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 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.

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

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.

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.

Dental Hygienists should not be replaced with dental assistants or foreign dentists. There is a reason we went to school for four years to obtain a bachelors of science degree in dental hygiene as well as taking a state board, clinical board, and a national board. Not to mention thousands of dollars of student loans hygienists have to pay all to be replaced by someone who is not trained. It takes two years in the dental hygiene program to even learn the correct instruments to use. Putting assistants to scale will be neglecting our patients and causing lawsuits due to endangering our patients. Our instruments that we use are as sharp as kitchen knives having someone who does not go through dental hygiene course to use properly will be putting patients at risk of hurting them. Not to mention every prophy that I’ve done you have to go subgingival to collect all the tartar and bacteria underneath the gums. This will lead to more periodontal issues for our population if hygienists are not completing these cleanings. Please do your research and educate yourself of the important of treating our patients with the proper care by only allowing dental hygienists to scale!!!!

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.

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.

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 adamantly opposed to this Bill. It is our ethical responsibility as healthcare professionals to uphold the highest standards and practices. If this Bill passes, the standard of care for Virginia's patients with DECREASE. I understand that there is a shortage of Dental Hygienists, and this is one idea that would help to alleviate this problem, But this idea is not ideal for many reasons. 1 - There is a shortage of Dental Assistants too 2 - I have yet to meet an Assistant that WANTS to be trained to do this 3 - Cleaning only above the gum line will turn a routine cleaning from a health procedure into a cosmetic one 4- These Scaling Assistants are not allowed to practice without a Dentist in the office. So, thinking that these new Assistants will help provide care for our underserved population is not a reality. 5 - Cleaning only above the gum line is like cleaning your pool, but only above the water line. The bacteria and slime are located under the water line, so you couldn't really call your pool 'clean'. The same goes for dental cleanings. Plaque is composed of mostly harmful bacteria. It is a living thing. It wants to survive, so it "hides" under the gum line. Left undisturbed, it multiplies and attacks and destroys the gum and bone. Dental plaque has a direct line into the blood stream. It circulates throughout the entire body all day every day. Dental plaque has been found in the plaque on the brains of dementia patients. Dental plaque has been found in breast cancer tumors. Dental plaque has been found in the plaque lining our arteries. The list goes on and on. Like I said, dental cleanings are a Health procedure. My last concern is for the enforcement of this. I hold Hygiene licenses in other States as well as Virginia. (I have family that live in other States and you never know what life will throw at you and if I might need to relocate), I can tell you that Virginia Dental Board is the most lax that I have encountered. The ONLY required CE course in VA is CPR. How about the most important course - infection control and OSHA?? The EASIEST thing to monitor is our required continuing education. In other States, I have to show proof of my compliance and there are random audits. The required CE courses are a lot more stringent also. In Virginia, I go online, I am asked if I have completed my required CE courses, I click a button that says "yes" and then am directly sent to pay the fee. There has to be more enforcement of our laws and regulations. I know of a pediatric office in Virginia Beach where the Dentist has been allowing his assistants to do teeth cleanings. And this Bill hasn't even passed yet!

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 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.

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

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.

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

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.

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.

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.

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.

As a licensed dental hygienist, I strongly oppose any proposed legislation that would allow dental assistants to be certified in supragingival scaling. Supragingival scaling is not a simple, isolated task. It is one component of a comprehensive preventive and periodontal assessment that requires extensive education, clinical training, and critical thinking. Dental hygienists complete rigorous coursework in anatomy, periodontology, pathology, pharmacology, radiology, and patient assessment—along with hundreds of supervised clinical hours and national and clinical board examinations. We are trained not just to remove deposits, but to evaluate tissue health, detect disease, identify contraindications, assess systemic links, and determine when treatment must change. What may appear to be “just supragingival calculus” can indicate underlying periodontal disease, systemic inflammation, medication-related gingival changes, or other pathology. Recognizing and appropriately responding to those findings is what protects patients. Not to mention it is not as easy as it may look and untrained assistants can seriously injure the patient. Dental assistants are essential members of the team, but their education and licensure are not equivalent to that of a dental hygienist. Expanding their scope to include procedures rooted in periodontal therapy blurs the distinction between supportive and licensed clinical roles and lowers the professional standards established to safeguard the public. This is not about protecting turf, it is about protecting patients. When scope of practice expands without equivalent educational requirements, quality of care and patient safety are at risk. If scaling “just above the gum line” is important enough to be performed, it should be performed by a provider who is comprehensively trained and licensed to assess, diagnose within their scope, and treat periodontal conditions appropriately. This proposal also creates an unnecessary and uncomfortable experience for patients. Having one provider perform supragingival scaling and then requiring a second provider to scale below the gum line means patients may endure instrumentation twice in a single visit. Not only is this redundant, but it also increases discomfort, sensitivity, and chair time. Patients expect streamlined, comprehensive care from a qualified clinician who can assess and treat their periodontal needs in one continuous appointment. Fragmenting scaling between providers does not enhance efficiency or comfort; it creates confusion, prolongs treatment, and places the burden of an impractical system directly on the patient. Diluting educational standards does not improve access to care; it lowers the bar of care. This proposal is not a meaningful solution to the dental hygienist shortage. Instead, it risks creating fragmented treatment and additional complications that already overextended hygienists will ultimately be responsible for correcting. For the integrity of the dental hygiene profession and, most importantly, for the safety and well-being of our patients, I strongly urge lawmakers to reject this proposal.

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 a Virginia licensed dental hygienist and Certified Dental Assistant. I oppose this 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

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.

Only registered dental hygienist should be able to provide such services

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

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

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!!!

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

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.

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!

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

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

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

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 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.

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.

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.

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

I strongly oppose SB 178. I worked as a registered dental hygienist for 42 years. The problem with dental assistants preforming removal of supragingival scaling is what happens to the subgingival calculus. The dentist is not going to come in and remove all of it. My father was a dentist and he always asked what is in the best interests of the patient. I can tell you that passing this bill is not in the best interest of the patient. Dental hygienists begin with reviewing or updating the patients medical history, taking any X-rays necessary , doing an oral cancer exam, periodontal probings to assess subgigival calculus, removing Supra and sub gingival calculus, providing oral hygiene instruction, checking the occlusion. Dental hygienists do not just clean teeth. Please do not pass this bill.

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.

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

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

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!

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

I oppose both of these bills!

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.

Do not pass this bill. This is gross neglect and will not benefit anyone especially patients. Dental hygienists help with treatment and prevention of oral diseases that can also affect overall systemic health. We are healthcare providers and educators not just scalers.

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

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.

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.

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?

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 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.

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

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 clinician and dental hygiene educator, I strongly oppose SB178, introduced by Senator Locke, which seeks to expand the duties of dental assistants in Virginia to include supragingival scaling and coronal polishing through a certification pathway. From both clinical practice and academic instruction, I can state unequivocally that supragingival scaling and coronal polishing are not merely cosmetic procedures. They are preventive and therapeutic clinical interventions that require comprehensive education in oral pathology, periodontal disease progression, radiographic interpretation, medical history assessment, pharmacology, infection control, and the ability to recognize contraindications and complications. Dental hygiene education is not limited to technical instrumentation skills. It is grounded in critical thinking, risk assessment, evidence-based decision-making, and the ability to identify underlying periodontal and systemic conditions that may present during preventive care. These competencies cannot be replicated through abbreviated certification training. Allowing individuals without full dental hygiene education to perform scaling procedures fragments care and creates a significant public safety concern. Scaling without the depth of knowledge necessary to recognize periodontal involvement, oral pathology, medically complex conditions, or emerging disease increases the risk of missed diagnoses, delayed treatment, and patient harm. Substandard or incomplete preventive care does not simply affect the mouth—it affects the entire body. The scientific evidence is clear that oral inflammation and periodontal disease are associated with systemic conditions such as cardiovascular disease, diabetes complications, adverse pregnancy outcomes, and respiratory disease. When preventive services are delivered without comprehensive assessment and disease management, chronic oral disease can progress unchecked, increasing inflammation, worsening systemic health conditions, and ultimately raising long-term healthcare costs. Inadequate scaling and failure to identify early periodontal disease can accelerate tissue destruction and contribute to a cycle of chronic oral infection that impacts overall health. As an educator, I am deeply concerned about lowering the standard of care in a way that suggests these procedures are simple tasks rather than integral components of comprehensive clinical assessment and disease prevention. As a clinician, I know firsthand that what appears to be “supragingival” often masks underlying subgingival pathology requiring skilled evaluation and intervention. Virginia has long upheld high standards to protect the public. Expanding scope of practice without equivalent educational rigor diminishes those standards and prioritizes workforce substitution over patient safety. Access to care must never mean incomplete care. The citizens of Virginia deserve providers who are fully educated, licensed, and trained to deliver comprehensive preventive services—not a two-tiered system that risks increasing chronic oral disease and negatively impacting systemic health outcomes. For these reasons, I strongly urge rejection of SB178. Patient safety, quality of care, and long-term public health must remain the priority.

As a health professional myself I find having to have this conversation absurd. Everyone stay in your own lane. Would you want a CNA pulling chest tubes or placing a PICC line on you? Would you want a nurse doing brain surgery? These dental hygienist go through lots of training and are trained to watch out for other health issues. While assistants have their important roles and are appreciated, they do not have the same expertise.

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.

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.

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.

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.

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!!

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 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.

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.

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

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

This is a ridiculous proposal

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 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 urge you to OPPOSE Senate Bill 178 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.

Your health is not a shortcut. As a dental professional, I am deeply concerned and frankly appalled by the proposed legislation in Virginia that would allow dental assistants with minimal training to perform duties currently reserved for Registered Dental Hygienists. This proposal suggests that the years of scientific education, clinical mastery, and rigorous board examinations required to become a licensed hygienist can be replaced by a short training course. That is not a workforce solution — it is a patient safety risk. Why this matters to every Virginia patient The Mind–Body Connection Dental hygienists are trained to detect oral cancer, periodontal disease, and signs of systemic illness such as diabetes and cardiovascular disease. This diagnostic skill is not learned in weeks — it is built through years of formal education, clinical experience, and licensure testing. Clinical Safety Procedures such as scaling, root planing, periodontal charting, and patient assessment are invasive medical procedures. Without comprehensive education in anatomy, pathology, pharmacology, and infection control, the risk of permanent tissue damage, untreated disease, and infection rises significantly. Integrity of Care Patients assume that the person performing preventive and periodontal treatment is a licensed healthcare professional. Allowing undertrained personnel to perform these duties undermines trust and lowers the standard of care across the Commonwealth. Virginia should not respond to workforce challenges by lowering clinical standards. Instead, we should invest in education, workforce development, and access-to-care solutions that maintain patient safety. I urge you to oppose this legislation and stand with patients, licensed professionals, and the integrity of healthcare in Virginia. Do not allow Virginia to trade patient safety for a cheaper bottom line.

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 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.

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 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.

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 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.

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.

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!

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.

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

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 writing to express my strong opposition to HB 970, which would allow dental assistants with on-the-job training to perform duties that fall within the scope of licensed dental hygienists under the proposed “Preventive Dental Assistant” model. This legislation represents a significant step backward for oral healthcare in Virginia, as it does not adequately prioritize patient safety or the education and clinical competencies required for safe, evidence-based dental hygiene care. Procedures such as scaling require advanced instrumentation skills, comprehensive assessment, and critical clinical judgment. These competencies are taught exclusively in Commission on Dental Accreditation (CODA)–accredited dental hygiene programs and are performed by licensed dental hygienists. Allowing unlicensed personnel to perform these procedures places patients at risk and undermines the integrity of the dental hygiene profession. Beyond the clinical concerns, HB 970 introduce serious insurance, billing, and legal risks for dental practices. Because “Preventive Dental Assistants” are not qualified to perform a complete prophylaxis, practices would be unable to bill under the D1110 code. Instead, they would be forced to 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. These scenarios expose practices to insurance disputes, audits, and potential allegations of fraud. When unlicensed personnel perform procedures outside their legal scope, any resulting claims submitted to insurers—including Medicaid—may be considered inaccurate or misleading. This places supervising dentists and practice owners at risk of violations under the False Claims Act, which carries severe civil penalties, repayment obligations, and reputational damage. These risks have been clearly documented by the American Dental Hygienists’ Association and should not be ignored. If enacted, HB 970 would lower professional standards, compromise patient safety, and expose Virginia dental practices to unnecessary legal and financial liability. The most effective, 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 “Preventive Dental Assistant” model introduces substantial risk without delivering meaningful benefit. As a licensed dental hygienist in Virginia, I see firsthand how deeply this issue affects both our profession and the patients we serve. I respectfully urge you to oppose and HB 970 and to support policies that prioritize quality patient care, legal compliance, and professional standards. Thank you for your time, service, and consideration.

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.

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

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.

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.

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.

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.

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.

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