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 have been a dental hygienist for 14 years. This legislation that proposes allowing dental assistants scale teeth is not solving an access to care issue to the patients that it is supposed to serve and in fact causes more problems for the patientsand the dental community. This legislation states that these assistants are to just clean supragingivally (above the gum line). Cleaning teeth this way allows periodontal (gum) disease to worsen by not addressing the bacteria load below the gumline. Periodontal disease is the #1 cause of adult tooth loss. Affecting over 50 percent or more of the adult patients over 30 years of age. Periodontal disease is a extremely common, painless, infection the the gums that becomes destructive to the bone that supports teeth. The bone loss is permanent and can lead to tooth loss if left untreated. It is the job of dental hygienist to screen patients (periodontal charting) and treat the patients that have periodontal disease with scaling and root planning ( below the gumline) hygiene services as well as administering subgingival medication to the diseased areas. The problem with leaving the preventative/ hygiene care in the hands of dentists and dental assistants is the assistant doesn't have the knowledge and skills and the DENTISTS DO NOT HAVE TIME FOR PERIDONTAL DISEASE DIAGNOSTICS OR TREATMENT! I have never in my career seen a general dentist do a gum disease screening (perio chart) or perform a scaling and root planning procedure to treat periodontal disease. Gum disease is too tedious and time consuming to treat and diagnose that dentists are reliant on their hygienist to perform the screening (perio chart) and identify patients that need gum disease treat before they even set foot into the room with the patient. Dentists are extremely busy only allow themselves around 3-5 minutes to examine a patient. A periodontal chart to screen for gum disease takes around 15 minutes to complete and treatment of gum disease takes 2-3 hours to complete for full mouth treatment. None of this fits into a dentists timeline. If the patient is not in the care of a dental hygienist their gum health needs will be skipped over to the detriment of the patient. I feel that the only person this legisation serves is the dentists. The dentists are interested in having dental assistants in this role to save on labor costs, driving down the wages of dental hygienists and eliminating many of our jobs. They call this an access to care issue because of a shortage of dental hygienists . I feel making dental hygiene education (associates degree) from accredited colleges more accessible would solve these problems. For example, it took me 5 years to complete my associates degree because of prerequisite requirements and wait lists. The barrier to entry can feel too difficult for many students interested in becoming a dental hygienist. Thank you for your time and consideration.

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 was passionate about preventive care, particularly periodontal health. Growing up, I did not fully understand how closely oral health is connected to overall systemic health. That realization, along with following in my mother’s footsteps, inspired me to pursue this profession. I was adopted and came to the United States twenty-two years ago. I still vividly remember my first dental cleaning. At the time, I was frightened because I believed my tooth was being damaged, when in fact hardened calculus was being removed. In my home country, dental visits were primarily problem-driven—we sought care only when in pain. Preventive dentistry was not emphasized. What impressed me most about dental hygiene in the United States was its strong foundation in prevention, education, and evidence-based practice. Dental hygienists are not simply “cleaning teeth.” We assess periodontal health, remove both supra- and subgingival deposits, identify early signs of disease, educate patients, and serve as a critical link between patients and providers. Prevention is not incidental to our role—it is our primary responsibility. I want to be clear that this is not about diminishing the important work of dental assistants. They already carry significant responsibilities within restorative dentistry. However, restorative procedures and periodontal instrumentation are distinct clinical disciplines that require different educational preparation and clinical competencies. Scaling limited to the supragingival area while leaving burnished calculus subgingivally does not meet the accepted standard of care and may contribute to disease progression. Incomplete subgingival debridement can accelerate periodontal breakdown rather than prevent it. Additionally, improper instrumentation can result in irreversible soft tissue trauma, including damage to the interdental papilla. These procedures require comprehensive education through accredited U.S. dental hygiene programs and successful completion of rigorous national and clinical board examinations. Any legislative change that lowers educational and clinical standards risks compromising patient safety and long-term oral health outcomes. Protecting the standard of care is not about professional hierarchy—it is about ensuring that patients receive the highest quality preventive services from properly trained providers. I chose this profession with pride and purpose. I respectfully urge you to protect the integrity of dental hygiene practice and to avoid changes that could weaken the standard of care our patients deserve. Thank you for your time and thoughtful consideration.

I am writing again in opposition of HB970. To emphasize again...there is no science that says that a supragingival cleaning will have a positive impact on patient health. The studies from Missouri were incredibly flawed and should not be used in decision making...no matter who is presenting them to you and how convincing they sound. This is a con that private equity and corporate dentistry loves to line their pockets. Real dentists and practices do not believe in this bill. So a win for this bill is a win for private equity and corporate dentistry which may have a lot of money but does NOT represent your constituents.

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

Please oppose these bills to maintain public health and safety.

Hello. I am a practicing dental hygienist of 23 years and have treated patients with disease at different stages. I truly care for them and my profession, please help me to understand how passing these bills (HB970 ans SB178) make sense. I strongly oppose these bills which will ONLY put patients at risk for advanced disease and the need for a more advanced level of professional care anyway.

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'm writing again in firm opposition of HB970. There is absolutely no impact that a dental health provider can make at the supragingival level. The thought process behind this bill has absolutely no science behind it and only financial concerns. It is motivated by the money and greed involved in corporate dentistry. It will not improve access to care. As I mentioned, there is absolutely nothing that a dental hygiene professional does that only impacts the supragingival environment. EVERYTHING they do from even most simple prophy aspect to flossing has subgingival impact. So truly...cleaning supragingival areas of teeth will not even have a solid impact on preventative health. So this bill hurts public health, it hurts a career that dental hygiene professionals have worked hard to be the experts at, and it does NOT solve any problems. The research that continues to be presented out of Missouri is flawed and no shrewd investigator of research would approve of this study. It was being manipulated by representatives that have been influenced by money. Just because they have dentists in their families does not mean that they are experts. Please please do not pretend to solve an issue just to further line the pockets of corporate dentistry. You will be hurting patients and the dental hygiene profession to line the pockets of private equity. Private equity are not your constituents. The people are and this bill HURTS them.

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.

Vote NO, I don't understand how this is even considered. ADA/VDA knows better.

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.

As a Registered Dental Hygienist with 26 years of clinical experience in the Commonwealth of Virginia, I write in strong opposition to HB970. My concerns are not rooted in professional protectionism, but in patient safety, evidence-based practice, and the long-term oral and systemic health of our communities. For more than two decades, I have assessed periodontal disease, identified early signs of oral cancer, detected systemic health indicators such as uncontrolled diabetes and cardiovascular risk factors, and provided preventive interventions that reduce the burden of disease. Dental hygiene care is not merely “cleaning teeth.” It is a preventive, therapeutic, and diagnostic-support role grounded in rigorous education, licensure standards, and clinical accountability. Legislation that expands delegation of duties or alters scope without equivalent education, training, and regulatory oversight places the public at risk. Periodontal disease is a chronic inflammatory condition with documented associations to systemic illness. Early oral cancer detection requires advanced knowledge of pathology, risk assessment, and clinical judgment. These are not interchangeable tasks that can be reassigned without consequence. While workforce shortages and access-to-care challenges are real, solutions must not compromise quality. Lowering standards or redefining roles without maintaining clinical safeguards does not improve public health; it creates a two-tiered system of care. Vulnerable populations, who already experience disparities, would be most affected by diluted standards. If the intent of HB970 is to increase access, then we should pursue evidence-based solutions: expanding public health dental hygiene models, incentivizing practice in underserved areas, strengthening collaborative care agreements, and investing in prevention-focused programs. Protecting access and protecting standards are not mutually exclusive. As clinicians, we are ethically bound to do no harm. Public policy must reflect the same principle. I urge legislators to carefully consider the downstream impact of this bill on patient safety, early disease detection, and long-term healthcare costs. The oral cavity is not separate from the body, and oral health decisions reverberate through the entire healthcare system. For the sake of our patients, our profession, and the health of the Commonwealth, I respectfully but firmly oppose HB970. -Amy DiGregorio, RDH, BS, MS candidate

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.

I oppose both bills. I have worked with assistants who were “trained” to scale supragingivally, and caused a lot of damage to the tissue as well as removed enamel from the tooth. There is a reason dental hygienists are trained so rigorously in accredited programs.

I am in opposition of the proposed bills of foreign trained dentist and dental assistants providing dental hygiene services. The Dental Hygienists hads trained in over 2900 hours and obtained a college degree. We have taken many clinical and written exams to show our compentency. We have taken an oath to uphold a high standard of care. If this bill was to be approved, patients will receive substandard care and dentists will br held liable for supervised neglect due to staff not having the education or skills to provide care to stabilize disease and prevent it. An alternative solution is to let Hygienist be independent practioners, like a nurse practioner is in the medical field. This is an established field in Pennsylvania and Colorado. The Hygienist can open a practice of their own and work in a collaboration with the dentist of the patients choice. Thank you for your time. Please consider the damage this could do to the health care field with substandard education and training. Respectfully, Nicole Schiffer

I am a dental hygienist and I do not support this bill. Lowering costs in which dentist pays their assistants verses their hygienists means lowering patients standard of care and the patients in Virginia do not want this. All dentists voting yes for this should be ashamed. And their names should be known and flagged for good.

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.

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.

My name is Breanna Ballesteros, and I am a licensed dental hygienist practicing in Alexandria, Virginia. I recently moved here from Arizona, where I was also a licensed hygienist, and I have gone through the full licensing process in Virginia. I can attest that the process was both thorough and commendable—it truly reflects the state’s commitment to upholding the integrity and safety of our profession. I am writing to express my strong opposition to SB 178/HB 970, which would allow dental assistants with only on‑the‑job training to perform procedures that fall squarely within the licensed dental hygienist’s scope of practice under the proposed “Preventative Dental Assistant” model. This legislation represents a serious step backward for oral healthcare in Virginia. It disregards patient safety and the specialized education and clinical competencies that licensed dental hygienists are required to attain before ever providing care. Scaling and preventive procedures require not only advanced instrumentation skills but also clinical judgment and assessment ability—competencies taught exclusively in CODA‑accredited dental hygiene programs. Licensed hygienists undergo years of education, hands‑on clinical training, and rigorous testing to ensure their readiness to deliver safe and effective care. Allowing unlicensed assistants—or even individuals with revoked licenses—to perform these procedures erodes the safeguards that protect patients from preventable harm. I am also deeply concerned about the insurance, billing, and legal implications of SB 178 and HB 970. Because “Preventative Dental Assistants” would not be authorized to perform a complete prophylaxis, dental practices could not ethically bill under the D1110 code. Instead, they would be forced to use D1999, which is reimbursed at a lower rate and requires extensive justification. This creates real pressure on practices and opens the door to improper coding, denied claims, and even allegations of insurance fraud—all of which jeopardize both patients and providers. I have seen firsthand how dentistry functions best when every team member works within their legal scope of practice. Lowering those standards will not meaningfully expand access to care but will instead compromise patient safety and professional accountability. I strongly urge the House of Virginia to oppose SB 178 and HB 970 and to continue supporting licensed dental hygienists—professionals who have demonstrated, through education and regulation, their commitment to safe, high‑quality, and ethical patient care. Thank you for your time, service, and dedication to safeguarding Virginia’s oral health standards.

As a Doctor and patient, I believe it is a disgrace to allow someone who has not gone through the proper schooling, training and experience, practice dental hygiene on patients. Lowering professional standards is not a responsible solution to access challenges. As a patient, I want policies that strengthen the dental hygiene workforce we already have and expand access in ways that are proven, safe, and effective. Supporting licensed dental hygienists to practice at the top of their scope and investing in evidence-based workforce solutions are far better approaches. The “Preventative Dental Assistant” model introduces risk without providing benefit to patients or communities.

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 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 that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards.

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 would like to prevent this as I am currently a dental Hygine student and I know the risk there are going to be with Assistants benign able to work on patients with no schooling or education on this matter! Oral cancer screenings are one of the most important parts of the dental visit and this will not be done if an assistant is doing the cleaning.

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

Supragingival scaling and coronal polishing require clinical education and training to perform safely. These procedures involve understanding oral anatomy, recognizing disease, and using proper technique to avoid harming patients. Dental hygienists complete accredited education programs, clinical training, and licensing exams to ensure patient safety. Dental assistants do not receive the same level of education or clinical preparation. Allowing less trained personnel to perform these procedures increases the risk of injury, missed disease, and lower quality of care. Access to care should be improved without lowering clinical standards or putting patients at risk. I respectfully urge you to oppose HB970 and SB178 to protect patient safety.

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

We should not allow dental assistants to do the job of a dental hygienist. I understand that there is a shortage of hygienists, but the current proposal is not the correct answer to resolve this issue. Dental assistance with relatively no training are not at all qualified to perform the role of a dental hygienist. Please take time to consider the long-term consequences of proceeding with this dangerous bill. One simply needs to compare the hours suggested in training the dental assistance in the bill to the current standards of dental hygienist. Also dentist coming from other countries should be required to pass test and board certifications in order to do a hygienist job. I’m extremely opposed to this bill as a Virginia resident since 1977 (except for 1 year of that I resides in PA).

I oppose this bill!! As a RDH, this is very degrading. It took 2 years of clinical practice, and then hands on experience in a job environment to fully grasps the concept of scaling and hygiene. Doctors will not have time to teach assistants how to do there jobs and HYG, will disagree with training them because we went to school for it, so they can too. This doesn’t fix the underlying problem. Do better.

Opposition to HB 970 and HB 1036 My name is Tamara Matthews and I have been a licensed dental hygienist since 1997. I strongly oppose HB 970 and HB 1036 because these bills create a clear public safety risk. They attempt to solve access issues by lowering the standard of care instead of addressing the real barriers to treatment. In dentistry, what we see clinically is often only the tip of the iceberg. Visible plaque and calculus are simply the outward signs of underlying disease processes such as periodontal infection and bone loss. Allowing unlicensed, unqualified, and insufficiently educated dental auxiliaries to perform scaling above the gum line ignores what lies beneath the surface. Without the education and clinical training of a licensed dental hygienist, these conditions will go undetected, untreated, and potentially worsened. Dental hygienists do far more than “scrape teeth.” We are the front line of preventive care. During routine visits we take and interpret blood pressures, perform oral cancer screenings, assess periodontal disease and bone loss, evaluate airway and breathing concerns, and provide patient education that prevents long-term disease. This is not an exhaustive list of our responsibilities, but it demonstrates the medical nature of our role. These responsibilities require education in pathology, pharmacology, anatomy, radiology, and medical risk assessment — not just mechanical instrumentation. Delegating these duties to assistants or internationally trained dentists without proper licensure does not increase safety or access. It lowers the standard of care and risks delayed diagnoses, missed pathology, improper treatment, and long-term consequences for patients. This legislation does not address the real issues affecting access to care. Instead, it creates new ones by diluting professional standards and compromising preventive healthcare. Public safety should never be balanced against convenience. For nearly three decades I have served patients with the responsibility entrusted to licensed professionals. These bills would undermine that protection and ultimately harm the very patients they claim to help. For these reasons, I respectfully urge you to oppose HB 970 and HB 1036.

Totally oppose this.. takes years of hard work and study to become a qualified Hygienist. My daughter has been a Hygenient for over 20 years after years of school and studies. I or on one else want anyone off the street with a certificate to be a profession Hygienist. Oppose !!!

These profession's should require the extra training . I do not want someone off the street not qualified to clean my teeth or qualified to give me an xray .

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 in a dental hygiene program at the university of Maryland even tho I am from Virginia, I didn’t get accepted into any schools in Virginia and so I went to umd and want to practice in my home when I’m done but stuff like this makes me want to stay in Maryland. Maybe you guys should work on opening more hygiene program seats instead of coming up with terrible shortcuts that will harm patients

Oppose HB970!

Oppose HB970!

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

Oppose HB970!

I am a retired dentist who worked with dental hygienists for over 30 years. I have seen the poor quality of care coming from practices that did not have hygienist working in them. I know that there is a need for more hygienists in Virginia, but HB970 is a short sighted “bandaid” attempt to easing the hygienist shortage. I believe that HB970 would severely decrease patient care and safety. The hygiene training programs in Virginia produce knowledgeable, skillful technicians who are a valuable asset to dental practices and patient care. Vote no for HB970!

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.

These bills are a detriment to the general public but also the dental hygiene profession. This will not fix your issue of having a shortage of dental hygienists, this bill, if passed, will cause qualified working dental hygienists skill set and value to be undermined. Our instruments require extensive training and precision to properly remove tartar, with improper angulation calculus becomes burnished which then worsens any periodontal conditions. Foreign trained dentists are not all the same, I worked with an assistant that was a dentist in Afghanistan and she doesn’t know how to use half of the instruments or even how to take an x ray because they don’t even have that technology. They fired her because she was so incompetent. Most dental assistants are not formally educated, they receive on the job training and typically only have a high school education. Practicing dental hygienists have extensive degrees, and have to pass rigorous boards to be able to be qualified to use our instruments. These bills are a very slippery slope. Dentistry is a business, and with this, they can keep more lesser paid dental assistants to do “above the gum line” scaling, instead of keeping hygienists. Dentists will abuse this. Dental assistants will not stay above the gum line, this will get abused. Then in turn, you will have hygienists leaving Virginia to work in other states with better pay. This will not solve your issue of shortages, it will only exacerbate it. Please do not pass these bills, the wellbeing of the general public is at risk.

I am writing to Oppose HB970 as well as SB178. As a licensed and registered dental hygienist we go through rigorous college courses to learn how to proficiently take care and provide the best services to our patients. Unlike what people say a lot of the time, we do way more than just “clean teeth”. We provide many things such as blood pressure screenings, diagnostic X-rays, oral cancer exams, thorough periodontal charting, prophylaxis cleanings gingivitis cleanings, or periodontal cleanings with adjunct services, nutrition counseling/tobacco cessation, oral hygiene education, and so much more. All of this education, accredited by CODA, is necessary to provide the utmost Standard of care for our patients. There is no such thing as “scaling Supra-gingival” as even the utmost healthy patients you have to go into the sulcus to adequately scale the calculus, plaque, and biofilm or bacteria out. Even on pediatric patients, I have still had to go below the gumline many times. There is no person who would benefit from these bills. This would just cause more issues such as disease to accumulate or even accelerate their current disease or periodontal health. I understand it is frustrating for patients to have to wait so long for appointments as the hygiene shortage, believe me when I say it is just as stressful or irritating to us as well. However, trying to pass laws to make a quicker “fix” is not the way to go about it. As I said this would do more harm than good as it compromises patient safety as well as their oral and periodontal health. Periodontal disease is irreversible, that’s why we do the best to prevent it by providing through examinations, and cleanings on what the patients may need such as gingivitis cleanings with adjunct therapies. Or if they already have periodontal disease, we can only manage it. Another important thing to mention is you cannot just look at tissue and assume it is healthy. Some cases yes, but not always. This is why the periodontal examination is needed before each appointment to determine. One case I remember is I had a patient who does good with homecare, visually the tissue looked healthy, but when I did the periodontal readings the numbers were showing an aggressive form of periodontal disease. I think of this instance because what if someone had only done a “Supra-gingival cleaning” on them? The disease would have only progressed much faster and declined her periodontal health drastically. In conclusion, these bills though made in good intent, are only going to cause issues if they are passed. We, hygienists in Va, would love to work with Dentists/ADA to try and problem solve to create better solutions, but these are not the way to go. Thank you for reading and considering my oppositions Respectfully, A Registered Dental Hygienist (BSDH) fighting for her patients overall health

I am writing in opposition of this bill. I have been in a study club with our local hygienists for over 7 years. They are some of the most passionate patient advocates that I've ever met and are constantly learning new things on how to improve their patient experience. There is no one in the dental field that could represent the patients' best interests better than hygienists due to their passion...literally couldn't imagine any other group of providers (no matter how well trained) that could be more focused on exceptional patient care.

I do NOT agree with these bills. My dental hygenist has taken YEARS of schooling to be able to do what she does, do NOT have some rando person off the street to come in and clean teeth/gums, because first of all: they won't do it correctly and secondly, they won't CARE if they do it correctly or not!!

I am writing an opposition to HB 970.i have been a licensed Dental hygienist in Virginia since 1993. To think my career could be undermined by people in a government setting is unspeakable. Dental hygienists in Virginia have no self regulations so we are at the mercy of the dentist. The Virginia Dental Association has not supported us and we have no voice, no big money to lobby , and feel like the underdog. There is so much wrong with this bill, including encouraged legislative malpractice and insurance fraud. Patient’s health and safety will be jeopardized. The biggest argument for support is that there is a shortage of hygienist. This will not help the problem. No one in the right mind would choose an unqualified person for service instead of waiting. Most likely the opposite will happen, hygienist will feel not valued and leave the profession, especially the older hygienist like myself who are closer to retirement. Passing this bill were encourage other health professions to cut corners on health. Would a CNA be able to continue their education by 120 hours and become RN? That is what this Bill is proposing. No thought has been given on how much money Virginia lose on license and continuing education opportunities for hygienist. Also no licensing for these new clinical assistance. Marie Johns RDH, BSDH VCU class of 1993

I oppose these bills as they undermine the dental hygiene profession and educational standards and put patient health and safety at risk for harm and damaging their health.

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

I am writing to express my opposition to HB970. While the bill may be presented as a way to improve efficiency or expand services, its real-world impact could negatively affect patient safety, access to care, and the integrity of our profession. I urge legislators to carefully evaluate the long-term consequences of HB970 and to engage directly with practicing dental professionals before advancing this bill. For these reasons, I respectfully oppose HB970 and encourage a more collaborative, evidence-based approach to addressing oral healthcare access in our state.

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.

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. A clear misconception is that some scaling above the gumline is better than no scaling. It is true, sometimes patients do have to wait a long time for their dental hygiene appointment. It is not true that coming in on time to have the deposits above the gumline removed would benefit them. When plaque and calculus (tartar buildup) is removed above the gumline it causes the gums to tighten around the tooth and traps remaining bacteria below the gumline. This entrapment is what leads to the exacerbation of preventable and manageable disease. Periodontal disease has been linked to other systemic health conditions such as cardiovascular disease, diabetes, pregnancy complications, Alzheimer’s disease, and certain forms of cancer. Oral health is a key contributor to overall health, but most of what demonstrates true oral health is what is going on below the gumline. Allowing any patient to have only supragingival scaling will prove detrimental to their health. I have seen first hand the implications of supragingival only scaling - exacerbated disease that leads to more involved, expensive treatment and potentially loss of teeth that could have been prevented. Dental hygienists have the education and knowledge to properly evaluate and plan for care of patients who have oral health concerns, educate patients about the different options they have to get their oral health back on track, and provide that important care after their patients have the information they require to make informed decisions. A preventive dental assistant will not have that same educational ability to discuss these important aspects of care with the patients because they will not have been held to the same educational standards of dental hygienists. Putting our patients in the hands of someone who is not prepared because they do not understand the consequences of their actions is unacceptable. As health care providers, it is our job to protect the health and safety of the public. Allowing preventive dental assistants that would scale above the gumline would not protect the health or safety of patients - it would be contributing to active harm. 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. The preventive dental assistant model will lead to higher rates of undiagnosed oral disease, negatively impact systemic health in many individuals, lead to higher rates of tooth loss, and put the public in harm's way. 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 a licensed dental hygienist practicing for 23 years in Virginia, and I am writing to respectfully express my opposition to HB970. Preventive dental care is not a single mechanical task (i.e. 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 programs with extensive clinical training dedicated specifically to preventive instrumentation and periodontal evaluation. Training assistants “on the job” to scale above the gumline is not going to create access to care. In fact, it puts patients at risk for periodontal disease. Every single patient of mine has build up below the gumline, which needs to be removed by a licensed dental hygienist. If this passes as it is written, I am very concerned that many patients will receive substandard care and there will be an increase in periodontal disease. I always want the best for my patients and every patient deserves the best possible care by a licensed professional. Respectfully, Kim Kready Registered Dental Hygienist

Is a registered dental hygienist, I strongly opposed this bill. Supra-gingival scaling alone does not prevent disease. Sub-gingival scaling is absolutely necessary on almost every patient. This bill would significantly lower the established standard of care for our patients.

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!

Public Comment on HB970 – Patient Safety and Prevention Standards Chair and Members of the Committee, Thank you for the opportunity to comment on HB970. I appreciate the intent to expand access to preventive dental care in Virginia, particularly in rural and underserved communities. Access challenges are real. However, expanding access must not come at the expense of patient safety or the integrity of preventive care. Dental scaling is often described as “just cleaning teeth,” but it is directly connected to identifying and preventing gum (periodontal) disease. Gum disease frequently begins below the gumline and cannot be reliably detected by visual inspection alone. Incomplete or inappropriate treatment can allow disease to progress, leading to tooth loss and other serious health consequences. For that reason, I respectfully oppose HB970 as written unless the following guardrails are clearly included: 1. Periodontal evaluation first Before a dental assistant performs supragingival scaling, a licensed dentist or registered dental hygienist (RDH) should evaluate the patient’s gum health. This ensures disease is identified before preventive treatment is provided. 2. Clear patient eligibility limits Dental assistant scaling should be limited to patients who are periodontally healthy or have mild, localized gingivitis. Patients with more advanced disease should receive care from a licensed hygienist or dentist. 3. Mandatory referral triggers The law should require referral to a hygienist or dentist when warning signs are present, such as excessive bleeding, deep gum pockets, heavy calculus, or suspected bone loss. 4. Statewide standardized competency assessment Competency should be verified through a uniform, statewide assessment, not solely by office-based sign-off, to ensure consistent standards across Virginia. Registered dental hygienists are licensed prevention specialists whose education centers on periodontal disease detection, risk assessment, and prevention planning. Expanding access should not unintentionally dilute or replace this expertise. If the General Assembly’s goal is to improve access, there are additional evidence-based pathways to consider, including expanding hygienist autonomy in underserved settings, increasing Medicaid participation and reimbursement, offering loan repayment incentives for rural practice, strengthening school-based and mobile dental programs, and exploring advanced practice dental hygiene models similar to nurse practitioners in medicine. Access and safety are not opposing values. With appropriate guardrails, Virginia can improve access while maintaining high standards of care and protecting patients. Thank you for your consideration.

I am a Virginia oral health care provider with a Master’s degree in public health. I respectfully oppose this bill Nearly 25 percent of Virginians will be age 60 or older by 2030, and and research shows 70% of adults 60+ have some form of gum disease; one of the fastest-growing and most medically vulnerable populations in the Commonwealth. In long-term care, Medicaid covers roughly two-thirds of residents. Participation levels in Medicaid further illustrate the problem: while about 2,000 dentists are in the program, only about 27 percent actually treat patients, 103 of Virginia’s 133 localities are designated as Dental Health Professional Shortage Areas, and eight localities have zero full-time equivalent dentists, according to HRSA. This bill will NOT solve shortages in communities without dentists. If there is no dentist physically practicing in a locality, hygienists and assistants cannot be employed there. Creating additional assistant-level roles does not place providers in these underserved areas; We already added —Dental Assistant II — yet there are only 46 currently practicing statewide. Evidence from other states shows similar outcomes. In Kansas, where scaling assistants are permitted in 1995, only about 19 percent of dentists use them, primarily in metropolitan areas. NOT in Dental Health Professional Shortage Areas From a public health perspective, this model risks gaps in preventive care, does not solve our shortage and compromises patient safety. I respectfully urge the committee to oppose this bill.

Do not support these bills an assistant should not be able to scale teeth

Oppose scaling without license

No to assistants doing rdh job without full college degree

I oppose HB970 and SB178. I only want dental cleanings done by registered hygienists as they go through rigorous academic courses and certification exams to ensure they are capable of providing quality care. Allowing cleanings and other procedures to be done without that level of knowledge and experience poses a risk to myself and other dental patients.

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 Delegate Price, I am writing to you as a patient who is opposing this bill for it being a substandard of care. From a patient’s perspective, dental hygiene is not simply a cleaning. It is the foundation of oral health. Proper evaluation of the gums, early detection of disease, and individualized preventive care are what help patients avoid tooth loss and expensive, invasive procedures. I am very concerned that this bill lowers the standard of care by allowing individuals without full, accredited dental hygiene education to provide services that directly affect patient health. As a patient, I want to know that the person assessing my oral health and identifying disease has the specialized education and clinical training necessary to do so safely and accurately. This bill does not improve access for patients. It puts patient safety at risk by weakening professional standards in a field that requires advanced training and clinical judgment. Sincerely,
 A concerned patient, Tatiana Borisyuk

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

While I was in school undergoing my 3000 hours of education and training, I struggled with one instrument in particular. I would pass my competencies using the instrument and then every time I had to actually use it on a patient, I did not feel confident. It was not until 2 weeks prior to graduation from my CODA accredited program that I had an instructor demonstrate the instrumentation perfectly to me, and it finally clicked. Every hour of education that dental hygienists receive is imperative to their career. Therefore, 120 hours of on the job training will NEVER be enough. Please do not support these bills. If you wouldn’t want a non-licensed individual working in your mouth, then oppose these bills so you AND others don’t suffer. In a world where disease rates are already so high, let’s not make them any worse, please!

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.

Regarding HB970 and SB178. Both of these bills will result in a decline in quality of care and are not in the best interest of any patient visiting a dental office. The training is not adequate and dental assistants already have an extensive list of responsibilities in their work day. As a dental hygienist myself, I’m aware that sub-gingival scaling is required on most patients. Who will perform this on the patients treated by assistants? Who will perform periodontal charting? Medical history review? Oral cancer screenings? Nutritional counseling? Doctors do not have the time during their exam, so most likely more patients will develop periodontitis, when it could have been prevented. Please consider how detrimental this will be to our patients, and navigate the provider shortage in a way that will truly benefit them without taking shortcuts.

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.

As a registered dental hygienist with over 13 years of clinical experience, I strongly oppose the proposal to allow oral preventive assistants to perform supragingival scaling in the Commonwealth of Virginia. I cannot imagine how permitting individuals with only a brief “crash course” in scaling teeth will meaningfully address the challenges currently facing the dental profession. Just yesterday, I provided care for over 20 patients( both children and adults) and not a single one would have qualified for an “above-the-gumline only” dental cleaning. In virtually every case, there was subgingival calculus present. Detection of calculus is not a visual skill alone. It requires tactile exploration below the gingival margin, supported by dental radiographs, to accurately assess the presence and severity of deposits. Limiting care to supragingival scaling ignores the reality of oral disease and systemic disease progression and creates a false sense of treatment completion for patients who still harbor active periodontal concerns. The current shortage of dental hygienists is not caused by overly rigorous education or licensure requirements. Rather, it is driven by widespread burnout, repetitive-use injuries, and workforce issues. Dental hygienists are unable to practice independently, and many dentists are unwilling or unable to meet fair wage expectations due to low insurance reimbursement rates and pressure to justify salaries through production metrics. Lowering the standard of care does not resolve these underlying problems. It risks patient safety, compromises quality, and devalues the extensive education and clinical training required to competently assess and treat periodontal disease. Introducing a lesser-trained provider to perform scaling does not improve access…it simply shifts risk onto patients. Virginia’s residents deserve preventive dental care that meets current standards and prioritizes long-term oral health outcomes. I urge you to reconsider this proposal and instead focus on solutions that support retention, fair compensation, and sustainable working conditions for licensed dental hygienists.

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

I am writing to firmly oppose HB 970, which would permit dental assistants to perform supragingival scaling with hand and ultrasonic instruments after on-the-job training. While the goal of improving access and efficiency in dental practices is understandable, allowing individuals without formal periodontal and instrumentation education to provide these services presents serious clinical, ethical, and regulatory concerns. From a clinical standpoint, a prophylaxis is not limited to “above the gumline” cleaning. It is a comprehensive procedure that requires assessment and instrumentation of the entire tooth structure, including areas that transition to subgingival surfaces. Separating supragingival scaling from a complete prophylaxis risks leaving etiologic factors in place, contributing to the progression of periodontal disease. It also creates a dangerous gray area where incomplete or fragmentary services may be perceived or billed as comprehensive care, raising legitimate concerns about potential fraud or misrepresentation of procedures. Dental assistants, while vital members of the dental team, do not receive the depth of education in periodontal disease, instrumentation, and patient assessment that is required of dental hygienists. These competencies cannot be reliably developed through a brief or “weekend” course or informal on-the-job training. Dental hygienists complete formal, accredited programs with extensive didactic and clinical hours in oral pathology, periodontology, instrumentation, radiography, and medical risk assessment before ever being allowed to treat patients independently. To perform even supragingival scaling legally and safely, hygienists must pass a national written examination, a standardized clinical examination, and a jurisprudence examination. These requirements exist to protect the public by ensuring that providers have demonstrated competence in both theory and practice, as well as an understanding of the legal and ethical framework governing care. If Virginia begins to allow on-the-job–trained personnel to perform core components of dental hygiene care without equivalent education and assessment, it effectively devalues the profession of dental hygiene and lowers the standard of care for patients. The same public safety issues raised with HB 1036 apply here: periodontal disease is already significantly underdiagnosed and undertreated. Allowing individuals without comprehensive training in disease etiology, risk factors, and instrumentation to provide scaling services increases the likelihood of missed or mismanaged disease, which ultimately leads to higher costs, tooth loss, and systemic health implications for patients. A more responsible approach to workforce challenges would be to fully utilize and, where appropriate, expand the scope and reach of licensed dental hygienists rather than delegating core hygiene functions to less-prepared team members. For these reasons, I respectfully urge you to oppose HB 970 and to prioritize policies that maintain strong educational and competency standards for those providing periodontal and preventive care to the public. Respectfully submitted, Dr. Joy Void-Holmes, DHS, BSDH, RDH, FADHA, AADH

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.

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 have written multiple letters to legislative members expressing my deep concerns for patient safety under this dangerous bill. I maintain my concerns, and am disappointed that patient safety could even be thought of as secondary to dental office profits. I ask that you do the right thing, and vote NO on HB970. Assistants, front office staff, office managers, and dentists are vital roles in an office yet they are not trained in preventative care. It is irresponsible to suggest an assistant can be on-the-job trained to perform tasks that require over 2 years of structured training for college educated hygienists to do. This is not about expanding access to care due to a “shortage”… this is about being able to treat patients as a number, and watering down educational standards. It’s deeply concerning and disheartening. I cannot understand how one can review all the evidence based information specialists and providers are writing, and still maintain that benefits outweigh risks. Please… do the right thing. For the future of Virginians, our families, our friends, our providers. Vote no. Thank you. Katarina Farmer, RDH

Hello all, I am not one to speak out usually, but this is insane. This will not improve access to care at all. The only thing this bill is going to do is ruin people’s lives. This will destroy families and harm so many!!!!! Do you really think dental assistants are going to work for the same hourly pay and do an hygienist job? The answer is no. Why would they??? They have watched hygienist make more and it because a hygienist DOES MORE! You can become a dental assistant at any local community college (8) or you can just be trained on the job. Also, if hygienist aren’t working in this state making the money they do…… that is less state tax dollars…… I can’t stress how important it is that we don’t pass this bill. People have worked hard for their RDH title and it is cruel to try and take that away. If it wasn’t for RDH’s we’d all be walking around with dentures if we were lucky. You may think Virginia will benefit from this…. It won’t all that is going to happen is everyone with a dental hygiene license is just going to move out of state and then the assistants you have left aren’t going to clean any teeth. An RDH spends more time training in a day than an assistant learns in 8 weeks. I truly don’t understand this blatant attack on hard working citizens of this nation. This bill is appalling and those who elevated this idea to this point…. You all should be embarrassed of yourselves. I am sorry that it seemed like I’m attacking whomever it reading this, I am never like this about things, but this is just insane. May God bless you and know I am praying that this goes well. I just ask that you think about this. Trying to push out RDH’s means loosing higher income people who are supporting their local economies and paying state taxes, dental assistants can not just learn to scale without hurting people and possibly killing someone. Also, do you really think in the society and culture we live in that anyone is going to do more work for less money???? No!!!!!! Dental assistants seem to mention how their workload is so heavy all the time… so I don’t think they are going to want to do more for less money.. May Gid bless you and I hope you all have a tok day.

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 970 (SB 178) which would allow dental assistants with “on-the-job” training to perform dental hygiene services. Thank you for your time and consideration. https://youtu.be/KRAMH92mDHA

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!

ar Delegate Price, My name is Darya Churikova, and I am writing to express my strong opposition to this bill. As an immigrant who grew up in a country where preventive dental care and dental hygiene were not available until the mid-2000s, I personally experienced the long-term consequences of the lack of prevention. Even with insurance in the United States, I have spent more than $10,000 on dental treatment. The emotional, physical, and financial impact of preventable dental disease is what led me to choose my career in preventive oral health as a registered dental hygienist. Dental hygiene is not “just cleaning teeth.” It is a licensed healthcare profession that requires a CODA-accredited education because we are trained to recognize risk factors, assess oral and systemic conditions, diagnose and treat periodontal disease, and determine appropriate care based on evidence and clinical judgment. Periodontal disease is complex, multifactorial, and requires specialized education and experience to manage properly. As a currently practicing registered dental hygienist, I have also treated many patients who previously received non-surgical periodontal therapy performed by dentists and were referred afterward due to continued disease progression. Unfortunately, in many of these cases, I did not observe improved outcomes, and several patients ultimately required periodontal surgery. This further demonstrates that periodontal care is a specialty that should be delivered by properly trained dental hygiene professionals. This bill will not solve the so-called dental hygiene shortage. Instead, it risks lowering the standard of care and placing patients at greater risk. Expanding pathways that bypass accredited dental hygiene education will create serious problems for patient safety and public health. Thank you for your time and consideration. Sincerely, Darya Churikova, RDH Registered Dental Hygienist

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!

As a licensed dental hygienist with 26 years in clinical practice & 7 years in education, I’m writing to oppose HB 970 (SB178) which is promoted as a solution to a “dental hygiene shortage” & way to increase access to care. My experience in clinical practice & education leads me to believe these measures may worsen the problem, not improve it. I am most concerned about patient safety & clinical outcomes when preventive services are performed by individuals who do not have the education & training required of licensed dental hygienists.

 Insufficient training increases the risk of tissue trauma, missed disease, progression of periodontal conditions, & potential impacts on overall health.

 Proponents have stated publicly that the intent is for assistants to clean above the gum & hygienists can return to clean below. This approach is neither efficient nor productive. When a hygienist performs subgingival scaling, supragingival scaling is completed at the same time. Having 2 providers treat the same teeth increases time, not improve efficiency or access.

 Proponents have also stated publicly that this bill is intended only for patients with healthy mouths, saying it would apply to individuals such as younger patients who “take good care of their oral health” and who do not have complex needs. National data does not support the assumption that adolescents and young adults represent a low-risk population. According to the CDC, AAP, & NIH: 57–58% of adolescents have experienced dental caries, 10–15% have untreated decay, 50–70% have gingivitis. Nearly 90% of young adults (ages 20–34) have experienced decay and, 7–15% already have gum disease. 

These age groups also show higher rates of vaping & tobacco use, frequent consumption of high-sugar beverages, & poor oral hygiene practice — factors that increase disease risk.

 These data demonstrate that gingival inflammation, decay, & early gum disease are common in adolescents & young adults. They require careful clinical assessment & skilled preventive care as they are not a low-risk population.
 
During my 26 years of clinical practice, it was extremely rare to see patients of any age without gingival inflammation/disease. A licensed dental hygienist is trained to recognize disease and provide education based on risk factors that contribute to the progression of disease. Anything less is unsafe and may be viewed as professional negligence. Access to care is critically important. However, solutions must strengthen the dental workforce while maintaining education standards, patient safety, and quality of care. Therefore, I respectfully urge you to oppose HB 970 (SB 282) and to uphold policies that prioritize patient safety, professional accountability, and the highest standards of care for Virginians. As you consider your vote on HB 970 (SB 178), I respectfully encourage you to reflect on this question: Would you prefer YOUR dental hygiene care to be provided by an on-the-job–trained assistant without standardized education, or by a licensed dental hygienist who has completed an accredited program & demonstrated clinical competency? Thank you for your service and consideration. CDC: https://www.cdc.gov/nchs/products/databriefs/db191.htm https://www.cdc.gov/oral-health/index.html American Academy of Pediatric Dentistry: https://www.aapd.org/.../policies.../bp_adoleshealth.pdf... National Institute of Health: https://www.nidcr.nih.gov/.../dat.../dental-caries/adults...

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.

I am a licensed dental hygienist and I am writing to sincerely ask you to oppose HB 970. I recognize this proposed was often discussed as workforce or access solutions. However, both would have allowed preventive clinical procedures to be performed without the level of education and supervised training required of licensed dental hygienists. Scaling and periodontal therapy are not merely technical skills. They require comprehensive assessment, radiographic interpretation, medical risk evaluation, and constant clinical judgment about when care is safe to provide. Virginia’s licensure framework exists so patients can trust that the person treating them has met uniform and rigorous preparation. 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 am writing to you as a concerned patient to voice my strong opposition to bill. I VALUE the specialized high-quality care I receive from my dental hygienist. I believe that lowering the educational and qualifications standard is the wrong way to address staffing needs . As a patient I deserve to be treated by a professional who has meet rigorous state standard and I am worried that this bill would let to a decline in the quality of oral healthcare provider in our community

Dear Delegate Price, I am writing to you as a licensed dental hygienist with over 50 years of clinical experience and a bachelor’s level education that required over 3,000 hours of formal training. I am urging (actually I am begging) you to vote NO on HB970 or failing that, is there any way that you would offer an amendment to it?  I can assure you that NO dental hygienist is willing to risk our own personal liability to supervise or train such an assistant in substandard care, nor should the assistants be permitted to use a high powered ultrasonic scaler.  Is there any way that you could:  place a sunset clause of three years on this bill; strike any provisions that allow dental hygienists to train or supervise these individuals; remove the authorization for ultrasonic instrumentation; and remove the APA exemption. This bill does not solve a workforce problem—it lowers the standard of care for Virginians and places patients at unnecessary risk.  I do not want my parents, children, grandchildren, friends or YOU and your loved ones to be treated in this way.  This bill WILL CAUSE HARM. HB970 allows unregulated and unlicensed dental assistants to perform scaling of teeth after only 120 hours of on-the-job training. This task is irreversible and invasive. Gingival (gum) tissues and tooth enamel and dentin does not regenerate when removed improperly, and damage caused by poorly trained providers is permanent. To suggest that 120 hours is remotely comparable to a college or university-based dental hygiene education fundamentally misunderstands the complexity and risk of this procedure. Compounding this concern is the reality that Virginia does not require licensure, registration, background checks, or identity verification to become a dental assistant. An individual can walk in off the street and be hired. These bills would then permit such individuals—unlicensed and unregulated—to work with blood, provide invasive procedures, and impact patient safety in a licensed healthcare profession. For comparison, cosmetologists in Virginia must complete more than 1,500 hours of training and hold a license simply to cut hair. Yet this legislation allows individuals with a fraction of that training—and no licensure—to perform oral procedures on patients. That is indefensible. As clinicians, we take an oath to do no harm. This bill violates that principle. This bill also expose dentists—and the Commonwealth of Virginia—to significant liability. Allowing unlicensed, unregulated individuals to perform procedures that can result in malfeasance creates expansive legal and ethical risk for the state. I am not asking you to vote NO out of fear or convenience but please vote NO to protect the citizens of Virginia. As a healthcare professional, and a Virginian, I appeal to you for higher standards for patient safety, professional accountability, and public health. Thank you for your service

As a patient & licensed practicing dental hygienist I strongly OPPOSE HB970. 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 and healthcare in general - 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 an assistant who was trained on the job by a "fixer" to provide my dental hygiene care, nor do I want this individual to provide care to any of my family, friends or patients or YOU! I respectfully ask that you OPPOSE HB970.

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.

House Bill 970 raises serious public safety concerns. Scaling is not a simple task — it requires thorough education, clinical judgment, and the ability to assess periodontal health. Registered Dental Hygienists complete extensive training and perform comprehensive assessments prior to beginning any scaling procedure, including reviewing medical history, evaluating periodontal status, assessing tissue health, and determining the appropriate course of care. Bacteria do not stop at the gumline, and adult prophylaxis includes scaling both above and below the gumline. Allowing dental assistants to scale above the gumline ignores the biology of periodontal disease and risks incomplete or inappropriate treatment. An RDH would still need to evaluate the patient and complete necessary subgingival care, creating duplication rather than meaningful access solutions. Improving access to care is essential — but lowering standards and fragmenting treatment is not the answer. Patient safety and quality of care must remain the priority.

As a concerned patient and parent. I oppose this legislation. I have watched my daughter who has been a registered dental hygienist for over 40 years, has a Masters degree and has been an educator for over 25 years have to defend her education/credentials time and time again. Why does lowering standards for dental care keep rearing its ugly head? There is no time that OJT for dental assistants is an acceptable option period. Please oppose this legislation.

My name is Cynthia and I am a licensed dental hygienist and I am writing to express my formal opposition to the bills HB 970 and SB 178 As a dental healthcare professional, my primary concern is the welfare of my patients. I believe these bills, as currently proposed, would significantly lower the established standard of care for our patients. By devaluing the rigorous educational and clinical requirements of the dental hygiene profession, these measures risk compromising patient safety and the quality of essential preventative oral healthcare. I urge you to vote NO on these bills to protect the health of our community and uphold the integrity of the dental hygienist profession. Thank you for your time and for your commitment.

As an RDH of 10 years, I STRONGLY oppose both of these bills. The passing of these bills is unethical, supervised neglect. This is not the solution to the dental hygiene shortage that we are currently facing. The passing of these bills will do nothing but lower the standard of care and create larger issues to come. Our oral health is directly linked to our entire body. Supragingival scaling alone is not adequate to maintain proper oral health and may contribute to delayed diagnosis of periodontal disease. It is incredibly frustrating and disheartening that these bills are even being considered. Please vote no to both of these bills.

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 am in strong opposition of HB 970 and HB 1036. While HB 970 and HB 1036 are being presented as workforce and access-to-care solutions, we must ask a fundamental question: When will we stop prioritizing money over patient health, safety, and educational standards? Imagine being treated by a nurse or doctor who was not trained according to current standards and they provided incomplete care that resulted in misdiagnosis and illness. Effectively this is what these bills propose for preventive dental care for Virginians. Dental hygienists complete two years of prerequisite education followed by two years in a rigorous, Commission on Dental Accreditation–accredited dental hygiene program. We complete over 3,000 hours of didactic and supervised clinical education and must pass national and clinical licensure examinations. This depth of training is essential because dental hygiene is not simply “cleaning teeth.” It demands a thorough assessment of gum and bone health, early recognition and staging of disease, an understanding of how medical conditions like diabetes and cardiovascular disease alter risk and healing, anticipation of potential complications, and sound clinical decision-making about whether it is appropriate to move forward with treatment. HB 970 would allow Dental Assistant I and II personnel to perform incomplete scaling procedures after only 120 hours of training on a mannequin or limited human experience. That is not comparable education. It is not sufficient preparation. And it creates a dangerous precedent of incomplete care putting the most vulnerable patients at risk. Leaving tartar and biofilm below the gumline allows periodontal disease to worsen, leading to chronic inflammation and the need for more invasive and costly treatment. Appointments become more complex, preventive care is strained, and workforce shortages are not resolved; only delayed disease and higher long-term costs result. Regarding HB 1036: Internationally trained dentists are highly educated professionals, and this is not a criticism of their abilities. However, the bill does not create a pathway to practice dentistry in Virginia. Instead, it permits entry into a different licensed profession, dental hygiene, without requiring accredited education specific to that field or ensuring standardized licensure safeguards. Unlike HB 1026, it lacks critical protections, and those omissions matter. Both HB 970 and HB 1036 lower educational and licensure standards under the guise of workforce solutions. In reality, they shift risk to patients while increasing profitability for dental practices. Organized dentistry is presenting these proposals as access solutions, but access without standards is not equity, it is compromised care. Dental hygienists have repeatedly offered constructive solutions to workforce challenges: Improving benefits for hygienists, increasing insurance reimbursement rates, reducing unnecessary supervision barriers so hygienists can practice at the top of their scope and reach more patients, and strengthening retention strategies. Above are real solutions that expand access without compromising safety. I respectfully ask the Delegates: When will we begin prioritizing patient protection over profit? When will we protect educational standards instead of weakening them? For the health, safety, and well-being of Virginians, I urge you to vote NO on HB 970 and HB 1036.

Healthcare decisions should not be influenced by money, political donations, or business pressures. Patients deserve transparency and the highest level of protection, not policies that risk compromising care for financial gain. For these reasons, I respectfully ask you to vote NO on HB970. This is awful. Shame on the Dentists promoting this dangerous bill.

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

Dental hygienists are required to complete 2 years of prerequisites be for entering a competitive dental hygiene program. To allow a dental assistant with very little training to do the same work is a joke. The lawyers will have a heyday with the amount of patients suing over missed periodontal disease diagnosis because they are not trained at all.

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.

I urge you to vote NO on HB970. As a licensed dental hygienist, a certified dental assistant, a former college educator for both dental assisting and dental hygiene programs, and someone who began my career as an on-the-job–trained dental assistant before returning to college for formal education, I can speak from direct experience. The education, scope, and clinical preparation for dental assistants and dental hygienists are not the same. The job responsibilities differ significantly. The dental materials, instrumentation, clinical decision-making, and patient assessment training required in dental hygiene programs are far more extensive, than what this bill requires, and are grounded in standardized, accredited curricula. These distinctions exist to protect patient safety and ensure consistent standards of care. Relying on individual dentists to provide training for a “preventative dental assistant” certification creates inconsistency across the Commonwealth. Not every dentist has the time or teaching ability to provide comprehensive clinical education. This would inevitably result in assistants with widely varying levels of preparation, placing patients at risk and undermining established professional standards. For the protection of patients and the integrity of dental care in Virginia, I urge you to oppose HB970.

I strongly OPPOSE bills HB970 and SB178. Lowering the standard of care does not increase access to care and these bills significantly lower the standard of care for the public. The concept of training an assistant in 120 hours with NO STANDARD TESTING of competency is negligent to the oath of “do no harm”. A hair stylist has 1500 hours and takes a licensing test. A nail tech has 1000 hours and takes a licensing test. Even a lash tech has to have 600 hours. I had to have 200 hours for my yoga certification and that doesn’t include sharp instruments in the mouths of the public. 120 hours is laughably negligent. How can dental health matter less?? Especially since two years ago the VDHA asked that the board of dentistry require assistants to have infection control training and they didn’t enact it. How can you not require them to be certified infection control but want to teach them to scale?? Dental hygienists have an associates of science before applying into dental hygiene program. They have extensive competencies to pass with instrumentation and months of practicing on each other prior to learning on patients. This bill promotes these assistants using ultrasonic scalers when in dental hygiene school we couldn’t use them on patients until our second semester of clinical care. Most importantly dentists do NOT receive the extensive training in dental hygiene preventative care. The dental hygiene students actually oversee then dental students in clinic when they learn and check behind them. Dental students do NOT take clinical board for dental hygiene skills. So how can they teach it? The importance of the dental hygienist thoroughly examining all tissues for disease and thoroughly cleaning subgingival is it removes bacteria and interrupts the disease process. EVERY patient needs this. If not it promotes the propagation of virulent bacteria which increases risks for many diseases, cancers , diabetes, and especially periodontal disease. In dentistry we call this supervised neglect. The real issue delta dental. They haven’t raised their rates in 15 years. So instead of seeking better reimbursement, they opt to cut costs by creating a cheap substitute and put public health on jeopardy.

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 curious to know if you like your teeth? Do you like to eat? Are you interested in maintaining a healthy mouth? If you answer yes, then it seems like you better oppose this bill. If this bill is pass, we will see an alarming rate of poor oral health in the state of VA. Please don’t make it a reality so that dentists can pocket more money.

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

I am a Registered Dental Hygienist and I strongly oppose these bills for the safety and livelihood of every patient. These bills are not going to fix an “access to care” issue or “hygiene shortage.” These will only do harm as 120 hours or some joke of on the job certification would not give anyone even an inkling of knowledge of what we as providers do in a day. I spent countless days/weeks in hygiene school learning all the parts of every instrument, how to properly hold them, adapt them to the teeth, ensure adequate calculus and plaque removal. I had to pass rigorous skill evaluations on each one before even beginning to move on to another. Those that couldn’t pass an evaluation were unfortunately dismissed from the program- because they simply weren’t good enough. I spent years learning the periodontal disease process, all the bacteria involved, microbiology, histology, embryology, pathology, nutrition, etc, and how it is all involved. I know about countless diseases and health conditions, different medications and their contraindications. Why did I and every other RDH have to go through all that just for people that don’t know a thing about our profession to diminish what we do in the blink is an eye? I’ve seen hundreds of patients in the past few years and I can confirm as a fact that about 95-98% of them have some type of periodontal disease (gingivitis or periodontitis). And a lot of these patients are in a private practice setting in which they’ve been seeing a dentist regularly and no one has said a word about their disease status. It’s these patients who you would allow an on the job trained dental assistant to scale “above the gumline” because they are “healthy.” Scary. Just scary. I care deeply about and will advocate for every single patient I encounter whilst working. I have a standard of care and ethical obligation to give the best care possible to my patients. I thoroughly go over medical history, do blood pressure screenings, oral cancer screenings, nutrition counseling, periodontal charting, specifically tailored oral hygiene instruction, inform about disease status, refer to necessary specialists, communicate with other members of patients’ care team, ultrasonic and hand scale, disclose, polish, floss. I never just “clean teeth.” Dental hygiene care is so much more than “cleaning teeth” and these bills are a personal attack on our profession. Money hungry DSOs and insurance cooperations want to further line their pickets whilst the little man suffers. I do not and will not stand for this. Open more dental hygiene schools, provide better working conditions and benefits, and you will see more registered dental hygienists in the workforce. This is not the answer. There is no such thing as a supragingival cleaning, that is just brushing your teeth.

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.

Only registered dental hygienist should be able to provide such services

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.

If access to care was an issue, give the hygienist more autonomy as they are trained professionals with their own licenses. This is clearly an agenda, push by dentist so that they can have assistance do the work of a hygienist for a half to 1/4 of the pay. In no way shape or form is this beneficial for the public. This is clearly a disguised agenda in order to line the pockets of dentist who can be heard complaining about the pay rate for a hygienist… often while disregarding how much it cost to go to dental hygiene school and the amount of time it takes to obtain and develop these crucial skills.

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.

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

I oppose HB970 and SB178. I am a concerned dental patient and want a RDH providing my care.

I strongly oppose this bill. Allowing dental assistants to be trained to scale supragingivally is UNETHICAL. Proper hygiene instrumentation to remove calculus and biofilm REQUIRES subgingival scaling(below the gumline)! This also requires precise technical instrumentation. Not removing plaque and biofilm subginingivally does patient harm, setting the stage for disease and neglect. Passing this bill is a step backwards in healthcare. Taking the all mighty dollar into consideration over ethical patient care is appalling. I have worked in every aspect of dental and before entering dental hygiene school I managed an office for 7 years. I’ve watched family dentistry go downhill because of corporate greed, running patients in and out like cattle. This bill aims to add to that perspective of numbers not people. Would you want someone in your mouth that hasn’t been licensed, passed board exams, or taken anatomy, pathology, microbiology, chemistry, pharmacology etc? my point is, hygienists are highly trained, highly educated individuals in their field. There is not a shortage of hygienists, there is a shortage of value and respect for the profession and for what the hygienist brings to dental practice!

I strongly oppose this bill. We need licensed professionals providing dental care. I do not approve of cutting corners in the interest of business endeavors. We should not put patients in harm’s way.

I am a concerned dental patient and I oppose HB970 and SB178. I want a RDH 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!!

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!!!

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 (Adult Prohylaxis) 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 Registered 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 to you, your family, your loved ones and friends than good and more disease will go undiagnosed. 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. 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 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 that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your service and consideration. Sincerely, Kacey Knox RDH

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 licensed dental hygienist in Virginia, I strongly oppose this bill. I completed four years of extensive schooling to earn my bachelor’s degree in dental hygiene, passed both national and state board examinations, and underwent rigorous clinical training with countless exams to demonstrate my competence and ability to provide safe, high-quality care. Creating the Oral Preventive Assistant role and lowering licensure standards for practicing dental hygiene diminishes the value of this education and training, undermines the scope of our profession, and ultimately does a disservice to patients. These changes put patient safety and quality of care at risk, and I urge legislators to protect the public and uphold the professional standards of dental hygiene by rejecting these bills.

Please vote NO for the HB970 to allow dental assistant to Supra gingival scale. I have been a registered dental hygienist for 30 plus years. Every patient I see I go under the gums to remove plaque and biofilm before it can turn into tartar/calculus. I have worked as a contractor for the military and assists were trained in short course to do above gumline visits. Long term a healthy patient turns into an unhealthy patient. Correlation between to heart disease inflammation, diabetes, dementia, and preterm birth are some effect that can happen. Oral health leads to over all health . This is by no means a good idea

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

As anyone who has been to the dentist knows, dental hygienists provide 90% of the services there. Dentist barely looks at you. Please don’t let people without experience and the education needed to contextualize what they see be our main dental health providers. Please don’t make dentistry an even worse experience for the consumer.

Allowing minimally trained dental assistants the ability to scale teeth is putting patient’s health at risk. Registered dental hygienists undergo years of didactic and clinical training which helps us to custom tailor our patient’s treatment in an effort to have the best outcome (saving them time in the long-run and money). Untrained dental assistants (with good intentions) do not have the skills it takes to effectively remove mineralized deposits of bacteria below a patient's gum line. If these calculus deposits are not effectively removed, a patients periodontal status is likely to continue to decline and and an increase in chair time, discomfort, and expense will be incurred on the patient when the patient is finally in the hands of a qualified professional.

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.

Please do jot allow dental negligence! Dental Hygienist go to college for a reason. Dental assistants should not be allowed to scale teeth. By allowing them to scale supra calculus you are allowing disease to be missed!

As a newly graduated dental hygienist in Virginia, I feel compelled to speak on this proposed legislation. I have just completed two very rigorous years in an accredited dental hygiene program, earning the education and clinical experience required to become a licensed and registered dental professional. Prior to hygiene school, I worked as a dental assistant — I’ve been part of the dental profession for nearly six years. I have tremendous respect for dental assistants. They are essential members of the dental team, and I truly appreciate everything they do for both patients and providers. However, this proposal feels like a disservice not only to hygienists who have invested significant time, effort, and financial resources into their education, but also to assistants themselves by placing yet another responsibility on their already full workload. Dental hygiene education goes far beyond basic on-the-job training. We receive extensive instruction in patient assessment, complex medical conditions, pharmacology, infection control, and the technical skills required to safely remove bacterial deposits both above and below the gumline using specialized instruments. This level of training is designed specifically to protect patient health and ensure high standards of care. If individuals want to practice dental hygiene, there is already a clear educational pathway — just as there is for becoming a dentist or any other licensed healthcare professional. Substituting that education with limited training risks lowering the standard of care and sends a discouraging message to new graduates like myself who entered this profession committed to excellence. I encourage you to consider this not only from a legislative standpoint but from the perspective of a patient. Would you feel equally confident receiving care from someone with roughly 120 hours of training versus someone with over 3,000 hours of education and supervised clinical experience? Please carefully consider the potential impact on patient safety, professional standards, and the future of the dental workforce before moving forward with this proposal.

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.

As a patient I oppose HB970. I will only consent to a licensed, degree-holding Registered Dental Hygienist to provide my preventive dental care. There is a reason a degree is required and 120 training hours is not a substitute, it’s an insult. This bill puts my health at risk and is a gross regression in dental care and quite frankly sugar-coated negligence. As a dental assistant of 14 years now hygienist for 2 years I oppose Hb970. Fourteen years as an assistant in no way prepared me to provide the level of care I now provide as a dental hygienist. Scaling above the gum line does nothing for the patient except give them the illusion they had a cleaning and charge them for a job that wasn’t done. It perpetuates disease. Periodontal disease will flourish under the gums where the aggressive bacteria that cause it thrive. Oral cancer screenings will go undone, and early cancerous lesions will go undetected at a time when they are the most treatable. Oral hygiene instructions which arm patients with the knowledge of how to care for their oral health at home will be inadequate and incomplete. Other medical conditions will spike and worsen with the increase in gum disease— we all now know the same bacteria has been linked to heart disease, stroke, certain cancers, Parkinson’s, rheumatoid arthritis, Alzheimer’s, and diabetes to name a few. As a mother, daughter, sister, and friend, I oppose this bill. Lest we forget, mostly importantly, every patient in the dental chair is someone’s loved one. Please consider whether you would want an unlicensed assistant with 120 hours under their belt working on your medically complex elderly parent, special needs cousin, young child at their first dental appointment, anxious spouse or even yourself. Or would you demand a registered dental hygienist with over 3000 hours of rigorous training and advanced education, a license, and a degree? I urge you to consider this when determining your stance on this bill.

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

This Bill should not be passed because it would lower standards of care for patients and requires more in depth training to deliver optimal care for patients.

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.

As a dual licensed individual, an RDA and RDH, I strongly oppose scaling assistants. This lowers the standards of care for patients. I've also worked extensively in pediatric settings, even for peds patients, I have scaled below the gumline to remove bacteria and tartar. Scaling above the gumline is not therapeutic and is also fraudulent when dealing with insurances.

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 HB970. I know what a true dental hygiene visit includes and I do not want someone with the limited training suggested to think they will provide my treatment. This is a terrible idea. You are putting me and all Virginians at risk.

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!

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 am writing as a concerned patient (not a dental hygienists) and Virginia resident to express my opposition to HB 970 and SB 178. I believe that maintaining rigorous educational standards for dental hygienists is essential to protecting public health and patient safety. Dental hygienists perform procedures that involve sharp instruments, soft tissue management, and close proximity to critical anatomical structures. Inadequate training or reduced educational requirements could increase the risk of injury, infection, misdiagnosis, or long-term harm. The oral cavity is closely connected to overall systemic health, including the brain and cardiovascular system, making proper knowledge and clinical judgment vital. Requiring comprehensive, college-level education ensures that dental hygienists are equipped with the scientific foundation, clinical competence, and ethical training necessary to provide safe, effective care. Weakening these standards may compromise patient trust and lead to preventable health complications. I respectfully urge you to prioritize patient safety and uphold strong educational requirements for dental hygiene professionals in Virginia.

I oppose SB 178 / HB 970 and SB 282 / HB 1036, which significantly lower the standards of care for preventive dental services. 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’m a concerned dental patient and I strongly oppose these bills.

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 a registered dental Hygienist employed at a military dental clinic. The military utilizes dental assistants as Dental techs because civilians are unable to go underway or deploy on a ship. These dental techs- on the job trained dental assistants are responsible for performing cleanings on patients/active duty military members. Once these patients get off of the ship or come back from a military base over seas, they have rampant gum disease. Majority of the time the damage is done and they have irreversible gum disease. The bill will allow dental assistants to clean above the gum. Majority of bacteria and calculus/tartar is below the gums. Majority of the gum disease I see happens due to neglect from people who are unqualified to perform dental cleanings. The same bills that Virginia dentists want to pass will have the same results but on our family and friends (the patients). I oppose of these bills because I see the irreversible harm it has already caused my military patients. If these bills are passed, the civilian sector will see the harm and neglect. They will think that you’re seeing a license practitioner but really the provider is someone who has no experience in the dental field and is “on the job trained”. The exams will be administered and passed by these dentists so that they can hire on these dental assistants to do a dental hygienists job. Foreign dentists are also trained to perform extractions, root canals, and fillings. They’re not trained to clean teeth/perform prophylaxis or do a Registered Dental Hygienists job. Therefore, these bills should not be passed and allow unqualified people to do a hygienists job. If these bills are passed, there will be no regulations or accountability. They need to take the same state and national board exams that a Registered Dental Hygienists completed to prove that they’re competent enough to work on patients. Someone who is on the job trained will not know the anatomy of the head, neck or mouth. Also, who will hold these dentists accountable when patients have irreversible Gum disease or undiagnosed oral Cancer? These two bills will take the dental profession backwards and not in a positive way for our patients.

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!!

Oppose HB970 and SB178 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 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. If helpful, I would welcome the opportunity to provide more information or connect you with dental hygiene professionals and educators who can explain what proper preparation for these procedures truly requires. Thank you for your service to our community and for considering my request.

I'm a Dental patient. I do not agree with this bill. I do not want to have a Dental assistant perform any treatment on me. They do not and will not have enough training to perform the duties a Dental Hygienist has. A Hygienist has far more education and hours in to clean my teeth and find diseases. I'm asking for your to OPPOSE this bill and HB1036 Respectfully, Theresa Groome

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

I oppose the bills HB970 and SB178. Allowing OPAs and individuals without CODA-accredited, U.S.-standard dental hygiene education to provide care is not a solution to workforce shortages or access challenges. These are risky shortcuts the public did not ask for. Introducing inadequately trained dental personnel to perform preventive services puts the public’s oral health at risk and threatens the integrity of the dental hygiene profession. We cannot allow unqualified individuals to become the norm or replace qualified, licensed dental hygienists.

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 am writing this as a dental hygienist of 15 years. Allowing minimally trained assistants would be a detriment to patient care and lead to increased disease occurrence. This bill has been pushed through with little to no input from the dental hygiene community despite repeated efforts to discuss this on multiple fronts.

I am writing to respectfully express my opposition to HB970. As a dental professional, I am deeply concerned about the potential impact this legislation could have on patient safety and the standard of care in Virginia. While I understand the intention may be to address workforce shortages and increase access to care, this bill lowers the educational and clinical standards currently required to perform procedures that directly affect a patient’s oral and overall health. With disregard to the true concerns in the workforce as fact checking why there is truly a shortage. Scaling and preventive dental procedures are not simply mechanical tasks. They require clinical judgment, assessment skills, and the ability to recognize signs of periodontal disease and other systemic health concerns. Licensed dental hygienists complete rigorous accredited education and clinical training to safely perform these services. Allowing individuals with significantly less formal education to provide similar procedures risks incomplete treatment, missed diagnoses, and long-term harm to patients. I am also concerned about the broader implications this bill may have on professional standards, patient trust, insurance billing clarity, and liability within dental practices. Rather than lowering training requirements, we should be investing in strengthening and supporting our existing dental workforce, improving retention, and expanding educational pathways for hygienists to increase access to care. Virginia patients deserve the highest standard of care. I respectfully urge you to reconsider HB970 and pursue solutions that protect both patient safety and professional integrity within dentistry. Thank you for your time and consideration.

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 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.

As a dental hygienist, I strongly oppose HB970. Passage of this bill undermines the entire dental hygiene profession. If you look at the dental hygiene curriculum and licensing process you will see it is a difficult curriculum and process with many hours of direct patient care. The passage of this bill jeopardizes the public’s safety and well being. A prophylaxis is seldom all supragingival or “above the gum line”. A typical schedule like mine today involved children who needed subgingival scaling, “below the gum line”. If this is not completed than a true “cleaning” is not being performed and the risk of infection increases. This is especially true for anyone who is prone to infections , such as someone with diabetes. The solution is being brought about by dentists who support this bill, not actual hygienists who do the job. I think more study should be conducted that involves active participation with hygienists to come to a solution that’s acceptable for everyone and places the public’s health and safety foremost. Thank you Debra Dycus RDH

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

I oppose allowing dental assistant to perform “above the gum” dental cleanings. To put things in graphic perspective- this is like going to Taco Bell, getting diarrhea and wiping the cheeks and not the crack. Gum disease starts UNDER the gingival tissue where pathogenic bacteria hides. It creates an inflammatory response that then dilates the blood vessels so white blood cells can attack said bacteria. Now that the gums are inflamed and more permeable this pathogenic bacteria will enter the blood stream where it will circulate throughout the whole body and may contribute to systemic conditions like heart disease, Alzheimer’s, strokes, erectile dysfunction, diabetes control, etc. Performing a “cleaning” takes specialized technique because doing it poorly can lead to a periodontal abscess, tooth loss or worse- death. Your tooth janitor does much more than scrape the Caesar salad from lunch off your teeth- and put up with entitlement. They have to review your medical history and medications as it can contribute to dental issues or vice versa. They have to perform an oral cancer screening to make sure all the fun you had in college when you got hpv doesn’t turn into something more serious as oral cancer has a 5 year life expectancy, we have to assess gum health and tooth health, perform your debridemebt in an efficient manner and lastly give your dentist a break down of all the findings- because they want to get back to their more lucrative appointment. This model of dentistry is not to establish increase access to care because of a hygienist - its profit increase, and production increase. This takes health care to chipotle assembly line. We hygienist are prevention specialists. Our goal is to keep patients healthy and what kind of business model do’s that serve when our assessments and procedures require time, and skills that have been well earned. We have sat through torturous hygiene school- because yes, tears were shed every day. If you think your hygienist gets on your ass for not flossing- can you imagine the OG instructors?! Failure is not an option. We have boards- written and didactic and those are not easy. And lastly we are required to maintain continuing education every year. We spend 2 + years learning how to clean teeth and your dentist gets- maybe a semester. We are much more qualified to scrub your pearly whites. Let’s also mention other factors like lack of increase from insurance reimbursements, increase in over head due to rising costs of materials and livable wages. This is an economy problem. And lastly we have turned dental care into la Burger King where everyone thinks they can have it their way- where you are onegoogle review from failure, where you have to provide health service, spa treatments, and an experience when you got ask of the same from the Castro working at the other end. If you want accessibility I provide the following solutions: 1- allow hygienist owned practices because claw can refer to a dentist 2- fund hygiene schools 3- allow hygienist to do Botox so we can increase dentist profit margins 4-include dental care in health insurance because your whole health starts in the mouth 5- stop corporations from buying dental practices. Respectfully a tooth cleaner that has referred patients out to be diagnosed with skin cancer, oral cancer, hashimotos, sleep apnea, high cholesterol, high blood pressure, speech issues, cervical instability, EDS, lichen planus, diabetes and a blood disorder.

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

I want dental assistants to be licensed and fully trained/educated in dental care.

I do not want to be treated by an unlicensed individual for my dental 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

This is concerning dental assistants being trained in-office, & being able to practice dental hygiene. First of all, I am a Registered Dental Hygienist of 35 years. My college education provided me with a background of dental requirements that you could not receive in the office. That gave me a start for my hygiene career of providing the best treatment I could possibly give my patients. Yes, I have learned so much from the dentists that I have worked for & the patients I have treated over the years. This would be a travesty to let dental assistants be trained in the office, after all the previous hygienists have worked their behinds off in school to make top grades & then go on to become successful dental hygienists. I certainly hope that this law is defeated. Dental hygiene will lose the respect that it has gained over the many years that educated hygienists have provided & earned! Thank you for your time!

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.

As someone who cares deeply about the health and well-being of our communities, I am concerned about the potential decline in patients’ oral health and overall health if this legislation moves forward. Expanding care models without ensuring the highest standards of education, training, and clinical competency puts patients at risk. Oral health is directly connected to overall systemic health. Conditions such as periodontal disease have well-established links to heart disease, diabetes, respiratory illness, and other serious medical conditions. When providers lack sufficient knowledge, education, and comprehensive clinical training, the risk of misdiagnosis, delayed treatment, and inadequate care increases — and patients ultimately suffer the consequences. Access to care is important, but it should never come at the expense of quality and safety. Virginia patients deserve providers who have the depth of education and clinical preparation necessary to diagnose complex conditions, manage complications, and protect overall health. I urge lawmakers to carefully reconsider their support for this bill and to prioritize patient safety and the long-term health of Virginians.

As a Registered Dental Hygienist, I strongly oppose these bills. This will only cause more issues especially to our patients.

I am writing to let my feelings be known about these 2 bills. As a periodontal patient I require 3 to 4 dental cleanings annually. I feel that these 2 proposed bills will not guarantee me the proper treatment that my situation requires. I do not want substandard care from someone who does not have the qualifications that a 4 year degree and/or a license provides. These hygienists have been through rigorous undergraduate classes ie. anatomy, pharmacology, chemistry, physiology among the few. Not to mention numerous clinical and rotation hours. Then on to written and clinical board exams to attain a BS degree and/ or license. College training is far and above anything that a person would get from “training” in a dentist’s office. I highly doubt a dentist has time to babysit these folks and oversee all of the aspects of treatment that patients require and deserve. Please DO NOT pass this bill. You will only be degrading dental health practices and I believe your constituents deserve better. I deserve better. Thank you for your time. Sincerely, Beatrice Moore

I’m writing in as a concerned patient. I know hygienists go through rigorous schooling to provide the care they do for patients. Having an assistant train on the job by a dentist (who probably doesn’t have the time to do this AND see patients) is completely lowering the standard of education and care for patients. It seems to me in this bill the dentist certifies the assistant to be able to clean? So they don’t have to take a board like the hygienists do? They can just train on the job, then they are given the go ahead to work on the general public? The makes ZERO sense. I don’t want to be a guinea pig someone to poke on who hasn’t passed a board or had proper training. This just seems like negligence waiting to happen. Virginians deserve better!

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

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 oppose both of these bills!

Circumventing long-established national standards for the practice of dental hygiene by permitting minimally trained scaling assistants to provide clinical services raises serious concerns regarding patient safety and quality of care. Other states, including Colorado, California, and Utah, have rejected similar legislative efforts after careful review of their potential impact. I encourage Virginia residents to advocate for their own health by seeking care from dental practices that employ licensed dental hygienists to perform scaling procedures. Additionally, I urge policymakers to carefully consider the public health implications of supporting measures that may compromise established standards of care. Patient safety and professional accountability must remain a priority in any legislative decision.

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.

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 have been an RDH for 27 years. I have watched many dentists push the limits on what assistants can legally do already and now you want to let them train assistants to do above the gum scaling? I’m telling you now, they will let them do below the gum just so they don’t have to hire and RDH and pay out more. On the job training is not enough for these assistants to know the correct techniques, instruments, and ways to remove the damaging tarter in patients mouth. You will end up with patients losing teeth, having more heart disease , and damage done to their mouth from cleanings by poorly trained assistants. You are risking the health of every person in the state. There is not a hygienist shortage, there is a shortage of dentists wanting to give decent pay and benefits. I also have seen some dental insurance companies discussing requiring RDH license numbers to be submitted with scaling/root planning and prophylactic cleanings since the same codes and charges will be used for them being done by a licensed RDH or a poorly trained assistant. The insurance companies will start not paying if it is not completed by an RDH!

I have been an RDH for 26 years and oppose bill HB 970. Dena Hygienists do so much more than “clean teeth”. We are oral health care providers. We spend years in school and are board certified to perform oral health care. We have taken classes on pharmacology, anatomy, oral and facial conditions, several health sciences along with our dental specific training. We understand the overall health and oral health connection. We diagnose and treat periodontal disease as well as gingivitis. We perform oral cancer screenings. We help diagnose oral health anomalies, developmental defects and so much more. The public deserves proper dental care and that only comes with licensed and properly educated individuals.

I would like to oppose and express my disagreement with the proposal which would allow dental assistants to do dental scaling and prophylaxis duties.

RDH’s are like the RN’s of teeth! Having a trained dental assistant without any schooling on cleaning a patients teeth is a disaster waiting to happen. Hygienist are trained to clean thoroughly and safely below the gum line to prevent periodontal DISEASE! As a DA myself, this is putting SO MANY patients at risk for periodontal disease, also at a higher risk for heart disease and dementia/Alzheimer’s. Terribl, terrible idea.

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 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!

As a retired dental hygienist and a patient, I am appalled that this bill was even introduced. I strongly oppose HB 970. This bill legislates for future negative public health outcome because unregulated and untrained dental assistants will only scale above the gum line. All disease causing bacteria live under the gum and they will be left behind causing periodontal disease and tooth decay. Periodontal disease is highly linked to many systemic diseases such as heart disease, stroke, diabetes, Alzheimer's, different cancers, pregnancy complications, etc. The VDA did a very good job brain washing many stake holders and legislators, selling this bill as improving access to care. How shameful! If this bill will pass, it will promote neglect, not to mention insurance fraud. Fix the root cause: give dental hygienists AUTONOMY, our own board, also invest in dental hygiene education: open new dental hygiene programs and expand existing ones, and pay respectable salaries for faculty.

Please oppose these bills. They are a disservice to the oral health of patients by bypassing the education and clinical training required for dental hygienists to properly treat patients. Supra gingival scaling does not address gingivitis or periodontal disease and even healthy patients require sub gingival scaling. These bills are a danger to patients and are a serious threat to oral health by allowing loopholes in patient care by allowing unqualified dental providers to treat patients.

Please vote NO. As a customer that goes faithfully for cleanings, I want the highly trained and educated dental hygienists for cleaning. If Dentist need to improve office pay or benefits to retain hygienists they will benefit with more customers. Dental health is important Thank you

This has been a crisis in the making for 20 years. How have we not come to a more sensible solution? Instead of being proactive, we are now being reactive and trying to fix a problem while jeopardizing the health of our community. If this bill passes, you will have a public health crisis due to increase in oral disease they went undiagnosed. The proposed "preventative dental assistant" will not have the education to properly diagnose or treat the general population. 70% of our population suffers from some form of gingivitis or periodontal disease. This will put our community at risk, as the assistant will not be able to diagnose the patient's issues and assess their risk of disease. They will not have the background knowledge of instrumentation. Every instrument (scaler) has a purpose. Where will they get this knowledge? How will they know which instrument to use? Ultrasonic instrumentation is even more risky as there are medical contraindications such as pacemakers and respiratory disease. This type of instrumentation is more likely to cause damage to the enamel and soft tissue. How will they receive training for this type of instrumentation? It is very difficult to scale a patient's teeth supragingivally without touching the soft tissue or accessing the build up (calculus/tartar) below the gumline (subgingival). It's just inefficient & not effective from a clinical stand point. Who will be in charge of making sure the requirements are being met? How will you know that the denist is doing their part and being accountable? When will the dentist even have time to supervise and educate, as most are overwhelmed and busy with their own schedule. Will there be a clinical test they need to pass to show proficiency? Currently, the bill allows scaling under indirect supervision, the dentist does not need to be physically present. What if there is a medical emergency? Who is liable? Who will set the guidelines, protocols & procedure for this new role in dentistry? I am not aware of senators and representatives being knowledgeable and proficient in dentistry besides Senator Papillon (who is a dentist). If we leave it up to the dentist to train them, the ones that are willing to take on that liability, training quality will be inconsistent. Why are we not consulting the Board of Denistry? They should be setting the guidelines and protocols for this proposed new role. The board can set parameters to monitor consistency and competency. Let's think about solutions that actually would work for the best interest of the patients. We can open a new dental hygiene school, we can increase class size or make Virgina accessible to other hygienist by easy reciprocity guidelines. There are options that are not being discussed or addressed that will not impact the health of the public negatively. Think about your constituence and your family and put their well being first. This is a disaster in the making.

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.

Good evening, This proposed bill is blatant disrespect to my profession. This bill makes all of my hard work, the sleepless nights, the hours upon hours studying, the debt I went into, all the tests/certifications/licenses and more worth NOTHING. We would NEVER say that a CNA has the same abilities as a nurse so why would we say that a dental assistant has the same abilities as a hygienist. Not to mention the HARM you will be putting your residents of Virginia, if not yourself, when going to the dentist. There is a reason dental hygienists go through 4 years total of school consisting of 2 brutal years of hygiene school. If you don’t believe me, go to hygiene school. My guess is you would think very differently about this bill. Did you know that calculus left underneath the gingiva leads to heart disease and Alzheimer’s? Probably not. Well allowing dental assistants to scale or in your words “clean” above the gum would be missing that calculus BENEATH. This is neglect and abuse- especially since you KNOW this is what happens. Because the dentists themselves are not even trained well enough in dental hygiene like we (RDHs) are- thankfully the Dentists that I work for are wonderful, know our worth, and not greedy like the ones who proposed this bill— my dentists will tell you THEMSELVES that they are not as knowledgeable nor have the capabilities to “clean” teeth. Neither the dentist nor the assistant have our knowledge and capabilities to perform the duties of a dental hygienist. I urge you to TRUST and LISTEN TO the THOUSANDS of dental hygienists, patients, and even the non-greedy dentists that are opposing this horrifying bill. If you don’t choose to listen to me and these people, the result WILL be periodontal disease leading to teeth and bone loss, infection in the gums untreated that could lead to sepsis, patients not getting the care and education they deserve, and a bigger shortage issue from hygienists not wanting to continue their career or students no longer wanting to become one. Your choice— but choose wisely.

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 do not work in dental, but I have been educated by people who do. I am concerned about the lack of education these bills will allow "assistants" to have. The bare minimum certification course required to become an "assistant" pales in comparison to the 2-4 years of university level education that dental hygienists receive, which is concerning considering the "assistants" would be able to perform a large portion of the job qualified hygienists perform, including (to my knowledge) teeth cleanings with surgical-grade implements. It seems unthinkable to me that someone can take a 100- or 200-hour course online, receive what will very likely be minimal on-the-job training, then be allowed to use sharp objects within and around a patient's mouth. This bill is frankly demeaning to Virginia residents, as its purpose is to diminish the quality of care we receive. Instead of watering down healthcare services, let us instead continue to set a standard for ourselves by allowing the well-trained and appropriately qualified dental hygienists to continue doing their work.

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.

Please oppose this bill as it is harmful and hurtful for the entire dental team and the patients we serve! The bill explains that someone other than an educated and licensed RDH can do “part” of their job. This will lead to 1.) lower quality of treatment 2.) dangerous treatment that has adverse outcomes risk of increase dental disease due to improperly “trained” personnel 3.) more Rdhs feeling disrespected and leaving the field 4.) fraud due to billing for something that wasn’t done correctly due to scope of practice only being what a dentist or Rdh can do and putting it on a dental assistant 5.) dentists and hygienists having to clean up the mess of improper treatment which will lead to more dental disease and treatment. No hygienist approves of this because we know you cannot do our job without our education and exams and licensure. Thank you!!!

I strongly oppose this Bill. If passed, this Bill will lower the quality of healthcare that Dentistry will provide. Our patients trust us to be ethical and perform to the best of our ability, not to lower our standards. Only cleaning above the gum line will be turning a health procedure into a cosmetic one. We are health professionals. The mouth is the gateway to the rest of the body. We help to keep our patients healthy. Also, there is a shortage of Dental Assistants right now. Every AD I've spoken to has stated that they do not want to be trained to do this. They feel like they are already over-worked and under-paid. I think this might actually ADD to the Hygienist shortage, because if this Bill passes, I imagine a lot of frustrated Hygienists will leave. I personally do not want to work in an office that has a Scaling Assistant. Lastly, I see no way of enforcing the guideline/rules of this Bill. The Board of Dentistry doesn't really monitor if we are taking our required CE courses. Checking a box 'yes' to prove we have fulfilled our required CE on our yearly license renewal form online, is hardly monitoring if we are actually taking the courses. And CE monitoring is a simple thing to monitor. How will this be any better? There are already Dental offices allowing Assistants to scale patients teeth. And this Bill hasn't even passed! Dentistry needs to do better than to shortcut a 'solution' to the Dental Hygiene shortage.

Has potential to cause a future healthcare crisis. Dental hygienists provide a service much more than just clean teeth. Our knowledge and clinical skills are perfected through years of treating patients. Dental hygienists are required by law to graduate under an accredited dental hygiene school, take and pass a national board, as well as take a regional board were we are graded by a faction of dentists and fellow hygienists on solely on are skill as clinicians. HB970 and especially SB178 are detrimental to the Dental Hygiene profession. Would you want someone who has had hours of experience as your provider or a Dental Hygienist who has had years of experience and is certified by a board, and taken an oath?

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 am deeply concerned that these measures prioritize the "appearance" of care over the safety and long-term health of Virginia's patients. Regarding HB 970, which proposes the "Preventative Dental Assistant" role, my clinical experience has shown that on-the-job training is often insufficient for advanced procedures. Research consistently demonstrates that supragingival scaling (cleaning above the gums) alone is clinically inadequate for preventing systemic infection and periodontal disease. Providing substandard care in the name of "access" often leads to delayed proper treatment, higher rates of infection, and a significant loss of patient trust. I have seen this firsthand in my veteran patients—including my father, a Marine Corps veteran—who received limited care from "prophy techs" and later required extensive, painful intervention to address years of neglected underlying issues. Furthermore, HB 970 raises a critical issue regarding informed consent and public transparency. In primary care, the distinctions between doctors, nurse practitioners, and PA's are clearly regulated. However, these bills lack the necessary safeguards to help the public distinguish between dental hygienists and assistants with lower levels of education. Patients deserve to know the qualifications of their provider and must maintain the right to choose care based on those standards.

Patients deserve a licensed professional to perform their cleanings. Their skillset is something that is clinically taught, and professionally developed. Chair side training is not sufficient enough to provide the best standard of care that we are legally supposed to provide. Supragingival scaling leaves 1-3mm of microscopic bacteria untouched below the gums. This bacteria can embed itself into the gingival tissue and travel to other parts your body, as a known risk for factor for heart disease, diabetes, Alzheimer’s and other medical conditions. Please consider your health, your family’s health, and your loved one’s health when considering convenience over care.

I strongly oppose HB 970. On-the-job training for unlicensed dental staff to complete dental hygiene services is negligent and is a public health risk. Prior to licensure, a dental hygienist in Virginia must complete courses on general anatomy, physiology, head and neck anatomy, microbiology, pharmacology, pathology, radiology, and extensive clinical instruction. This foundation is crucial to prepare dental hygienists to comprehensively complete assessments of the head and neck, gum tissue, and teeth to evaluate for oral cancer, periodontal disease, and problems with the teeth. Research has established links between oral health and overall health including cardiovascular disease and Alzheimer’s disease. A preventative dental appointment includes much more than “just cleaning teeth.” Without the years of education from a fully accredited school, which is now the standard for dental hygiene education, patient care will decline. Oral health will decline. General health may decline.

I strongly oppose any bill that allows dental assistants to perform the duties of a Registered Dental Hygienist (RDH) after only a short training course. RDHs complete 2–4 years of rigorous education, clinical training, and national and state board examinations. Their training goes far beyond “cleaning teeth.” They are licensed healthcare professionals trained to detect periodontal disease, identify oral cancer risks, recognize systemic health connections, and provide preventive care that protects long-term patient health. Reducing those responsibilities to someone with a brief certification course lowers the standard of care. Patients would be paying the same price while receiving treatment from someone with significantly less education and clinical training. That is not transparency, and it is not fair to Virginia families. If the goal is expanding access to care, we should focus on increasing the dental workforce responsibly—not replacing highly trained professionals with minimally trained substitutes. Virginians deserve safe, high-quality oral healthcare delivered by properly educated and licensed providers. For the sake of patient safety, professional standards, and honest healthcare practices, I urge you to vote no on this bill.

Upward mobility and wages have been impacted by the influx of foreign workers in many US jobs. They haven’t served this country the way current citizens and their ancestors have and did. This bill should not be approved. It could result in fewer US citizens committing their talents and resources into becoming dental hygienists. Instead pass a bill that will provide incentives encouraging more US citizens to enter this profession.

As a concerned citizen I am writing to ask that you vote NO on HB970. I do NOT want to receive my preventative care from an unlicensed and undereducated individual. Dental hygienists go to college to provide vital healthcare services, and their clinical skills should not be undermined for financial gain. Healthcare should be maintained as an educated, licensed profession. I respectfully urge you to vote NO!

Please do not pass dental assistants providing supragingival scaling, as this is a risk to the community for injury and advancing gum disease. The college education and licensing to become a dental hygienist is rigorous because it takes skill, knowledge and clinical hours to proficiently detect and treat gum disease. Please do not undermine an entire profession of college educated people in a predominantly female profession.

As a small private dental office business owner I cherish employees that can maintain a superb standard of care. I spend hours continuously training my auxiliary team to ensure that my patients are cared for properly. I have been an externship site for the ECPI Dental Assisting program for over a decade! I love to teach. I educate dental assistant students to make them the best they can be to become a valuable asset to any office. With that level of training, through my team, my patients enjoy the trouble free care we give. With the many hours of training and the many more hours the dental assistants see the actual mechanics as I perform the treatments chairside, even my highly skilled and highly educated summa cum laude dental assistant graduates could never replace a highly educated and trained RDH. The level of clinical experience a hygienist gains during their TWO FULL YEARS of an accredited hygiene program cannot be replicated after minimal hours for a nominal certificate. A dental assistant cannot anticipate nor comprehend what each individual patient requires in their treatment without YEARS of clinical training and MEDICAL classes discussing the biology, physiology, psychology, and mechanics of treatment planning. What I have determined is these bills presented are a way to ease the pain to a dental office when they are unable to find enough RDHs to support their patient base. But what I have found over the years when I need a temporary RDH to fill in while one of my current RDHs is out on leave, that there are plenty of temps out there that like a flex schedule and only temp. Yes it costs more. But ultimately my patients are cared for properly. That allows me to sleep at night knowing that my patients have received quality APPROPRIATE care. These bills will allow a dentist to place an auxiliary in that RDH chair to just “decrease the outgoing payroll and shift the revenue into their own pocket”. I believe my colleagues that want these bills are not looking at the standard of care but caring about their bottom line and profits. Sham on them. As for me, my patients are receiving quality medically appropriate care with a licensed and BOARD CERTIFIED RDH. Please vote against these bills SB 178 and HB 970.

I strongly oppose HB970 and SB178. Supragingival scaling alone is not adequate to maintain periodontal health and may contribute to delayed diagnosis and progression of periodontal disease. Oral health care is not simply the mechanical removal of visible deposits; it requires comprehensive assessment, critical thinking, and the ability to identify and manage subgingival disease. These bills would allow individuals whose preparation may involve weeks of training to perform procedures that licensed dental hygienists are required to complete years of accredited education and extensive supervised clinical experience to provide. That difference in educational depth and clinical rigor is significant. It directly impacts a provider’s ability to recognize pathology, evaluate risk factors, and intervene appropriately. Patient safety and long-term health outcomes must take precedence over workforce convenience. If staffing shortages and financial pressures are the concern, the solution is not to lower standards of care. The profession should instead address reimbursement structures, workplace conditions, and sustainable compensation models that attract and retain qualified dental hygienists. Our patients deserve care delivered by professionals fully trained to protect their overall health—not a reduced standard of care. Thank you for your consideration.

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.

Dental hygienists are the preventive specialists in dentistry. As a hygienist with a bachelor’s degree from a school of dentistry, having a hygienist’s scope of practice encroached on by a certification that provides minimal clinical training poses several ethical concerns. Gum disease begins below the gum line. In the proposed bill, dental assistants would not be permitted to scale below the gingiva, leaving behind bacteria that could contribute to disease and in severe cases, tooth loss. Completing a 120-hour course does not certify that a dental assistant (DA I /DA II) is able to assess oral tissues for signs of disease, including oral cancer. Patients in rural areas need access to care now more than ever, with patients in these areas typically being at a higher risk for developing gum disease. However, having a dental assistant with several weeks of training treat these patients will not be beneficial, as dental assistants would only scale above the gum line. This would be an incredible disservice to patients who already face issues regarding access to care. With oral disease at the forefront of public health concerns, Virginians deserve licensed, boarded hygienists providing care, as they have been extensively educated in the theories and methodologies of dental hygiene. Without proper licensure, standards of care are lowered, leaving patients with subpar treatment. If ethical dilemmas were to arise, the supervising dentist would be held liable as he/she is the license-holding individual overseeing treatment. Dental hygienists are educated in pharmacology, radiology, pathology, histology, anatomy, etc. Extensive education is absolutely necessary for aiding dentists in their diagnosis and in the overall treatment of patients. Subgingival scaling is critical for the prevention of gum disease. Lowering standards in an attempt to improve access to care is a risk to the public’s oral health. Optimal oral health begins with disease prevention, and dental hygienists are crucial in this process.

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

It is very clear that most people don’t know the difference between a dental assistant and a hygienist. I will only see a hygienist. Money hungry individuals are ruining dentistry.

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

As a Registered Dental Hygienist that has been practicing for over 30 years, I’ve seen a lot changes. This would be the most detrimental of all. The quality of care would decline for ALL involved including those passing the bill. 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. 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 writing as a licensed dental hygienist with over 30 years of experience — first as a dental assistant and later as a registered dental hygienist — to strongly urge you to oppose HB 970 During my career, I have seen first hand the difference that professional training, education, and licensure make in patient care. I have worked in a clinic that accepts Medicaid, which did not have a licensed dental hygienist for over a year. In that time, minimally trained dental assistants were tasked with performing prophylactic dental cleanings. The result was devastating. When I later treated these patients — many of them children — I saw a sharp increase in acute gum disease caused by calculus left beneath their gums. Without the proper education in anatomy, instrumentation, and infection control, these assistants were simply unprepared to perform such procedures safely or effectively. I have even observed instances of harm caused by aggressive and improper polishing techniques, which can remove protective enamel and result in permanent damage to the teeth. These experiences have been deeply troubling. Most concerning is that these individuals often do not realize the harm being caused — not out of neglect, but due to a lack of education and understanding of oral biology and professional standards. What I have witnessed in that clinic represents exactly what HB 970 would allow to happen on a much wider scale. Dental hygienists are highly educated, licensed health care providers dedicated to preventing disease and promoting lifelong oral health. Reducing or bypassing professional standards of care will endanger patients, particularly those already vulnerable and underserved, such as Medicaid recipients and children. I urge you to protect the health and safety of Virginia’s citizens by standing against HB 970. Please support policies that strengthen the dental workforce through education, licensure, and collaboration — not by lowering the standards that safeguard our patients.

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.

I strongly oppose HB970 and SB178, which would allow dental assistants to perform supragingival cleanings. Oral health care is not just the removal of visible deposits—it requires years of accredited education, critical thinking, and clinical training to assess patients, recognize pathology, and manage periodontal disease safely. Allowing individuals with only weeks of preparation to perform these procedures risks delayed diagnosis, compromised patient safety, and poorer long-term outcomes. Our patients deserve care from licensed dental hygienists fully trained to protect their overall health, not a reduced standard of care for workforce convenience. Thank you for your attention to this critical matter.

Please oppose HB 970! I have been practicing as a Registered Dental Hygienist for 40+ years. Although I have witnessed changes in dentistry through the years, one constant that remains is Gum Disease. As a college educated oral health prevention specialist and provider of non-surgical periodontal therapy, I am very concerned with this bill and the harm that can be caused if this passes. Recent data from the CDC shows around 47% of adults over 30 have some form of periodontal (gum) disease, which is approximately 64 million people. This figure rises to roughly 70% for adults 65 and older. Bacteria does not only accumulate above the gingiva (gumline.) Subgingival (below the gumline) calculus will leave a rough surface which traps more bacteria, thus accelerating inflammation and periodontal disease. Leaving this calculus that is often tenaciously attached to the root below the gumline will significantly affect a patient’s periodontal health which can ultimately result in tooth loss. Allowing techs or assistants to be trained on the job to perform dental hygiene duties exposes the un-knowing public to substandard care and long-term health risks. This bill is proposing an additional dental assistant that has no standardized training and no oversight. This approach is being promoted as a solution to dental workforce shortages, but the evidence does not support that. For each patient who needs scaling above the gum line, a hygienist will have to follow up and complete scaling below the gum line in order to complete the procedure and file the appropriate claims to insurance companies. 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. I respectfully urge you to reject HB 970 and to support policies that prioritize patient safety, evidence-based care, and a strong licensed dental workforce. Thank you for your service and for your attention to this important public safety matter. Working together, increasing the number of Dental Hygiene programs and chairs in existing programs is the best long term solution for all! Melanie Bartlam, RDH

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.

Licensure requirements such as those needed to become a hygienist exist for several important reasons, including safety concerns for the patient. Periodontal disease and oral cancers are already under diagnosed and dismissing these requirements is expected to exacerbate this issue. Further, any profession requiring advanced training and licensure requirements tends to command a higher wage; reducing these might lead to a corresponding reduction in wages and lesser incentive to enter a profession that is already experiencing shortages.

As a practicing Dental Hygienist of 29 years, I strongly oppose these bills. I see no benefit of oral health of the patient to justify these bills.

I oppose the proposed HB970 allowing non-licensed assistants and foreign dentists scaling for dental cleanings on the basis that they do not poses the adequate training or knowledge standards as deemed acceptable by CODA. This presents a health risk to the population. Allowing this will only lead to poor oral health conditions and neglected health care.

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.

This bill is not for the benefit of patients - please do not pass this hill. Dental hygienists do more than just clean teeth, we are health care providers focused on prevention and treatment of oral diseases that also affects overall systemic health. DO NOT pass this bill as we will all suffer as patients.

I strongly oppose HB970 and SB178. Supragingival scaling alone is not adequate to maintain periodontal health and may contribute to delayed diagnosis and progression of periodontal disease. Oral health care is not simply the mechanical removal of visible deposits; it requires comprehensive assessment, critical thinking, and the ability to identify and manage subgingival disease. These bills would allow individuals whose preparation may involve weeks of training to perform procedures that licensed dental hygienists are required to complete years of accredited education and extensive supervised clinical experience to provide. That difference in educational depth and clinical rigor is significant. It directly impacts a provider’s ability to recognize pathology, evaluate risk factors, and intervene appropriately. Patient safety and long-term health outcomes must take precedence over workforce convenience. If staffing shortages and financial pressures are the concern, the solution is not to lower standards of care. The profession should instead address reimbursement structures, workplace conditions, and sustainable compensation models that attract and retain qualified dental hygienists. Our patients deserve care delivered by professionals fully trained to protect their overall health—not a reduced standard of care. Thank you for your consideration.

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.

The solution to a shortage of dental hygienists is NOT lowering the standard to “create” them. If you think there’s a shortage now, fast forward 10 years when all the people who have gotten cleanings by uneducated/certified OPA’s (if this passes) for a decade now have tremendous amounts of bone loss, oral infections, and virulent pathogens under their gumline that has been left to fester and worsen under the care of people who can not legally clean it out. Dental Hygienists will leave the field in DROVES if this bill passes and supervised substandard care is the new precedent. WHO will fix the oral health crisis then?

As an experienced Registered Dental Hygienist, who primarily treats Periodontal Disease, I oppose both bills for fear of public safety. Scaling above the gum line is supervised neglect. This puts the public at danger and will lead to an increase in systemic problems within our communities, primarily heart disease. Untreated and under diagnosed periodontal disease can also exacerbate diabetes and increase the risk for certain cancers such as esophageal and pancreatic cancer by 50%. There are safer and more responsible ways to address what the VDA claims as a Dental Hygienist “shortage”, rather than allowing under educated staff members to perform the dental work of properly educated and skilled professional providers.

I do not wish to be treated by an unlicensed individual for dental care.

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.

I strongly oppose HB970 and SB178 See the attached PDF for my official comment.

I want a hygienist that has a certificate to work on me. I have heart disease and a certified hygienist knows what to look for and knows what to do if I have an infection. Safety is a top concern of mine and I will not put my life in someone that didn't complete the years of training to be a hygienist.

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

Everyone should oppose this. Not only is it dangerous idea to allow someone who has not gone through proper training, rigorous hand on competencies, and extensive course work in dental hygiene to scale teeth it is extremely disrespectful to hygienists who have done everything to work for their license to treat patients. Any dentist who supports this should be ashamed of themselves and really look at their professional ethics. A dentist who allows this will put their patients in harms way no matter the amount of “on the job training” an assistant gets. Patients should be scared if this passes and should always request to see a valid dental hygiene license prior to allowing a cleaning .

Vote no! I am a retired dental hygienist. This would be malpractice to just scale above the gum level! Dangerous for patients!

As a hygienist these bills are absolutely astounding. Not only do they show a lack of understanding of all the training that goes into being a hygienist but you are also showing a complete lack of concern for the health of the population. This is sickening …. I object this

Dental care has always been a priority for my family, and the ability to receive stellar care from a professional—who possesses the education and is specifically trained and licensed—is of utmost importance. In today’s climate of lawsuits, it is imperative that patient health not be put at risk by having someone who has not been through the rigors of advanced education, intensive study and hands on training like dental hygienists. Allowing dental ‘assistants’ to scale a patient’s teeth could lead to many risks—not only to a patient’s health—but lawsuits when things go wrong. Let’s be honest, time that doctors/dentists have with patients is very limited. Should this bill be passed, the dentist, dental assistant, and the entire practice could be open to legal implications that could be costly to the practice and result in the forfeiture of licenses—all of which could be prevented by only allowing professionals who are truly credentialed and qualified to perform this type of care. It would be a travesty for this bill to be approved. Kill it before the health or life of dental patients in our Great Commonwealth is put at risk.

As a dental hygienist with over 40 years experience in general practice setting it is shocking to think this would be acceptable patient care.. We hygienists pour our heart and soul into patient care with the knowledge we obtained with years of education as well as years of clinical experience.. Dental assistants are a valuable part of the dental team but they should not be given the opportunity to “play hygienist “- unless they want to invest their time and money to go to dental hygiene school for the proper education.. As hygienists we continue to learn with required continuing education…

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 do not wish to be treated by an unlicensed individual for dental care.

Hello Marcia Price, My name is Grace Kissell and I am a licensed, registered dental hygienist and resident of Newport News. I am writing to express my strong opposition of HB 970. This bill is a proposed solution to the dental hygienist shortage in our state. The proposed solution allowing dental assistants with little training to scale above the gum line creates a major safety risk to the public. As a dental hygienist I completed a bachelors degree at an accredited program and graduated in 2024. During my time I completed countless hours of training and patient care before ever being allowed to see a patient on my own. Gum disease is one of the most prevalent diseases in the world and can contribute to other major health issues such as diabetes and heart disease. There are several other links between gum disease and other conditions currently being studied such as Alzheimer’s and different types of cancer. As a dental hygienist my job is so much more than scaling. I am a prevention specialist in charge of oral/head and neck cancer screenings, gum disease screenings and in depth health history assessments. Scaling above the gum line will allow gum disease numbers to rise, contributing to so many other health problems for the public. We cannot ignore what is going on below the gum line. The standard of care should never be lowered when it comes to healthcare. Please consider this bill and how detrimental it will be to the public.

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

I would like to have you know that I'm a dental patient. I really do not want a dental assistant working in my mouth with subpar training in hours and education. My husband and I have serious medical conditions. He is a heart patient. I'm a diabetic. We need someone with who is well trained and has a medical background. I'm asking you to please oppose this bill. Thank you.

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.

I have been a dental hygienist for the past 6 years. We go through a substantial amount of training to be able to effectively treat our patients. They count on us as the experts. It takes thousands of hours to be able to become licensed. We are all passionate about this field and want the best for our patients. Subpar care is not a part of that. Allowing dental assistants to scale supragingivally (above the gums) is not going to assist with reach. It would still require a provider to have to go underneath the gums to remove resident tartar. This does not close the gap. Hygienists are here and available and desire to provide care, but without the appropriate work environment and support, care becomes a challenge to provide. Hygienists deserve appropriate appointment lengths to provide optimal care, benefits such as PTO, health, dental and vision benefits and 401k. Some of these essential things are not provided by these offices. Without these things, wouldn’t one feel unappreciated and not supported? Additionally offices want hygienists to see more patients and provide them with less time to actually provide the care. This is not a conversation about reaching more patients for prevention, but a conversation on how offices can leverage their employees to do more work to increase production for the office.

As a recent dental hygiene graduate approaching two years of clinical practice in Virginia, I strongly oppose the passage of legislation such as HB 970. Dental hygiene is not a task-based occupation, it is a licensed healthcare profession built on extensive biomedical education, clinical training, and regulatory accountability. Hygienists complete two to four years of accredited education that includes anatomy, physiology, head and neck anatomy, pathology, radiology, pharmacology, periodontology, pain management, medical emergencies, ethics, and evidence-based practice. Beyond coursework, we complete hundreds of supervised clinical hours treating diverse patient populations and must pass rigorous national and regional board examinations to earn licensure. We are then required to maintain continuing education and are regulated by the VBD. This bill requires only a short training period and limited clinical exposure before performing supragingival scaling procedures. Scaling is not merely “cleaning teeth.” It is a clinical procedure that requires assessment, instrumentation skill, anatomical knowledge, and critical thinking. The visible calculus above the gumline is often only a fraction of the disease process. Periodontal disease is primarily driven by subgingival biofilm and calculus, inflammation, pocket formation, and systemic risk factors. Treating only supragingival deposits without comprehensive periodontal assessment risks giving patients a false sense of health while underlying disease progresses. We perform comprehensive periodontal charting, assess pocket depths and attachment loss, evaluate bleeding and inflammation, identify mucosal abnormalities, recognize signs of oral cancer, assess caries risk, interpret radiographs, evaluate medical histories for contraindications, and modify care based on systemic conditions such as diabetes, cardiovascular disease, pregnancy, or immunocompromised status. We are trained to recognize when a patient requires scaling and root planing rather than a prophylaxis, when referral is necessary, and when findings indicate a more serious pathology. These responsibilities require clinical judgment developed through formal education and hands-on experience — not a brief training module. Allowing assistants to perform scaled-down preventive procedures risks lowering the standard of care in Virginia. Suggesting that the preventive component of our profession can be adequately replaced by individuals without equivalent academic preparation devalues our expertise and undermines the integrity of dental hygiene as a healthcare profession. Healthcare providers should not be created through shortcuts. If the goal of this legislation is to increase access to care, there are better solutions that do not compromise standards. Lowering educational and licensure requirements is not innovation, it’s dilution. Periodontal disease is linked to diabetes, cardiovascular disease, adverse pregnancy outcomes, and other systemic conditions. The provider delivering that care must be equipped with the scientific knowledge and clinical judgment to recognize complexity and respond appropriately. A limited-training assistant cannot replace a licensed dental hygienist without compromising patient safety and professional standards. This bill risks patient health, professional integrity, and the long-standing standard of care in our state. I’m so incredibly disappointed.

DENY THESE BILLS!!!!

As a registered, licensed dental hygienist in Virginia, I strongly oppose Bill HB970. Lowering the standard for who is permitted to provide this level of care places patients at risk and weakens the protections that currently exist to ensure safe, thorough treatment. Scaling is not just a basic task; it is a clinical procedure that requires knowledge of anatomy, disease progression, instrumentation, infection control, and the ability to recognize warning signs of oral and systemic health conditions. These skills are developed through accredited education programs, hands-on clinical experience, and competency-based exams. Removing those requirements does not make care more efficient — it makes it less safe. If this bill passes, it is very likely more patients will be categorized as “healthy” and assigned to providers with less training. When the standard for determining who is “healthy” is subjective, it creates an environment where conditions can be missed, delayed, or overlooked. We already face a systemic problem with under diagnosing periodontal disease and not consistently meeting the current standard of care. This bill has the potential to make that problem worse. Early detection and prevention depend on trained professionals who can identify subtle signs of disease before they progress. Lowering the bar for who can provide care will not improve access — it will increase the likelihood that problems go unnoticed until they become more serious and more costly to treat. Patients trust that the person providing their care has the proper education and has demonstrated competency through licensing. That trust should not be compromised. For the safety of patients, the integrity of preventive care, and the long-term health of our communities, I respectfully urge you to oppose HB970.

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 feel that a hygienist should be the only person cleaning teeth! They have the proper education and training to perform this roll. The hygienist has acquired a degree that was grueling and put in a lot of work for this role. I feel that if a dentist wants a assistant to perform this role they need to quite a degree to become a dental hygienist

Hygienists need to be trained.

I’m not sure why this is the only fix that can be provided to address the hygiene shortages. If you’re able to produce 100 dentist in one single graduating class and only 24 hygienist. This ratio alone should tell you something! Out of those 100 dentist, each one of them would be legally allowed 3 hygienist to work under their supervision. Why can’t we look to produce bigger class sizes for hygienist. I’m not opposed to assistants becoming hygienists, because I am one. I started in dentistry when I 17 as an assistant but continued my education to become a hygienist. They can do the same with more access to education. I’m not saying a 4 year BS degree is necessary to produce a hygienist. Just like a trade school will educate and train a plumber or electrician, we could have a 2 year trade school for hygienist. My art history class I had to take to satisfy my 4 year BS degree, did not make me a better hygienist. Access to education is where we need to start. If this bill is passed and these assistants only care for above gum line bacteria, this will be classified as neglect for our patients. It will be sweeping bacteria under rug aka gum that will produce harm to our patients. It will produce earlier periodontal disease in patients, which will lead to earlier medical issues with heart disease, diabetes, cancers, etc….. Declining this bill can then open the real discussion channels that needs to be had about our storage in hygienist.

Pretty much every single patient that we see, children included, need to have tartar/calculus and plaque cleaned from below their gumline. Every single patient that I saw today, including those with healthy mouth and gums, had bacteria that needed to be cleaned subgingivally. This leaves me wondering who exactly will be eligible for the “supragingival” cleanings that assistants will be providing if passed. This bill will only lead to incomplete cleanings being done and will lead to an increase in periodontal disease and decay issues. It only takes a few days for gingivitis to form and a few weeks for periodontitis to form. Gum disease is being directly linked to heart health, diabetes, Alzheimer’s, adverse pregnancy outcomes, and so many more systemic conditions. Please consider how this will negatively impact the overall health of ALL Virginia citizens if passed.

Absolutely opposed to this bill. As a dental professional this is an outrageous idea and a risk to the public.

I am writing today in opposition of these bills. I have been a dental hygienist for 26 years. My training and education provided me the competence to provide proper oral health care. With the evidence showing the link between periodontal disease and heart disease should make this decision a no brainer. The ability to properly diagnose early and treat early is incredibly important. This is what I do all day every day. I don’t just “clean” tarter off teeth. I am assessing the mouth and assessing the health or the host response to the bacteria. I was a dental assistant before a hygienist and I didn’t even know or understand plaque. Dental assistants are trained to assist the dentist not to diagnose and treat gum disease. This cannot be taught on the job. Passing these bills will take all our field backwards. We need more schools! There are so many people waiting and wanting to get into hygiene school but when a school only takes 20 students at a time of course we will have a shortage! Let’s actually fix the root problem not dumb it down!

I have been a registered dental hygienist since 2004 and these two proposals are just the most insane thing I have ever seen! Registered dental hygienists are highly educational professionals - we do not “just clean teeth” we save lives! The proposals are absurd and a slap in the face to our profession! It is also a disservice to the patients that deserve excellent care! If this passing I truly believe all hygienists should go on strike!

I'm wriing with concerns about the Preventative dental assistants; certification Bill, because having dental assistants without certification seems very dangerous. It's going to start making people sick if hygienists cleaning your teeth are not properly trained and held to strict standards like licensed hygienists. Allowing this bill to pass will be very dangerous for Virginia citizens and most people don't even know that this is happening, or that they might be getting their teeth cleaned by someone who is not licensed in the future. Would you want some sort of unlicensed nurse giving you an IV? What's the real difference here? Thank you for considering not passing this bill.

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 absolutely attest these bills. I feel that we deserve licensed professionals to give us the best oral care. Having a certification is not enough being as though oral health can affect the entire body.

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.

This bill is a threat to public safety!!! Allowing unlicensed or insufficiently trained personnel to scale supragingivally without the education necessary to identify underlying pathology creates significant risk. What may appear to be “above the gumline” often involves disease processes that extend subgingivally. Without proper training, residual biofilm and calculus may be left behind, resulting in: - Continued or worsening periodontal disease - Delayed diagnosis of underlying conditions - Increased need for more invasive and costly treatment later - Longer, more complex future appointments - Greater strain on the limited number of fully trained providers An incomplete or improperly performed procedure does not expand access to care, it creates deferred problems that ultimately increase the burden on patients and the healthcare system. Public safety must remain the priority!!! Expanding duties without equivalent education, licensure, and accountability undermines the very standards designed to protect patients.

I am writing as a Virginia constituent and a licensed dental hygienist with 18 years of clinical experience to express my strong opposition to HB940 and HB1036 and to respectfully urge you to oppose legislation that lowers healthcare standards and compromises patient safety in the Commonwealth. These bills do not meaningfully address a workforce shortage. Instead, they weaken long-standing professional and educational safeguards that exist to protect Virginians from preventable harm. Of particular concern is the provision allowing Level III dental assistants to perform scaling of teeth after only 120 hours of on-the-job training. Scaling is an irreversible, invasive procedure involving living gingival tissues. Improper removal of tooth structure or gingiva does not regenerate and can result in permanent damage, infection, and disease progression. This training requirement is profoundly inadequate when compared to the more than 3,000 hours of formal, accredited education required to become a dental hygienist. These pathways are not comparable in rigor, clinical judgment, or patient-safety preparation. Equally troubling is the regulatory framework in Virginia. Dental assistants are not licensed, registered, or regulated by a state board, nor are they subject to mandatory background checks or identity verification. Individuals may be hired directly from the general public with no formal oversight. Under these bills, such individuals would be permitted to perform invasive procedures involving blood and patient safety within a licensed healthcare setting. For perspective, cosmetologists in Virginia must complete over 1,500 hours of training and obtain licensure to cut hair. Allowing unlicensed individuals with minimal training to perform irreversible oral procedures represents a clear inconsistency in regulatory standards and raises serious public-safety concerns. These bills also rely on the assumption that patients have undergone a comprehensive periodontal assessment and have been accurately deemed “healthy.” In clinical practice, periodontal disease is frequently underdiagnosed or missed altogether. When disease is overlooked, patients receive inadequate treatment and suffer disease progression with significant consequences. The broader public-health implications are substantial. Periodontal disease is associated with cardiovascular disease, diabetes complications, and systemic inflammation. Inadequate diagnosis and treatment will increase Medicaid expenditures, emergency department utilization, and long-term healthcare costs for the Commonwealth. Finally, this legislation exposes dentists and the state of Virginia to expanded liability by authorizing unlicensed and unregulated individuals to perform procedures capable of causing harm. As healthcare professionals, we take an oath to do no harm. Public policy should reflect that same principle. Lowering standards is not innovation—it is regression. Thank you for your consideration and for your commitment to the health and safety of Virginians.

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

Dear Delegate Price, I am writing in opposition of HB 970. Thank you for hearing my concerns; and possible solutions. Regarding the Preventive Dental Assistant (PDA), (HB 970); the bottom line is that scaling above the gumline and polishing does NOT prevent disease. Currently in the United States 85% of our population have some form of periodontal disease. Periodontal disease has been directly linked to stroke, uncontrolled diabetes and heart disease. Even those in health still have live dangerous bacteria and tartar below the gumline, which if not treated and if patients are not educated in oral hygiene will lead to disease. It is a false narrative and is misleading to our patients that our citizens will be getting a thorough visit. This is not equitable care. Even children will need scaling at times. Who will be doing cancer screenings, assessing cavities, assessing periodontal status, initiating nutritional counseling to prevent cavities and gum disease, assessing and educating on oral hygiene? With this model NOBODY will be doing this to the extent of an accredited, educated, boarded (1–8-hour exam, 1–2-hour clinical exam and 1-1-hour OSCE exam) licensed dental hygienist. It is a disservice to the profession of dental hygiene, but ultimately a disservice to our citizens of Virginia. States where this provider was initiated, have not shown positive results and it has had no effect on access to care. For instance, in Kansas today, NOT ONE dentist hires a “scaling assistant” in their practices. 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. The Preventive Dental Assistant is not a solution. It is a false, misleading provider, who will not provide the standard of care we as professionals demand for our patients. I would suggest other strategies to increase the access to quality oral health care by providing additional financial incentives, as many states now do, for professionals to practice in rural underserved areas, or allowing dental hygienists to work to their full scope of education and training. Furthermore, adding a mid-level provider to Virginia such as the dental therapist would provide an accredited dual provider who can do dental hygiene AND some dental procedures. These strategies have been shown to be an effective way to reach patients in need of care and provide them with the high-quality care they deserve. The Preventive Dental Assistant is not a solution. 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

This bill is a threat to public safety!!! Allowing unlicensed or insufficiently trained personnel to scale supragingivally without the education necessary to identify underlying pathology creates significant risk. What may appear to be “above the gumline” often involves disease processes that extend subgingivally. Without proper training, residual biofilm and calculus may be left behind, resulting in: - Continued or worsening periodontal disease - Delayed diagnosis of underlying conditions - Increased need for more invasive and costly treatment later - Longer, more complex future appointments - Greater strain on the limited number of fully trained providers An incomplete or improperly performed procedure does not expand access to care, it creates deferred problems that ultimately increase the burden on patients and the healthcare system. Public safety must remain the priority!!! Expanding duties without equivalent education, licensure, and accountability undermines the very standards designed to protect patients.

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 urge you to OPPOSE House Bill 970. These bills are based on a false premise—there is no shortage of dental hygienists in Virginia. What we have is an insurance reimbursement crisis that these bills fail to address. Dental Hygiene Is a Specialized Clinical Skill Dentists receive minimal training in dental hygiene practices—often just weeks during dental school—because it is not their specialty. Calculus detection and removal requires specific tactile skills, extensive training, and clinical experience that dental hygienists spend 2-4 years developing. You cannot replicate this expertise with on-the-job training. As a dental hygienist, I regularly see new patients from offices that provided negligent care. Subgingival calculus left behind by inadequately trained providers leads to: ∙ Progressive bone loss and tooth loss ∙ Bacteria entering the bloodstream ∙ Increased risk of heart disease, stroke, and diabetes complications ∙ Systemic inflammation affecting all body systems The consequences of substandard care are irreversible. Research Links Oral Health to Overall Health The mouth is a gateway to the body. Periodontal bacteria don’t stay in the mouth—they: ∙ Enter the bloodstream through inflamed gum tissue ∙ Contribute to arterial plaque and heart disease ∙ Worsen blood sugar control in diabetics ∙ Increase risk of respiratory infections ∙ Are linked to Alzheimer’s disease and adverse pregnancy outcomes Dental hygienists are often the first to detect early signs of these systemic conditions during routine cleanings. Untrained workers won’t have the knowledge or skills to recognize these warning signs. Lowering Standards Does More Harm Than Good These bills propose to address access issues by: ∙ Allowing unlicensed, on-the-job trained workers to scale teeth ∙ Eliminating preventative care education requirements ∙ Permitting inadequate calculus removal that leads to disease progression This is not increased access—it’s sanctioned negligence. In the long run, inadequate care will lead to: ∙ More emergency dental visits ∙ More tooth extractions ∙ More systemic health complications ∙ Higher overall healthcare costs ∙ Greater health disparities The Real Solution Virginia doesn’t need lower standards—we need adequate reimbursement rates so licensed professionals can afford to accept Medicaid and insurance patients. Address the payment crisis, not the professional standards that protect patient health. I urge you to oppose these bills. Don’t sacrifice Virginians’ long-term health for a short-sighted solution that benefits insurance companies while harming patients.

I do not want to compromise my dental health by having an unqualified assistant scale my teeth. No amount of cost cutting is worth risking the health of my teeth.

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 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 that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your service and consideration.

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.

I am the co-chair for TDHA, a licensed dental hygienist, and an Associate Professor in a baccalaureate program here in Virginia and want to ensure you have my unique perspective and evidence on this matter. 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. As your constituent, 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

I can tell you if I walk into a dentist office and they're hygienist are not a certified and qualified to do the work on my mouth that I have spent thousands upon thousands of dollars to fix. I will find a dentist that has only certified and qualified hygienist. I cannot believe that you are willing to put people at risk by allowing someone that is not qualified to do this kind of work. You should all be ashamed of yourselves. Just follow the money it's always about the money it's never about the people

Your Health is Not a Shortcut As a dental professional, I am appalled by the proposed legislation in Virginia. This bill suggests that the years of scientific study, clinical mastery, and rigorous board examinations required to become a Registered Dental Hygienist can be condensed into a short training course for assistants. Why this matters to you: The Mind-Body Link: Hygienists are trained to spot oral cancers and systemic diseases. Short-term training cannot replicate the diagnostic intuition built over years of study. Clinical Safety: Scaling and advanced periodontal work are invasive. Lack of proper education leads to permanent tissue damage and infection risk. Integrity of Care: Dentists who support this are choosing profit over the standard of care. It is a shameful move that treats patients like numbers rather than people. We must stand up for the standards of our industry. Do not let Virginia trade your safety for a cheaper bottom line. Michele McTague, BS, RDH

I am writing to respectfully express my strong opposition to the proposed legislation that would allow dental assistants to perform duties currently reserved for licensed dental hygienists without completing accredited hygiene education and licensure requirements. This proposal raises serious concerns related to patient safety, quality of care, infection control, and professional accountability. Dental hygienists are licensed healthcare professionals who complete extensive education and clinical training, typically including: • An accredited dental hygiene degree program • Hundreds of hours of supervised clinical care • National board examinations • State clinical licensure exams • Ongoing continuing education requirements These requirements exist to ensure patients receive safe, competent preventive and periodontal care. Please don’t lower the standard of care for patients. This would be a public health disaster.

I am writing in strong opposition to HB970. I have been a dental professional for 42 years. I started out as an young assistant( and was allowed to work at 15 years of age with a work permit) with a Dentist who trained me to assist. There is NO on the job training that a Dentist can provide to an assistant that compares to a fraction of education, medical history precautions, or precise tactile instrumentation techniques that were taught in dental hygiene school. Dentists only recieve 12 hours of clinical scaling instruction in dental school compared to 3000 hours a hygienist recieves. There was a reason dental students had the Hygiene students teach them to scale. Please oppose this bill. As a young dental assistant who never went to a dental assisting school, I was not qualified to do a hygienist's job...and the assistants who would be allowed to do what is proposed in this bill will NOT be qualified either. It is gross neglience of patient care to allow this bill to advance.

To pass this bill would be absolutely negligent and an enormous risk to patient safety. Dental Hygienists are required multiple years of education, clinical competency, and the passage of state and clinical boards. To lower the standard of care is a slap in the face to patients and clinicians alike. Please protect your constituents from the harm this will bring - to patients health and to hygienists’ careers that we worked incredibly hard for!

Gum disease is linked to over 57 different systemic diseases and conditions (heart disease, Alzheimer’s, diabetes, infertility, etc.) - please protect the citizens of Virginia but maintaining the integrity of their healthcare providers!! Dental hygienists are licensed, extensively trained professionals - please do not compromise standards.

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 dental patient and I do not wish to have an uneducated and inexperienced individual working on my teeth. I chose to see the devalue hygienist for this reason twice a year and the dental professionals should support their hygienist.

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 am a licensed dental hygienist and certified dental assistant in Virginia and I greatly oppose HB 970. Dental assistants in Virginia do not have to complete any certifications to work besides a weekend xray certification, and while I attended a CODA certified program to obtain my CDA (which most dental assistants do not), I can say wholeheartedly I would have been a horrible hygienist if I was trained to perform “supragingival” scaling on the job. The fact of the matter is, there is no such thing as “supragingival scaling”. Every patient that I see in my chair, including children as young as 5, I have had to subgingival scale. I have seen the detrimental effects to patients periodontal status that have been treated by those that have not had proper hygiene training, including dentists (who only get minimal hygiene training in school) and those that have been overseas from prophylaxis that had not scaled subgingival and left behind calculus deposits that caused bone loss and tissue damage, or periodontal disease. I understand there is a shortage of hygienists in Virginia, but the patients will suffer greatly if this bill is passed. Periodontal disease is irreversible and has a plethora of health impacts including increased risk of heart attack, stroke, Alzheimer’s disease, colon cancer (as the bacteria that live in our mouths contribute to these) as well as many other co-morbidities. If someone who is not even trained to understand basic infection control (as dental assistants in Virginia are not required to) how to complete a head and neck exam, or understand complex medical history, how will they know what bacteria causes periodontal disease, or the science behind what they are doing to a patient to educate the patient on their oral health? Given the absolutely devastating effects to the unknowing patients that this bill could cause, I please ask you to oppose this bill. Makenzie Green, RDH, CDA

To me, a citizen with concern, this bill represents a huge negligence in care. To me, this is the equivalent allowing an xray tech the ability to reset broken bones just because they had a two week course. Absolute insanity. Would you allow a nurse aid to administer anesthesia to your parent? 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.

The proposed legislation will NOT address any needed hygiene shortage. As a previous educator with 15 years teaching experience, there is no way a dentist will be able to properly train a dental assistant in 120 hours to safely treat a patient for removal of supragingivally present calculus. This takes the dentist away from treating his/her own patients which is generally higher yield monetary procedures. Working in dentistry for 40+ years, I find it hard to believe any dentist will truly take the time away from their procedures to accomplish the proposed training. Additionally, hygienist are TRAINED and educated to the same levels of a REGISTERED nurse. Approving this legislation directly puts the patient at risk for oral disease development, progression and injury from unprepared individuals utilizing sharp instruments adjacent to fragile oral tissues. Please realize that this will NOT address any fabricated "shortages" of licensed dental hygienist in the Commonwealth of Virginia. Signed, A hygienist with Associate of Applied Science in Dental Hygiene Bachelor's of Science in Dental Hygiene Master's of Dental Hygiene DEGREES Vickie Schram

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 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 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 that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your service and consideration.

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 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 that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your service and consideration.

I as a dental patient would not want an unlicensed assistant who has not been to hygiene school todo a cleaning on me or my family

Please SAY no to these! This is not the solution for a hygienist shortage! This puts patients at harm. It’s almost literally IMPOSSIBLE to complete supragingival scaling without having to go subgingival. Patients are not going to want to return for more than one appointment and I would not trust them to even come back after the “Supra” cleaning. Instrumentation, detecting calculus, using an ultrasonic scaler can take MANY years to fully understand. I’ve spent over 3,000 hours to become a dental hygienist in school and now seven years in the field. This will cause much harm in the long run. This is pure NEGLIGENCE.

The proposed legislation will NOT address any needed hygiene shortage. As a previous educator with 15 years teaching experience, there is no way a dentist will be able to properly train a dental assistant in 120 hours to safely treat a patient for removal of supragingivally present calculus. This takes the dentist away from treating his/her own patients which is generally higher yield monetary procedures. Working in dentistry for 40+ years, I find it hard to believe any dentist will truly take the time away from their procedures to accomplish the proposed training. Additionally, hygienist are TRAINED and educated to the same levels of a REGISTERED nurse. Approving this legislation directly puts the patient at risk for oral disease development, progression and injury from unprepared individuals utilizing sharp instruments adjacent to fragile oral tissues. Please realize that this will NOT address any fabricated "shortages" of licensed dental hygienist in the Commonwealth of Virginia. Signed, A hygienist with Associate of Applied Science in Dental Hygiene Bachelor's of Science in Dental Hygiene Master's of Dental Hygiene DEGREES Vickie Schram

I strongly disagree that this bill should not be accepted or even allowed because I don’t want and no one wants an un licensed dental hygienist or dentist working on our teeth. It is very dangerous and it’s not safe or trustworthy. When I go to the dentist I want to have trust that I will be taken care of without ever having the slightest doubt of not knowing if this person is licensed or not. I want to be able to feel safe going to the dentist and if this bill passes I won’t feel safe. Please do not let this pass

These bills will provide substandard care for patients. Dental Hygienists have over 3000 hours of clinical training that encompasses more than just teeth…it is a whole body approach. We hold a state license that we have to renew each year with continuing education and had to pass a National exam. These bills only serve to get non-qualified persons to attempt to do a job that they do not comprehend for less money for the employer dentist. Please do not endanger the public by passing these bills!!!

Allowing these bills to pass is wreckless and neglectful to patient health. This would put patients at risk of infection. Have you ever been uncomfortable at a teeth cleaning? Now imagine if that person had less training than they did. Irresponsible

As a dental hygienist for 16 years, no assistant should ever be able to scale . We went through extensive, expensive schooling to earn a degree and license!

Plain and simple. Oppose this bill!

I am asking to not pass these bills. This is a disservice to our patients and will only cause more problems than good. There is not a shortage of hygienists out there. We are just tired of poor pay and working conditions. So many of these assistants barely do their own job properly so how can they do proper hygiene! We spent 3000 hours learning anatomy and proper instrumentation and medical emergencies. This is not fair to hygienists or patients.

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.

Allowing these bills to pass is substandard care. Patients of mine are already coming in questioning why this is even happening. Supragingival scaling only will do more harm than good. I’ve been a hygienist for 20 years- bachelors degree in dental hygiene. This is not the answer for the lack of hygienists in the state. More schools, more seats at current schools, changes in DENTAL INSURANCE is the answer here. This is supervised neglect. This is malpractice. Morgan Temple, RDH BSDH

I oppose this bill for the well being of patients overall oral health and long term well being. I was an assistant for 6 years before going to dental hygiene school. Assistants are vital in every practice and have multiple jobs/tasks in running a practice smoothly. That being said, we all have our roles to play in dentistry. Scaling and using an ultraonic instrumentation should only be used by LICENSED and trained/ educated individual that went to an accredited school. Hygienists went through thousands of clinical hours and 4 semesters of courses focused on dental hygiene plus national boards and clinical state board. I hope that anyone that votes yes for this is okay with subpar cleanings and bone loss over time.

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!!

Let's pretend there is a shortage of technicians to do oil changes. So to alleviate the shortage, we said all cars under 5 years old would get an oil topper, and their job was just to add more oil and not change the oil, because the car is healthy and new. How long will that car last? Or let's say I have a new boat and we spend all summer on Lake Gaston having fun with it. And since it's new, we leave it in the water all year. We clean the boat above the waterline but never below because it's new and healthy. What do you think you'll see when you pull the boat out of the water after a year, even though it was new? These examples mirror the idea of a preventive assistant that will scale only above the gumline in healthy patients. All patients should have their biofilm in their mouth, above and below the gumline, disrupted at regular intervals. Patients will end up with disease. This is simply put malpractice. Yes, dentists are struggling to hire hygienists (and assistants). Let's put our resources into schools. I worked at the now-closed VPCC dental hygiene program. Let's look at the ratios of dentist-to-hygienist graduates and ensure they are aligned to set us up for future success. Don't lower educational standards when someone's health is on the line.

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!!!

Disastrous bill. I will make sure that none of these people touch my teeth.

Disastrous bill. I will make sure that none of these people touch my teeth.

Hi, my name is Miranda Walters and I just want to make clear that passing these bills will result in poor quality of care for patients. Hygienists go to school for years to learn these things in depth. I am currently a dental assistant and hygiene assistant for the past two years now and I do NOT support these bills being passed. My dream is to go to school and become a hygienist like my mom but by passing these, what is the point?? What is the point of going to school and becoming licensed if you are giving away the ability to scale to just anyone? You are taking away professional quality care and putting it into the hands of people who are NOT licensed. This is poor and unethical.

SB178 and Hb970. I have been a dental professional for 35 years. Hygenists have the appropriate degree and liscensing to insure patients safety when they are treated. I strongly oppose anyone without the proper RDH degree working inside soneones mouth.

I am a licensed dental hygienist, and I am writing to respectfully express my opposition to HB970. Allowing dental assistants to perform teeth cleanings can be problematic because it blurs important lines of professional training and patient safety. Dental hygienists receive specialized education in periodontal health, disease detection, and proper scaling techniques, which prepares them to recognize early signs of infection, bone loss, or oral cancer during a cleaning. Dental assistants, while essential to a dental practice, are typically trained to support procedures rather than independently assess and treat patients. When assistants perform cleanings, there is a higher risk that plaque and calculus are removed improperly, gum tissue is injured, or serious conditions are overlooked. This can lead to delayed treatment, worsened oral health, and reduced trust in care. For quality and safety, teeth cleanings should remain the responsibility of properly licensed and trained dental hygienists. As a hygienist who has completed countless of teeth cleaning. It is extremely difficult to clean gumline calculus without having the scaler going subgingival.

As someone who cares about and takes seriously my dental health, I strongly oppose both of these bills (HB970/SB178). In other states where this has been implemented, a recent update has shown this has not increased access to care or help with the workforce shortage. I have great concern that only cleaning above the gumline and not addressing the buildup below would be harmful to anyone seeking (routine and proactive) dental treatment. These bills are creating a path of neglect for dental health and this is not ok. There should continue to be a reputable threshold for anyone responsible for the treatment of another person’s (dental) health. Where is the Board of Dentistry in this document to continue setting protocols and guidelines to protect the patients and ensure proper care? I do not want to be a guinea pig and do not want this for my family. Please do not lower the standards of education in the healthcare field—Virginians deserve better.

As a dental assistant, I believe it is important to carefully consider the proposal of allowing assistants to perform subgingival scaling. Dental assistants already carry a significant workload each day from chairside assisting, infection control, sterilization, patient preparation, radiographs, scheduling coordination, and ensuring smooth clinical flow. Adding subgingival scaling to that list increases responsibility without realistically adjusting the time, support, or compensation required to perform it properly. Subgingival scaling is not a simple task. A few weeks of training does not equate to the depth of education and clinical knowledge obtained through a four-year dental hygiene degree. Dental hygienists receive extensive training in periodontal health, systemic connections, pathology, patient assessment, and risk management. That foundation cannot be replaced with short-term certification without potentially compromising the standard of care. Patients already experience anxiety about dental visits. They deserve high-quality, comprehensive care delivered by appropriately trained professionals. When assistants are stretched thin, patient education often becomes the first thing sacrificed. With the current day-to-day schedule of a dental assistant, where would there realistically be dedicated time to discuss oral hygiene instruction, preventative care, and long-term periodontal health? Additionally, if access to hygiene care is the concern, perhaps the discussion should focus on improving pathways into hygiene programs. Many assistants work extremely hard to meet the demanding and often restrictive requirements for dental hygiene school. While everyone must earn their degree, the barriers can feel discouraging even for highly experienced assistants who are already contributing significantly to the field. Adding to the statement, as a dental assistant pursuing dental hygiene what is the point to keep going? It also raises an important question: what message does this send to future hygienists who have invested years into pursuing that education? There must also be accountability for workplace environments. Offices that struggle to retain hygienists often face issues such as unrealistic production pressure, burnout, and toxic culture. Expanding assistant duties does not resolve those systemic problems. Dental assistants are hardworking, adaptable, and deeply committed to patient care. However, many of us are already exhausted and experiencing burnout. Expanding clinical responsibilities without proportional education, compensation, and structural support risks further straining a workforce that is already stretched thin. This is not about limiting growth it is about maintaining professional standards, protecting patient care, and ensuring fairness across roles within dentistry.

I'm a patient and I oppose these bills.

PLEASE listen to license registered dental hygienists who oppose HB 970. My letter explaining my opposition is attached to this link. Thank you for your thoughtful consideration of Virginians oral health.

As an RDH and previous dental assistant I oppose both bills HB970 & SB178. In states where this has been implemented updates have shown that this does not increased access to care or help with the workforce shortage. There are so many alternative options other than these bills such as addressing dental hygiene schools closing down and class numbers of open schools diminishing, license reciprocity to allow hygienist to travel across state lines, & taking on insurance companies poor reimbursement rates that do not reflect the cost of business today. More than half the adult population nationwide has periodontal disease. It is harmful to only clean above the gumline and not address the buildup below. Removing only supragingival buildup will cause the gums to tighten or heal some and trap the buildup below the gumline, causing periodontal issues and difficulty in accessing these areas when they need to be scaled, contributing to periodontal disease. Hygienists go through thousands of hours of clinical training in addition to 2 years of prerequisites and boards to be able to do our jobs. Why will this bill allow people to our same job with less training and licensure than a person who does lashes? The people of Virginia deserve better than lowering the educational standards of healthcare!

Dear delegates, as a registered dental hygienist of almost 30 years I encourage you to decline passing these two bills. Allowing minimally trained providers will in no way benefit the health of our dental patients. We have been trained to do far more than scrape stuff off of people’s teeth. We are trained in CPR/AED, oral cancer screenings, periodontal disease examinations, blood pressure, patient education to prevent dental disease and are required yearly to be monitored by the state board of dentistry to attain a minimum of 15 credit hours of continuing education. We have been schooled not only in scaling technique but, pathology, anatomy, pharmacology, chemisty, biology, etc. In turn over 2 years of education from accredited programs prior to multiple board examinations before we can even receive our licenses to practice as healthcare providers. Allowing above gum line scaling will only lead to increased disease in dental patients by allowing bacteria and hard deposits remain below the gumline. These bacteria are also being linked to heart disease, Alzheimer’s, diabetes and even cancers. A simple google search will give you the statistics that more than 50% of adult Americans are affected by periodontal disease, which is irreversible and can lead to tooth loss. I have seen a huge shift in dentistry in the past 30 years. COVID certainly did affect the numbers of hygienists practicing. But, from social media groups I see a large number of younger hygienists quitting after just a few years large in part due to burnout. They are burning out because they are being asked to do more and more in less time. Dentists ask for more in less time large in part because dental insurances are reimbursing at the same low rates they have for too many years. Do I agree that changes need to be made to better offer care for out patients in a timely manner, yes. Is allowing minimally trained clinicians to do it, no. Please vote no, on these two bills.

Respectfully, I strongly oppose HB970. I hold a bachelor’s degree in dental hygiene from VCU School of Dentistry that required 8 semesters of education. I am a Registered Dental Hygienist, RDH that required taking a national board exam. I hold a license to practice dental hygiene in the state of Virginia which means I have oversight and standards to uphold or I am subject to losing my license to practice. I am offended and appalled that this state would create a position that endangers the public’s health and safety. There is no therapeutic benefit to scaling above the gumline. I would call this supervised neglect at best or perhaps something worse. There are many letters here that review the scope of practice of Dental Hygienists and the many details that go into providing care for the patients in our chairs. So I will keep my comments brief.

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

Opposed to the dental assistant scaling bill. As a 20 plus year practicing RDH with a BS degree, I am not worried about my job or working future, I'm worried about my personal healthcare as I age. This bill is absolutely frightening This bill is very vague in allowing uneducated individuals to perform the work of licensed Healthcare workers. Preventative care requires skill and knowledge that will not be attained in a few days of on the job training. .

I have been a dental assistant for 25 years. I very much oppose this bill. We do not have the significant education and clinical training that hygienists do. Dentists are just trying to cheapen labor. I will not participate in this.

I am a Registered Dentak Hygienist of 22 years. I oppose these bills. We went to school specifically for these procedures. For years. We are trained to teach patients how to maintain oral health, total health and preventative health. It is not safe for the patients to be treated by an untrained/ uneducated person.

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.

My sister is a hygienist snd this scares me. I do not want an unlicensed, dental assistant or foreign dentist to clean my teeth. They don’t have standards and this is going to cause more harm than good. Everyone in the dental field is needed and their area of expertise is different. How come we don’t have licensed practical nurses doing the job of a RN. This doesn’t make sense and will only cause issues. Everyone in the dental field is needed but they do not do the same thing. This is very dangerous and needs to be stopped. If we need more hygienists we need more community colleges, better pay, better pay back from insurances, less clocking out for administrative duties.

I am a licensed dental hygienist practicing in Virginia, and I am writing to respectfully express my opposition to HB970 and SB178. Preventive dental care is not a single mechanical task (i.e. 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 programs with extensive clinical training dedicated specifically to preventive instrumentation and periodontal evaluation. HB970/SB178 would create a new category of “preventative dental assistant” authorized to perform supragingival scaling after a significantly abbreviated training pathway. While framed as an access solution, this approach introduces a tiered preventive model that risks separating scaling from comprehensive periodontal evaluation. This may unintentionally compromise early disease detection and creates a lower standard of preventive care for Virginia patients. Periodontal disease begins subgingivally and is not always visibly apparent above the gumline. Even clinically healthy patients accumulate subgingival biofilm that, if not properly assessed and disrupted, can contribute to future disease progression. Preventive standards must remain aligned with the biological reality of how oral disease develops. If access and workforce sustainability are the concern, policy solutions should address insurance reimbursement, public health hygiene expansion, and retention of licensed preventive providers rather than reducing clinical training requirements. Virginia families deserve preventive care that prioritizes early detection, thorough assessment, and long-term health outcomes. Thank you for your time and consideration.

I do not find these bills to be beneficial, wise or a good idea for the health of the masses I do not support.

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. 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. Only money hungry dentists would want these bills to pass to make more $$ for their offices!

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. 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. Only money hungry dentists would want these bills to pass to make more $$ for their offices!

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!

Patient access to care also means access to quality care. Education matters. Patients deserve to be treated by a healthcare provider with the proper education, training, and licensing. Circumventing this process is unreasonable. Patients deserve better.

Yall here is the blurb if you want to oppose the bills!! Let me send the link too! 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.

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.

As an RDH with 20 years experience and a VCU grad I strongly oppose both of these bills (HB970/SB178) In other states where this has been implemented a recent update has shown this has not increased access to care or help with the workforce shortage. Solutions are- joining a multi state licensure compact that allows licensure portability across states, streamlining license reciprocity (this can take months!), increasing class sizes in hygiene schools & taking on insurance companies poor reimbursement rates that do not reflect the cost of business today. Scaling above the gumline only is not within the CDT billing code as a complete prophylaxis. That includes medical history evaluation, periodontal assessment, oral cancer screening, scaling Supragingival (above the gumline) and subgingival (below the gumline), & oral hygiene education. More than half the adult population nationwide has periodontal disease. It is harmful to only clean above the gumline and not address the buildup below. Removing only supragingival buildup will cause the gums to tighten or heal some and trap the buildup below the gumline, causing periodontal issues and difficulty in accessing these areas when they need to be scaled, contributing to periodontal disease. It is neglectful to not clean below the gumline in a routine dental prophylaxis (cleaning). Logistically, during an appointment when will the dr be able to come in, do a complete medical history review, periodontal assessment, oral cancer screening, periodic exam and remove subgingival deposits? The drs are stretched thin with their time as is, so when will they have the time to thoroughly do all those assessments? Hygienists go through thousands of hours of clinical training (not to mention 2 years of prerequisites) and boards to be able to do our jobs. When is the dentist going to have time to train this assistant? Then they just have to do 20 scalings, judged by the dentist, to then be able to work on the public? So no double blind formal board to determine they can actually do their job? No written board to determine they understand the science? Just the OK from the dentist? This is completed biased and not sound science. The board of dentistry also is excluded in the language of this document, so who is overseeing the certification of these OPAs? They set protocols and guidelines to protect the public and ensure proper care. Why is that not in this bill? This bill seems to just be rammed through without any thought given to the long term implications. There will be under diagnosis of disease & open up potential for lawsuits for dentists. There has been no scientific evidence that this model works. Do you want your constituents to be guinea pigs? The people of Virginia deserve better than lowering the educational standards of healthcare.

I oppose dental assistants and foreign dentists scaling for dental cleanings on the basis that they do not poses the adequate training or knowledge standards as deemed acceptable by CODA. This presents a health risk to the population.

Purpose of the bill is unclear. There are no formal guidelines. 70% of adults in our nation suffer from gingivitis or periodontal disease. That means many of you do as well. Supra vs. sub gingival scaling: supra is above the gumline and sub is below the gumline. To prevent oral diseases you have to scale below the gumline to remove calculus (tarter), plaque, bacteria and debris. This is where the oral disease process begin, under the gumline. The role of a hygienist is to treat and prevent oral disease. This can not be accomplished if subgingival scaling is not being utilized. We have other duties that we have been trained in, such as reviewing medical history, periodontal disease evaluation, patient education, oral cancer screening and infection control. Why is the Board of Denistry not involved to set guidelines? It seems as they have been purposefully excluded. They set protocols and guidelines to protect patients, our community. There has been a drastic shift to corporate dentistry from privately owned, 80/20 to 60/40. This is a potential segue for corporate dentistry to exploit ODA causing decreased patient care and higher prevelance of oral disease. What type of precedent will this set for other healthcare fields in VA? What other short cuts will be proposed that will compromise patient care? How do we guarantee that dentist that are supervising the assistant are actually doing it? Who will over see and audit this? There has been no scientific evidence that this model works. Only 2 states have used this model and it has not been effective. Malpractice lawsuits will increase due to negligence in diagnosing periodontal disease. I do agree with allowing foreign dentist to practice as hygienist is a great ideas as long as they can pass the national and clinical board and go through the licensing procedure set by the Board of Dentistry. I can see this bill allowing access to care in rural areas mostly in the pediatric setting, but we should be working with the board to have protocols and guidelines to protect the patients.

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. 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. A clear misconception is that some scaling above the gumline is better than no scaling. Contrary to what was said in the meeting, it is harmful to have only supragingival deposits removed. When buildup is removed above the gumline it causes the gums to tighten around the tooth and traps remaining bacteria below the gumline. This entrapment is what leads to the exacerbation of preventable and manageable disease. Periodontal disease has been linked to a multitude of systemic health conditions. Oral health is a key contributor to overall health, but most of what demonstrates true oral health is what is going on below the gumline. Allowing any patient to have only supragingival scaling will prove detrimental to their health. I have seen first-hand the implications of supragingival only scaling - exacerbated disease that leads to more involved, expensive treatment and loss of teeth that could have been prevented. Dental hygienists have the education and knowledge to properly evaluate and plan for care of patients who have oral health concerns, are able to educate patients about the different options they have to get their oral health back on track, and are able to provide that important care after their patients have the information they require to make informed decisions. A preventive dental assistant will not have that same educational ability to discuss these aspects of care with patients because they will not have been held to the same educational standards as dental hygienists. Putting our patients in the hands of someone who is not prepared because they do not understand the consequences of their actions is unacceptable. As health care providers, it is our job to protect the health and safety of the public. Allowing preventive dental assistants to scale above the gumline would not protect the health or safety of patients - it would be contributing to active harm. 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. The preventive dental assistant model will lead to higher rates of undiagnosed oral disease, negatively impact systemic health in many individuals, lead to higher rates of tooth loss, and put the public in harm's way. 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.

Good day. I’m a practicing registered dental hygienist and I oppose this bill that allows for a dental assistant to receive a certificate to be able to scale people’s teeth. I spent four years educating myself in the applied science field. I spent an additional two years in a dental hygiene program. I’ve learned head and neck, anatomy, oral cancer, screenings, periodontal, disease, detection, histology and pathology. There is more to my job than just scaling plaque off of teeth. A dental assistant and a certification program will not teach the vital responsibilities of dental hygiene and patients will suffer. This is a direct slap in the face to my profession and to the whole dental community. And I speak with direct knowledge I was a dental assistant for six years before I went to dental hygiene school. Even after I graduated dental hygiene school, I have spent countless hours educating myself on periodontal disease and attending dental continuing education so that I am always providing my patience with the best care possible. I asked that you please reconsider this bill and vote no!! Thank you for your time and attention to this very important matter.

background data on other states that have rejected this legislation, new follow update on another state that shows access to care did not increase and reasons why behind the workforce shortage. Solutions are needed and briefly introduced.

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 oppose HB970. They claim this will give people better access to care. If you are okay with the people of Virginia getting access to substandard, poor care, then sure. We deserve better than this!!

As a dental hygienist with a bachelor's degree, this would create a significant risk to our patients health. 1. Simply removing calculus above the gumline is not the standard of care. Deposits left subgingivally will continue to cause periodontal disease. 2.Rarely when scaling, can calculus above the gum line be removed without going subgingivally to remove the deposit. 3.We are educated on disease prevention, and oral and systemic health,. There is an abundance of research that shows the oral bacteria that causes Periodontal disease is also connected to heart disease, dementia/alzheimers, preterm labor, among other illnesses. We don't just clean the calculus off teeth. We restore oral health and allow tge patient to have better overall health 4 Even the VDA president states that a hygienist would still have to see the same patient as the assistant to remove subgingival deposits. How is this going to help?

Dear House Health and Human Services, Subcommittee on Health Professions, I strongly oppose HB970, After examining the language of the bill, on line 66, the bill requests that regulations promulgated by the Board of Dentistry be exempt. This means that the current regulations established by the Board of Dentistry would not apply to Preventive Dental Assistants. This exemption raises concerns regarding consistency and patient safety. If passed, the bill would create three categories of dental assistants: • DENTAL ASSISTANT I (NO SPECIFIC FORMAL EDUCATION OR STATE REGISTRATION IS MANDATED, MUST WORK UNDER DIRECT SUPERVISION OF A LICENSED DENTIST) • DENTAL ASSISTANT II (ACTIVE CERTIFICATION AS A CERTIFIED DENTAL ASSISTANT FROM DENTAL ASSISTING NATIONAL BOARD, COMPLETE A CODA -ACCREDITED DA II PROGRAM, REGISTRATION WITH THE VIRGINIA BOARD of DENTISTRY. • PREVENTIVE DENTAL ASSISTANT (NO SPECIFIC FORMAL EDUCATION, NON-CODA ACCREDITED, NOT DANB CERTIFIED) Additionally, this bill requests that the Preventive Dental Assistant be permitted to perform the same duties as both DA I and DA II. This expansion of duties, combined with the exemption from the Board of Dentistry regulations, warrants scrutiny and should be halted. Melvena J. Peace, Registered Dental Hygienist

Letter provided in opposition to HB970 and HB1036

Please oppose HB970. Cleanings “above the gumline” are not cleanings at all. It’s basically having a patient pay to have their teeth brushed. It’s entirely cosmetic and does nothing to prevent disease. The hard deposits BELOW the gumline are what need to be removed to prevent disease. This is not just substandard care, it is negligence. This bill does not create even one more dental hygienist. It will push more out of the field. It’s bewildering to me as a dental hygienist that a dentist would find this acceptable at all. Perhaps this lack of appreciation for what we do has some impact on the workforce shortage.

Please see attached file: Re: Opposition to HB 970 – Protecting Patient Safety and Dental Hygiene Standards

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.

Please vote to oppose this bill. Cleaning only above the gum line even in healthy individuals is a disservice to their health. As a dental hygienist, there is not one single patient that I do not clean below their gum line. In a 1mm-deep gingival pocket there can be more than 10 billion bacterial cells. A healthy gingiva is 1-3 mm deep. That's a lot of infection left behind by above the gum line cleanings. For the health and safety of our community, please oppose HB 980.

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!

I am a registered dental hygienist in Roanoke, Virginia and I oppose HB970 due to concerns about patient safety and the quality of care. Licensed dental hygienists complete rigorous, accredited education programs that include extensive clinical training, courses in anatomy, pathology, infection control, and more. These courses are then followed by national and state licensure examinations. This level of preparation ensures hygienists can safely perform scaling and identify oral disease, training that far exceeds the limited requirements proposed for preventative dental assistants under this bill. Oral health is closely linked to overall health. Periodontal disease is associated with conditions such as diabetes, cardiovascular disease, and chronic inflammation. Allowing individuals who have a lack of sufficient training to perform preventive procedures risks improper care and may lead to undetected disease and negatively impact systemic health. Dental scalers are sharp instruments that require advanced clinical skill and judgment. Improper use can cause injury to the gingiva, enamel, and surrounding tissues. Additionally, many individuals experience dental anxiety and rely on the trust that their care is being provided by a licensed, highly trained professional. Allowing preventive procedures to be performed by those who are not properly trained may undermine patient confidence and discourage people from seeking necessary care. For these reasons, I oppose HB970. Patient safety and high standard of care must be prioritized. Thank you for your time.

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 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 SB178, which would allow dental assistants to perform dental hygiene services through on-the-job training.  Dental hygienists complete accredited education programs providing extensive knowledge regarding anatomy and physiology, head and neck and dental anatomy, radiology, local anesthesia, periodontics, pathology, pharmacology, public health, medical emergencies, and many other aspects of clinical care. In order to obtain licensure, we must pass national, state, and clinical board examinations and meet ongoing continuing education requirements for the rest of our career. On-the-job training cannot replace this level of education or clinical preparation. Dentists are restorative professionals, not trained to educate in the preventative services of dental hygiene, and most offices lack the resources to provide adequate training.  The bill's 1,800-hour requirement is misleading, as it does not ensure experience in direct dental hygiene services such as scaling with hand or mechanical instruments- the primary skills the bill seeks to expand.  Lowering education and licensure standards puts patient safety at risk and can lead to missed disease, incorrect diagnostics, and incomplete, negligent care. Workforce shortages, especially those in healthcare, should never be addressed by reducing professional standards, and ignoring years of education and professional training.  I respectfully urge you to oppose SB178 and support policies that protect public health and patient safety.  Sincerely, Jada Keene

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 in opposition of HB970 that is trying to be passed. As a proud Dental Hygienist and that has a bachelor’s degree in Dental Hygiene for the past almost 12 years, I do not believe this bill is increasing “access to care.” It is doing the exact opposite! You are increasing the risk of periodontal disease, patient injury, malpractice, and insurance fraud. I understand a dental assistant will not be able to “scale” subgingival (beneath the gum line) so my question is how will this help provide more access to care for patients when they will be leaving calculus and bacteria in the sulcus (pocketing around the tooth), increasing the risk of a periodontal pocket around the tooth (inflammation or bone loss around the tooth, depending on the extent), or even a periodontal abscess. Patient injury is a concern of mine for the fact I spent two years learning and studying instruments. I was taught and tested on instruments on typodonts and then on human patients. So how do you think 120 hours of an assistant learning how to scale from a dentist who only spends about 6 weeks learning to scale themselves in dental school (which that is current criteria not criteria from 40+ years ago when some current dentist learned) is enough time for someone to learn correct instrumentation not to injury a patient? Or how will they even know enough to decide what instrument to use! And due to this, do you think there would be more malpractice lawsuits due to if they do preform subgingival scaling, injure a patient, or a patient develops severe periodontal disease due to the lack of subgingival scaling and periodontal charting (measurement of gum health). Plus, will an assistant have to state they are in fact an assistant and not an actual licensed hygienist performing their prophylaxis? Will they be told they can scale but not beneath the gum line? As a patient, I would want to know! Would you want to see and have a “cleaning” from someone that cannot even preform what you came to the appointment for but that is what you will receive. Are you afraid of insurance fraud? Don’t you think practices are going to take advantage of this situation and code out for a prophylaxis but that isn’t the procedure that is actually preformed. I believe you are setting Virginia’s dental access to care at even more risk because this situation is really going to make actual licensed Dental Hygienists question their career. I believe and I have heard from many other hygienists that this bill is very demeaning and will think long and hard about if this is what they will tolerate because their work has been demoted! I myself put a lot of hard work, long study hours, and a lot of money, which I am stilling paying off, in my schooling so I could have the career I always wanted. I think you will see more hygienist leave the field just like they did after coming back to the office after Covid due to the stress, changes, and burn out we endured. I hope this bill is thought on really hard because I believe this a a huge mistake! If this bill is passed I would assume in five to ten years there will be a huge increase of lack of patient care, lack of licensed hygienist, and lost of trust from patient and provider! I hope you listen to our considers that we have in protecting our careers and trying to protect our patients!

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.

I am a licensed dental hygienist and certified dental assistant in Virginia and I greatly opposed HB 970. Dental assistants in Virginia do not have to complete any certifications to become one, and while I attended a CODA certified program to obtain my CDA (which most dental assistants do not), I can say wholeheartedly I would have been a horrible hygienist if I was trained to perform “supragingival” scaling on the job. The fact of the matter is, there is no such thing as “supragingival scaling”. Every patient that I see in my chair, including children as young as 5, I have had to subgingival scale. I have seen the detrimental effects to patients periodontal status that have been treated by those that have not had proper hygiene training, including dentists (who only get minimal hygiene training in school) and those that have been overseas from prophylaxis that had not scaled subgingival and left behind calculus deposits that caused bone loss and tissue damage, or periodontal disease. I understand there is a shortage of hygienists in Virginia, but the patients will suffer greatly if this bill is passed. Periodontal disease is irreversible and has a plethora of health impacts including increased risk of heart attack, stroke, Alzheimer’s disease, colon cancer (as the bacteria that live in our mouths contribute to these) as well as many other co-morbidities. If someone who is not even trained to understand basic infection control (as dental assistants in Virginia are not required to) how to complete a head and neck exam, or understand complex medical history, how will they know what bacteria causes periodontal disease, or the science behind what they are doing to a patient to educate the patient on their oral health? Given the absolutely devastating effects to the unknowing patients that this bill could cause, I please ask you to oppose this bill. Makenzie Green, RDH, CDA

I am a licensed dental hygienist in Virginia, and I respectfully oppose HB 970. HB 970 expands the role of preventive dental assistants to include supragingival scaling; however, this does not reflect the clinical reality of patient care. The majority of dental patients require subgingival (below-the-gumline) treatment to properly manage periodontal disease. Supragingival scaling alone addresses only part of the disease process and often results in incomplete care. Dental hygienists are specifically educated, licensed, and trained to assess periodontal conditions and provide comprehensive preventive treatment, including subgingival debridement. Expanding limited above-the-gumline services while maintaining restrictive practice models for hygienists does not improve access to care — it lowers the standard of care and delays appropriate treatment for patients. If the goal is to improve access and public health outcomes, legislation should focus on fully utilizing licensed dental hygienists within their education and scope, rather than expanding partial care through less extensively trained roles. For these reasons, I urge the committee to oppose HB 970. Ke’Annah Baldwin, RDH Glen Allen, VA

My name is Katherine Bigoney, RDH. As a trained hygienist who spent two years training to provide safe, appropriate clinical care, this bill would be of great detriment to the overall patient population. The intensive training we receive and board certification that is required to perform our duties is not something that could be quickly obtained on the job. HB970 should not be passed. Thank you for your time.

I am a licensed, practicing dental hygienist of 16 years and I oppose HB970. I display my bachelor’s degree with pride, and my license represents the education, clinical training, and national and written board examinations I successfully completed to earn it. Dental hygienists are college-educated, licensed healthcare professionals trained in prevention, early disease detection, and patient education. Allowing unlicensed or on-the-job trained individuals to perform dental hygiene procedures threatens to lower the standard of dental care in Virginia. This is not about titles, roles, or access to care—it is about patient safety, quality treatment, and protecting preventive care and allowing people that do not have the proper education will not help patients. Patients deserve more than "on-the-job training" when it comes to their oral and systemic health. Failure to properly clean below the gumline directly impacts periodontal health, alters disease progression, and causes real harm to patients. Prevention requires education, skill, and licensure—and anything less puts patients at risk. Beyond clinical concerns, HB970 introduces serious insurance, billing, and legal risks. Because “Preventative Dental Assistants” cannot perform a complete prophylaxis, clinics would be unable to bill use the proper CDT code. Instead, they must rely on the “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 or even, insurance fraud. 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 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 HB 970 and ensure that Virginia continues to uphold policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your time and consideration.

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

Hello! My name is Katarina Farmer, I am a registered dental hygienist based in Troutville, Virginia. I am writing to ask that you vote no on SB178/ HB970. As a Registered Dental Hygienist (RDH), I received two years of supervised preventative clinical training prior to being allowed to work with the public. Clinical and didactic training was supervised by another RDH, and consisted of extensive education in pathology, pharmacology, head and neck and oral anatomy, local anesthesia, nutrition, medical emergencies, working with all special needs considerations, and much more. I had to pass National, state, and clinical board examinations, and have to take a minimum of 15 continuing education hours per year to maintain my licensure. SB178’s training requirements are quite unclear and suggest the PDA would be supervised by a dentist, a member of the dental team NOT trained in preventative services, and often who doesn’t have time to provide one on one training hours. The bill suggests these assistants would be providing “coronal polishing and supragingival scaling”. These are not therapeutic services aimed at the prevention of disease. Coronal polishing is essentially brushing your teeth with a spin brush, it is a cosmetic procedure that aids in the removal of loose plaque, or food debris, and the removal of some stain. It has no therapeutic benefit and is not encouraged for all patients, nor for every tooth every time.  Supragingival scaling, or cleaning only above the gumline, fails to remove bacteria that lives UNDER gum tissue. This bacteria I’m referring to has been scientifically linked to Alzheimer’s, Cardiovascular Disease, Stroke, Heart Attack, Infertility issues, and more. I’d also like to address that I’ve had extensive training on dealing with our population who have special needs and may experience medical emergencies in our chair. Will this new role you’re proposing receive the same in-depth training? Will they know what to do when their patient has a seizure in the chair? Will they know the certain tools and instruments they cannot use on a patient with a pacemaker? Will they educate the patients to the highest standards of care in tobacco cessation, oral hygiene education, proper methods of brushing and flossing, and be able to conduct an accurate oral cancer screening? Will patients even be made aware that their healthcare will be provided by an unlicensed person? Are you yourself, going to be comfortable letting your parents, siblings, spouses and children… receive this watered-down version of oral disease prevention? Especially those suffering from pre-existing medical conditions? This bill will allow unlicensed people with minimal education and understanding to use sharp tools and mechanical instruments that can gouge restorations, and cause irreversible tissue damage. I joined healthcare not for profit, but to benefit my community. I will always advocate for them to receive the highest standard of care. This bill is not a solution, it is lowering the standard of safe care and watering down critical healthcare roles. I am a preventative healthcare specialist, not a “tooth janitor”. I would love to be able to work with legislation and the VDA on suggestions to expand access to care in a safer manner while upholding education standards. I have emailed all delegates and senators, attempting to share this message best I can. Thank you for your time, most sincerely. Katarina Farmer, RDH

I am a Board Certified Periodontist specializing in Diagnosis & Treatment of gum disease and placement of Implants. I am a long standing VDA member. I have taught and lectured in 5 universities and have been a consultant to the Surgeon General for periodontal service, appointed to the Supreme Court of Virginia as a consultant for periodontal service and a consultant for Delta Dental for periodontal claims. More recently along with managing my periodontal practice in NN, I was an Adjunct Faculty for 40 years in the Periodontal Department at VCU School of Dentistry. I have taught undergraduate dental students and graduate students obtaining a Master’s Degree in Periodontology. My concerns with House Bill 970 are as follows: • Dental students have more time spent in the areas of dentistry other than periodontics; whereas dental hygiene students spend their entire education in dental hygiene topics related to diagnosis, physical assessment, pathology, treatment modalities, and recare. • The Dental Hygiene curriculum includes significantly more clinical hours for hygiene services than dental school curriculum. • The skill level of graduating hygiene students is superior to that of dental students regarding prophylaxis and periodontal maintenance. Dental graduates are not provided courses in teaching methodologies. The idea of a dental hygienist shortage needs a better solution then the current proposal of House Bill 970 . ADA evidence reports it as a dental hygienists’ retention issue that warrants study of challenging employment factors. What I know from over my 50 years of practice, the turnover of staff has only been with the dental assistants; therefore, a more serious shortage exists with that group of dental personnel. Utilizing a dental assistant, including the DA I the front desk receptionist with no formal education and no Board of Dentistry regulation to attempt to take the place of a licensed dental hygienist should never be adopted. How would a dentist who is required to provide DIRECT supervision to the current DAII, now provide Indirect Supervision to a DA I for scraping tooth surfaces while treating his own patients? Ask a dentist: would they be happy with this service in their mouth. I’m not sure that they wouldn’t prefer a dental hygienist even over another general dentist to provide their maintenance care. I would not consent to this fragmented, substandard care. I have worked diligently along with my team of dental hygienists, to obtain a healthy periodontium of my clients and I would not want an “on the job trained” auxiliary to attempt to maintain these fragile, now healthy patients. Without competent care, these clients could once again breakdown. This could present significant moral and legal issues. What about coding insurance coverage with this type of incomplete treatment, what about malpractice issues: remember that DA I and DA IIs do not have a license controlled by the Board of Dentistry which ensures public protection. Who is asking to have “cleaning” by one of these “tooth scrapers”? I urge you to protect the citizens of Virginia and vote NAY and stop House Bill 970, as well as SB 178. If these bills pass and are enacted as law, at your next dental visit make certain you ask to see the license of the person cleaning your teeth before consenting to any services. Barry Lee Green, DMD, MS Yorktown, Virginia 23692 docbgreen@verizon.net 757-503-1516

This testimony provides further evidence-based context related to the impact that SB178/ HB970 Preventive Dental Assistants (PDAs) will impose on marginalized communities in the Commonwealth of Virginia. This bill will significantly impact all Virginians because it does not promote comprehensive preventive dental care, will not address patients’ access to dental services, and threatens patient safety. PDAs are not a solution to the workforce shortage or access to care concerns. This proposed bill will cause a disruption to preventive dental care, jeopardize patients’ trust towards dental hygienists, and increase the burden of oral disease among Virginians. This is particularly concerning for marginalized groups who have encountered decades of manipulation and mistreatment in the U.S. healthcare and dental care systems. Ethnic and racial minorities are more likely to experience discrimination at healthcare facilities, which leads to a distrust in healthcare professionals and negative impacts on health, including oral health. In a national study that used the 2014 Behavioral Risk Factor Surveillance System (BRFFS) data, a survey of nationally representative U.S. adults, found that discrimination at healthcare facilities had the strongest association with tooth loss even after controlling for socioeconomic factors, health insurance status and dental services use [1]. Marginalized populations who already face barriers to accessing dental care should not receive substandard, inequitable care. In general, marginalized groups experience significantly more oral-systemic diseases such as periodontal (gums) disease and cardiovascular disease and Type II diabetes; dental caries and tooth loss than their counterparts. Periodontal disease: In total, 42% of U.S. adults aged 30 years and over have some form of periodontitis (gum disease). The greatest race and ethnic groups impacted by gum disease are non-Hispanic black (56.6%), Hispanic (48.5%), multiracial groups (46.2%) compared to non-Hispanic white (37.0%). In terms of socioeconomic level, the greatest prevalence (60.4%) of periodontitis was among those who reported a <100% FPL. Lastly, among those who reported having diabetes, roughly 60% had periodontitis [2]. Similar disparities are observed for dental caries among adults. Roughly, 51% of U.S. adults aged 20-64 years had untreated dental caries [3]. The oral health disparities paired with barriers to access to care continue to persist among racial and ethnic minority individuals. Allowing unlicensed, minimally trained, individuals to provide incomplete care will be detrimental to the health of Virginians, especially racial and ethnic minorities that are already at an increased risk for adverse health outcomes. It would be unethical and a disservice to Virginians to allow this model of proposed care. There are more effective alternatives to increasing access to dental care that do not impose health and safety risks. Lastly, I respectfully urge you to consider the health and safety of yourself, family, and friends. All Virginians deserve equitable, safe, high-quality care from licensed oral health professionals.

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.

Comments Document

Honorable Committee Members, I am writing to express my strong opposition to HB 970. It would allow dental assistants with on the job training to perform tasks belonging in 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. These also bills do not address the gap in the dental workforce because it does not create any new qualified providers. Please read my attached letter. Sincerely, Mirtill "Mimi" Magyar, RDH

Comments Document

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