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

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

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

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!!!!

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

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

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!!

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

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

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

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

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

I 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

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!!!

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.

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

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

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

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

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

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

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

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

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

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