies that prioritize patient safety, professional accountability, and standardized educational pathways for all licensed healthcare providers in Virginia.

I am writing to express my strong opposition to HB 970, which would allow dental assistants with on-the-job training to perform tasks that belong within the scope of licensed dental hygienists under the proposed "Preventative Dental Assistant" model. As a current dental hygiene student at VCU and an alumna of Germanna Community College, I have a unique perspective on this issue. I earned my Certified Dental Assistant (CDA) certification in 2021 and my Expanded Functions Dental Assistant (CDAII) certification in 2022. My educational journey through both pathways has shown me firsthand the critical importance of proper, accredited education in protecting patient safety. This legislation is a significant step backward for oral healthcare in Virginia. Scaling requires advanced instrumentation skills, assessment, and critical clinical judgment—competencies taught exclusively in Commission on Dental Accreditation (CODA)–accredited dental hygiene programs. Allowing unlicensed personnel to perform these procedures jeopardizes patient safety and undermines professional integrity. If there is a genuine need to expand preventive care capacity in Virginia, the solution already exists: the Expanded Functions Dental Assistant certification. Rather than creating an entirely new, inadequately trained category of providers, any expanded scope should be incorporated into the existing EFDA pathway, which requires accredited program completion with proper didactic and clinical training. Creating a "Preventative Dental Assistant" role that bypasses accredited education is unnecessary and dangerous. Beyond clinical concerns, HB 970 introduces serious insurance, billing, and legal risks. "Preventative Dental Assistants" cannot perform a complete prophylaxis, so clinics would be unable to bill using the D1110 code. Instead, they must use the D1999 "unspecified preventive procedure" code, reimbursed at significantly lower rates. This creates financial pressure that may lead to improper coding or billing for incomplete care. When unlicensed personnel perform procedures outside their legal scope, resulting claims submitted to insurers—including Medicaid—may be considered inaccurate or misleading. This puts supervising dentists and practice owners at risk of violating the False Claims Act, which carries severe civil penalties, repayment obligations, and reputational harm. If enacted, HB 970 would reduce professional standards, compromise patient safety, and expose Virginia dental practices to unnecessary legal and financial liability. The most effective way to expand access to preventive oral healthcare is to support licensed dental hygienists practicing at the top of their scope and invest in proven strategies like properly accredited EFDA programs. As both a former dental assistant and current dental hygiene student in Virginia, I see firsthand how deeply this issue affects our profession and the patients we serve. I urge you to oppose HB 970 and ensure that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards through accredited educational pathways.

After attending the Health and Human Services sub-committee meeting on 2/5/2026, it was clear there was misunderstanding of the concepts of dental hygiene education and practice for the committee members. There are foundational differences in the education of dentists and dental hygienists - dental hygiene is not a subset of dentistry, it is its own entity. Dentists are primarily responsible for diagnosing oral disease and restoring hard tissue, with other specialties addressing more niche applications such as oral surgery and orthodontics. Dental hygienists are primarily responsible for the prevention and treatment of oral disease related to the periodontium (the gum tissue and supporting bone). Dental hygienists receive a thorough education to assess, diagnose, treat, and evaluate oral health conditions such as gingivitis and periodontal disease. This education includes courses in dental anatomy, radiology, pharmacology, theory and practices, ethics, pathology, oral anesthesia, dental materials, and a large number of clinical hours spent practicing dental hygiene care. Dental students at VCU receive education on dental hygiene instrumentation in one lecture, one lab session on a student partner, and one simulation model before performing cleanings on their restorative patients. Dental hygienist students spend their entire 2 years dedicated to this study after 2 years of pre-requisite courses. The skills required for scaling teeth effectively are very different from those required to prepare teeth for restorations such as fillings and crowns. I am in no way discounting the difficulty and skill level of dentists; however, I am saying that the skills they have are not interchangeable with the skills that dental hygienists have worked for years to hone. The conversation of the delegates quickly strayed from what this bill is actually about. The bill related to foreign trained dentists is not a problem of immigration or workers - it is a problem because dentists are not trained to be dental hygienists. Avenues to allow foreign trained dentists to be dentists would be more appropriate, as that is the specialty they were trained in. In summary, dentists treat the teeth, hygienists treat the gums – they are two very important and different aspects of your mouth that contribute to your oral health. I urge the legislators to do their duty by opposing this bill. Listen to the experts on periodontal oral health prevention, the dental hygienists, and make informed decisions that protect public safety.

My name is Elena Cantwell. I am a fourth-year dental student at Virginia Commonwealth University, a Second Lieutenant in the United States Army, the granddaughter of a dentist, and the daughter of a dental hygienist. Most importantly, I am a proud registered dental hygienist in my own right, and I occupy a uniquely informed position within the oral health care system. I graduated from VCU’s dental hygiene program in 2021 and will graduate from VCU’s DDS program in 2026. This dual perspective gives me a clear understanding of the education, clinical judgment, and patient safety considerations required at every level of oral health care. For these reasons, I strongly oppose HB 970/SB 178 and SB 282/HB 1036. I can state with confidence that this proposed legislation will result in supervised neglect of oral disease. Supragingival scaling is not a mechanical or isolated task. It requires clinical judgment, the ability to assess oral tissues, recognize disease, and determine when referral or advanced intervention is necessary. Without comprehensive education and training, disease will go undetected, be improperly managed, or falsely reassured. Allowing individuals with substantially less education to perform preventive procedures undermines the standard of care and exposes patients to avoidable harm. It also devalues the dental hygiene profession by permitting core preventive services to be delivered without equivalent training, accountability, or licensure. Patients reasonably expect that licensed providers meet uniform educational and clinical benchmarks. Blurring professional boundaries weakens licensure integrity and sets a dangerous precedent. Having been trained in both dental hygiene and dentistry, I firmly believe that workforce shortages and access challenges must be addressed by strengthening, not diluting, professional standards. Dividing essential members of the dental team does not increase access to care, it jeopardizes it. Collaboration between dentists and dental hygienists is not optional; it is essential for safe, high-quality care. My own education highlights this distinction clearly. In dental school, my colleagues and I receive one to two lectures and a single hands-on session on scaling technique. The reality is that scaling is not the forte of the general dentist. Dentists focus on restoring existing disease; dental hygienists focus on preventing it. Dental hygienists spend thousands of clinical hours mastering instrumentation to effectively remove bacteria above and below the gumline. This level of expertise cannot be replaced with abbreviated and unregulated training. Forgoing effective disease prevention only increases the cost of care for patients. Poor management of oral disease leads to progression, systemic health implications, and a cascade of preventable health concerns for our community. Additionally, my patients and your constituents deserve better than a system that pits professionals against each other. For these reasons, I respectfully urge lawmakers to oppose SB 178/HB 970 and SB 282/HB 1036. Patient safety, public trust, and the integrity of licensed health professions must remain the priority in any legislation affecting oral health care in Virginia. Thank you for your time and consideration. I urge you to make the just decision, one that protects patients and honors the licensed, trained, hardworking, and compassionate professionals who serve them.

Approving this bill will take a detrimental impact on the communities most at need. Improper prophylactic procedures will mask disease and exacerbate risks to the public including increase in Medicaid costs in the end. These costs will seem lower at first until disease progresses into life threatening infections in the states most vulnerable populations resulting in increased costs in emergency room visits with infections, exacerbations of medical diseases like diabetes and heart disease. It is appalling that this bill would be proposed to solve a perceived shortage of qualified professionals that depend on dental hygienists to prevent disease and some spend 3,000 of education and residency hours practicing to prevent. This bill will allow on the job training of 129 hours which does not equate to a proper prevention model. The definition of prophylaxis or D1110 is "Removal of plaque, calculus, and stains from the tooth structures and implants in the permanent and transitional dentition. It is intended to control local irritational factors." which the current bill proposed does not serve. Vote no to protect the patrons of this beautiful state. I am a master level dental hygienist with specialty in community outreach, and public health in my county of Fairfax, VA.

Dental Hygienists are prevention specialists. We have training in microbiology, anatomy, physiology, pharmacology, histology, periodontology, pathology and public health outside of the physical training on how to scale teeth. This prepares us to evaluate and treatment plan our patients needs. To let an untrained assistant or a foreign trained dentist do any of this is substandard care. If the foreign trained dentist wants to do it let them pass the same written and hands on board tests hygienists have to complete prior to being licensed.

I am writing to ask you to oppose the passage of HB970. This is a health and safety issue that will affect thousands of dental patients in Virginia. I am a retired dental hygienist who worked for 50 years in both private dental offices and in public health with the Virginia Department of Health. What is being proposed by the Virginia Dental Association will have short and long-term effects on not only the dental health of our patients, but their general health when the prophylaxis does not include subgingival scaling, for which dental hygienists have extensive training, disease will occur. This includes not only tooth decay, especially an older adults, but also gum disease in children and adults, as well as the risk of impacting diabetes, heart disease, pulmonary conditions- the list goes on! Is this what we want for our Commonwealth citizens? Over my 50 years of practice, the Virginia Dental Association has not only impeded and limited the full scope of practice of dental hygienist, but now are actually threatening the health of our patients. Please do not allow this to happen. There are other ways to address the need for more hygienist and dental offices. P.S. If you do vote for this and this passes, then make sure the next time you go for your ‘cleaning/prophylaxis’ that YOU ask to see the license!

Letter provided in opposition to HB970 and HB1036

Please see attached file for: Re: Letter Opposing HB 1036

My name is Brenda Bradshaw. I am a licensed dental hygienist and associate professor of dental hygiene. I strongly oppose HB 1036 and SB 282, legislation that would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia. These bills rely on workforce substitution models that are not supported by evidence showing improved access to care, patient safety, or better health outcomes in states that have already adopted similar policies. Florida provides a clear and cautionary example. In the 1990s, Florida began allowing internationally trained dentists to become licensed dental hygienists by meeting licensure requirements—such as examinations and credential review—without completing a dental hygiene education program. Between 2010 and 2012, there was a sharp increase in applications from foreign-trained dentists, which drew public attention and controversy. Today, Florida residents continue to raise concerns regarding education standards, supervision, and patient safety. Most importantly, workforce substitution has not solved access-to-care shortages. Despite aggressive policy changes, Florida currently ranks last in the nation for dental access. It has the lowest rate of children receiving dental visits, and 65 of its 67 counties remain federally designated dental health professional shortage areas—even after permitting foreign-trained dentists to practice as hygienists. In 2024 alone, emergency room visits for preventable dental conditions cost Florida nearly one billion dollars. Florida also ranks among the highest states for periodontal disease. Estimates based on National Health and Nutrition Examination Survey data place Florida third in the nation for overall periodontitis prevalence and fifth for severe periodontitis among adults aged 30 to 79. Additionally, Florida ranks among the top five states nationally for medical malpractice payments, including dental-related claims, according to data from the National Practitioner Data Bank. This raises serious concerns about patient safety and oversight. Virginia should not replicate approaches that have failed to deliver measurable improvements in access, safety, or outcomes elsewhere. I respectfully urge you to oppose HB 1036 and SB 282. Thank you for your time and consideration.

The laws trying to allow assistants and foreign trained dentists to scale are concerning. I keep seeing statements that it will expand access to care. What kind of care is it? More people having access to substandard care is not care. I do not know of one dentist who will sit, watch, and supervise someone else cleaning teeth for 20 hours. They will not take time out of their production filled schedule to properly train an assistant if it could even be accomplished that quickly. Also, most dentists do not clean teeth very well by their own admission. Who will make sure the assistants only scale above the gum line and that it is a healthy patient? The people who have not had care due to access issues typically are not healthy anyway. Who will complete periodontal probing? Is it even possible to clean appropriately without being sub gingival? How are you going to track any of this? Just take people’s word that they are following the law? It’s concerning because patient safety and quality of care are at risk without any oversight of how this is going to be implemented in real offices.

I am writing to inform you that I OPPOSE HB1036 and HB970. As a dental professional, I know that if these bills are passed, we are putting the health of Virginia citizens at risk. Why would we consider something that is not in the best interest of our community? These bills would lower the standard of care in our state. One point I'd like to bring up is the assistants being allowed to scale above the gums only. This is an absolute waste of time. If someone is going to a dental hygiene appointment and only having their teeth scaled above the gums, you are not getting proper care. The entire point of going to a dental hygiene appointment with a LICENSED and EDUCATED dental hygienist is to have the tarter removed from below the gums to prevent an infection or treat an infection if one has already started. So we are going to allow patient's to get an above the gum cleaning only? And allow the tarter to just remain there under the gums? This is supervised neglect. The patient's that have these above the gum only cleaning are going to have major periodontal (gum) infections in the future. This is going to damage their overall health (because gum disease is associated with heart disease, diabetes, Alzheimer's, cancer, etc.) and they are going to have to pay more money to get this treated when it could have been prevented in the first place. There is also absolutely no way dentists are going to be able to monitor and oversee what is really happening in these appointments. And allowing a dentist from another country to come to the United States and work as a hygienist is taking away jobs from American dental hygienists and also lowering the standard of care we expect. Training requirements and education for dentists in other countries varies. How do we know that they received the training and education that we have in America? Who is verifying this? These bills are backed by money hungry insurance companies and greed. Please protect Virginia!

Concerned citizens of Hampton Roads signed a peition to STRONGLY OPPOSE HB 970 AND HB 1036. The attachment is too large for attaching here, so please check your emails delegates as I will send them there as well. There are 1010 signatures we have been able to collect since starting on 1/21/26 and we will continue to collect and share as we get them. Thank you.

I am a licensed dental hygienist and certified dental assistant in Virginia and I oppose HB 1036. While I respect the dentists and their education, lowering the requirements that all practicing hygienists in the commonwealth have completed for varying education and one board exam would be detrimental to the patients. Any person practicing dental hygiene in the state of Virginia should complete a CODA certified program. There are many other ways around the shortage, such as license portability and reciprocity measures, expanding the scope of existing hygienists, increasing class sizes (and therefore faculty sizes), and funding for more dental hygiene schools. While good intentions are made with this bill, the patients of Virginia deserve better, please oppose. Makenzie Green, RDH, CDA

I OPPOSE HB970 and HB1036! These bills are not in the best interest of Virginians. Our health is at risk if we allow these nonsense bills to pass. Please protect the health of Virginians! Dentists do not want to deal with the possible risks associated with these bills.

I am writing to OPPOSE HB970 and HB1036. This bill is backed by corruption and greed. HB970 would essentially allow for supervised neglect in dental care. Dental assistants serve an important roll in dentistry, but they are required to have NO educational background. Dental hygienists spend at least 2 years studying their practice in disease prevention and disease treatment. Nail techs are required to do more hours of training than what this bill proposes for just anybody off the street to be using sharp instruments in your mouth. This makes no sense! Please protect the health and well being of the people of this state. Don't let Virginia fall below the standard of care when it comes to our oral health. Virginians deserve better! HB1036- If dentists want to come work in the United States as either dentists or dental hygienists, they need to go through the same education and training to make sure that we are receiving the standard of care that you would expect from your health care professionals!

I am writing to STRONGLY OPPOSE HB1036 and HB970. Gum disease is directly related to heart disease, diabetes, Alzheimer's disease, and even certain cancers. Gum disease happens when tarter forms UNDER the gums and causes an infection. HB970 would allow dental assistants with no educational background to remove tarter above the gums. Almost every single person has tarter below the gums when they come in for their dental hygiene appointments. What good is it to allow assistants to scale just above the gums? This does not prevent and treat disease! Dental hygienists are go through at least 2 years of rigorous training. They study anatomy, physiology, pharmacology, biology, chemistry, pathology, microbiology, nutrition, radiology, local anesthesia, and so much more. Dental hygienists are not just "teeth cleaners" but focus on the overall health of the patient and disease prevention. When there is disease, they are trained to treat the disease. Dental hygienists are trained to use special instruments to clean UNDER the gums to prevent and/or treat gum disease. IF this bill passes, there is no way to monitor the assistants during each appointment to make sure they are just scaling above the gums and not breaking the law and putting the patient's safety and well being at risk. I'm sure there will be many that will get too comfortable and attempt to scale below the gums, which can lead to serious damage and risks for the patient. There are many other solutions that the Virginia Dental Hygienists Association has come up with that does not put the safety and health of Virginians at risk. Please do not let foreign dentists come into this country and take the jobs of American trained dental hygienists. Who knows what type of training they have received and if it is even up to our standards. At the end of the day, this comes down to one thing...greed and money in the pockets of the people pushing for this. Please do the right thing and protect the citizens of Virginia and keep their best interests and health as your top priority.

Greetings Virginia House Subcommittee, I'm writing to oppose HB970 / SB178 and HB1036 / SB282. I'd like to request my letter be used as testimony. I'm a licensed hygienist, having had to pass three board examinations in order to practice; a national board, a state and a clinical board. My accredited program and its accrediting body, the Commission on Dental Accreditation (CODA), are necessary steps in ensuring safe patient care. Practicing as a dental hygienist is so intricate that I carry liability insurance because I could be sued in the event of negligence or malpractice. Dental hygienists are at the forefront of recognizing and treating periodontal disease. Periodontal disease is linked to preterm labor, heart attack, stroke, diabetes and Alzheimer's. "On the job" training is dentist dependent and doesn't replace the hours I spent in college courses on pharmacology, oral pathology, physiology, and so forth. The Standard Occupational Classification (SOC) by the United States Office of Management and Budget has classified hygienists as Healthcare Diagnosing or Treating Practitioners, the same category as dentists. Can education and practice so significant be replaced? Virginia's population is placed at risk for greater health complications, both orally and systemically, when conditions are unrecognized and untreated. Employment shortages must be addressed through expansion of existing accredited programs; patient care should not be placed in jeopardy. I personally would not consider a move to a state authorizing "on the job" training, and Virginia might lose hygienists as a result of HB970 / SB178 and HB1036 / SB282 being approved. In my time as a dental hygienist, I've seen "on the job" trained assistants do unacceptable things, including actions that place their own health at risk, such as reaching bare handed into an ultrasonic cleaner to pull out dirty instruments. Have you seen the video of a dentist on a hoverboard while extracting teeth? Thankfully he was caught and charged. However, the unfortunate reality is that dentists are just people too that can make errors in judgement (and thus also training). Dentistry is hard physically on your body. My education also covered how to prevent long term musculoskeletal disorders. Who's going to be looking out for those that will need disability in a few years as they are practicing physically unsafe ergonomics? Medical assistants can not receive training through non-accredited means in order to fulfill Registered Nurses workforce shortages; the same should be true for Registered Dental Hygienists. I would never dream of having non-accredited training in order to make crowns or perform fillings on patients. Accrediting bodies ensure dentists provide safe care to their patients and the same should be said for patient hygiene care. My biggest fear for Virginia is for patients who do not know what is and is not safe and are relying on those in trusted healthcare positions. Please keep the oral health care of Virginia's citizens safe. Please oppose HB970 / SB178 and HB1036 / SB282. Respectfully, Sarah J French Linthicum, RDH 891 Station St. Herndon, Virginia

I am have been dental healthcare professional for over 17 years. I have practice as a dental assistant and currently practicing as a dental hygienist. I want to express my concerns regarding HB 970 and HB 1036. HB 930 wants to create the role of preventative dental assistants. Most of the public doesn't know that dental assistants currently don't need any formal education to do their jobs, just on the job training. Dental assistants aren't required to taken any infection control, anatomy (dental or otherwise), medical emergency courses that would give them the knowledge to keep patients out of harm. The bill states these assistants would be supervised by dentist to verify their hours. Dentists while in school might receive at most a month worth of training in the skill of "cleaning" teeth. These course are taught by dental hygienists. Upon completion of this training, dentists are not required to prove their skills. Dental hygiene students train for 2 plus years to prefect their skills and the diagnosis of gum disease. HB1036 wants to just give a dental hygiene license to foreign dentists. I will refer back to my earlier statement about dental students in the USA only receiving at most a month of training supervised by dental hygienists. We do not know what these foreign dental schools curriculum looks like. This is putting the public at higher risk for malpractice and harm. Lastly as any healthcare professional we took an oath to prioritizing the needs of our patients and we are held to a high ethical standard. By devaluing and downgrading the dental hygiene profession and care of the public is a great disservice to our oath and our community.

Another graduate of our program from 2023, Fernanda Vasconcellos Rossi, was a former dentist from Brazil. She was also unable to be here today, but I would like to share the testimony she provided to me which also directly challenges the assumptions underlying HB 1036 / SB 282: “I am sharing my personal experience as an internationally trained dentist, which speaks directly to the importance of proper education and preparation in the dental hygiene profession. My name is Fernanda Vasconcellos Rossi, and I am a dentist originally trained in Brazil. After coming to the United States, I learned that in the state of Florida, internationally trained dentists may have the opportunity to become dental hygienists by completing the board examinations. At first, this pathway seemed like a faster option. However, I quickly realized that providing oral healthcare is a serious responsibility, and I did not feel it would be ethical to treat patients without being fully prepared for the specific scope and standards of dental hygiene practice in the United States. Because I take patient care very seriously, I made the decision to enroll in the Dental Hygiene Program at Old Dominion University (ODU) in Virginia. Even though I already held a dental degree, the program showed me that dental hygiene is not simply an extension of dentistry—it is a specialized profession with its own depth, training, and clinical excellence. Through my education at ODU, I gained essential knowledge and hands-on experience in preventive care, instrumentation, periodontal therapy, radiology, patient management, and evidence-based practice. The program was fundamental to my professional formation and helped me develop the confidence and competence necessary to provide high-quality care. Today, because of the strong foundation I received at ODU, I have been able to advance professionally and currently have the honor of teaching at the University of Florida in the Periodontics Department. I truly believe that my success in this role is directly connected to the education and training I received through the dental hygiene program. I hope my testimony helps highlight that dental hygiene should be recognized as a serious and specialized career that requires proper education, preparation, and respect—especially for internationally trained dentists seeking to enter the profession. Thank you for your consideration of my testimony. Sincerely, Fernanda Vasconcellos Rossi, DDS, RDH” These summaries of these graduates' lived experiences as an internationally-trained dentists in dental hygiene school are telling to the specialization of dental hygiene that requires rigorous and specific education. This is evidence of the specialization that dental hygiene is as a profession, rather than just a subset or afterthought of dentistry. The educational standards and competencies in place are for the safety of the public and the health of our patients. Please also see the attachment regarding board examinations and this population. I urge you all to oppose HB 1036 and not let it get any further. Thank you for consideration of this testimony. Sincerely, Jessica Suedbeck, RDH, BSDH, MSDH, PhD(c)

Hello Chair Price and Committee Members, Hi, my name is Jessica Suedbeck and I am a licensed dental hygienist and associate professor in dental hygiene education here in Virginia. I am here today to strongly oppose HB 1036 (SB 282), legislation that would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA)–accredited dental hygiene education program or the required hands-on clinical training specific to the profession. In opposition to this bill, I would like to share the lived educational experience of a recent graduate of the Bachelor of Science in Dental Hygiene program at Old Dominion University. Lily Salazar, Class of 2025, entered the United States already licensed and trained as a dentist in Peru. Despite her prior dental education and clinical experience, Lily chose to complete the full, CODA-accredited dental hygiene program at ODU in order to practice dental hygiene in the United States. Upon enrolling in the School of Dental Hygiene, Lily completed the same prerequisite coursework and the full two-year dental hygiene curriculum required of all students. Although ODU carefully evaluates prior education for transferability, none of her previous dental coursework was deemed equivalent to dental hygiene prerequisites or core curriculum courses. Throughout the program, Lily consistently shared how distinct and specialized dental hygiene education was from her prior dental training—particularly in the areas of periodontal disease, prevention, instrumentation, and patient-centered preventive care. With Lily’s permission, I am sharing testimony she provided for me as she could not be here today, which directly speaks to the assumptions underlying HB 1036 / SB 282: “I never imagined that being a dental hygienist in the United States would be such a challenging yet rewarding career. Although I am a dentist with a degree from another country [Peru], it did not lessen the intensity of the studies required for the dental hygiene profession. My ODU education provided me with a solid foundation in dental anatomy, dental materials, prevention, and other essential subjects. However, the scope of dental hygiene was entirely new to me. Learning about the various scaling and root planing instruments, as well as how to perform different treatments, presented a steep learning curve. I also had to adapt to the state-of-the-art digital radiographic equipment and understand the ALARA guidelines while performing radiographic exams. Additionally, I gained new insights into universal precautions, the connection between oral health and its role in preventing heart disease and other systemic conditions, and the latest staging and grading systems for periodontal disease—just a few of the many important aspects of this field. I hope that all international dentists come to recognize the importance of dental hygiene as a specialized profession that deserves to be taken very seriously. While my dental degree studies in Peru had periodontics condensed into just four months, dental hygiene is an entire career and should be viewed as a specialty within periodontics and treated as such. Thank you for consideration of my testimony, Lily Salazar Lily Salazar, DDS, RDH, BSDH Graduate Teaching Assistant” I will submit testimony from another graduate separately as there are not enough characters, but they go together. Thank you.

Comments Document

Honorable Committee Members, I am writing to express my strong opposition to HB 1036, which would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without completing a Commission on Dental Accreditation (CODA) accredited dental hygiene education and required clinical hours and training. This measure does not address the gap in the dental workforce because it will not produce any new qualified providers and could drive some licensed hygienists out of the market. Please read my letters of opposition HB 1036 below. Sincerely, Mirtill "Mimi" Magyar Registered Dental Hygienists (retired)

Comments Document

Honorable Committee Members, Please read my letters of opposition HB 970 below. Sincerely, Mirtill "Mimi" Magyar Registered Dental Hygienists (retired)