Kính gửi bà Sacksteder và các thành viên Hội đồng Nha khoa:

In creating the regulatory framework and educational requirements for Dental Assistant IIs more than fifteen years ago, the Virginia Board of Dentistry (Board) considered over 1,000 public comments, convened an ad hoc committee of experts including representatives from the Virginia Dental Assistants Association, the Virginia Dental Hygienists’ Association, the Virginia Dental Association (VDA), and faculty from the CODA-accredited dental assisting program at J. Sargeant Reynolds Community College.  

In the petition to remove direct pulp capping from the duties that can be delegated to a Dental Assistant II (DAII), the Board has not demonstrated to the general public or communities of interest that there has been any harm caused to Virginia patients in the 15 years in which this procedure has been allowed.  

The Board has not provided any evidence of the inadequacy of the educational curriculum at Virginia’s two Dental Assistant II programs.  

The Board has not provided any indication that the current scope of practice of a DAII exceeds the intent of legislators who passed enabling legislation to create the position to help better address the oral healthcare needs of Virginians.  

The Board has not provided any indication that it has sought expert advice from the directors of the accredited programs in Virginia at which DAIIs can be educated or from any dental practices that employ the dental assistant IIs whose educational curriculum included direct pulp capping.  

Rather than proposing to amend educational standards to satisfy the board that a DAII can perform direct pulp capping safely, the Board’s actions instead suggest that DAIIs as a class of persons can no longer be educated to safely perform this procedure, which has been within their scope for 15 years.  

We ask the Board to bear in mind that a DAII practices under the supervision of a dentist.  If the dentist is concerned during a prep, he or she has the responsibility of intervening and treating that patient using their best professional judgement.   

Many direct pulp caps may be best placed by the dentist, but mainly so that the exposure is sealed as quickly as possible during the procedure.  Time is of the essence and, for fifteen years, appropriately trained DAIIs in Virginia have helped address exposures during the prep with four-handed dentistry, to allow them to be better isolated.  

The VDA asks the Board to reconsider this proposed regulatory amendment, which comes at a time when the Board is aware of well-documented shortages in Virginia’s dental workforce that impact access to essential dental care.   

Trân trọng,

Ryan Dunn

Tổng giám đốc điều hành, Hiệp hội Nha khoa Virginia