Full Potential: Why Dental Hygienists Must Work to the Top of Their Abilities

In the complex world of healthcare, the role of the Registered Dental Hygienist (RDH) is often misunderstood and, more critically, underutilized. These highly trained, licensed professionals are the backbone of preventive oral healthcare, playing a crucial role in maintaining public health and well-being, yet a large percentage of them have left the workforce or are considering it, due to burnout, compensation issues, and lack of autonomy in their practice decisions. Across many jurisdictions, RDHs find their capabilities constrained not by their education or skill, but by a labyrinth of regulations that often seem to serve interests beyond patient care. This article argues that RDHs must be empowered to work to the full extent of their abilities, free from limitations imposed by outside governing bodies who may, intentionally or unintentionally, benefit financially from restricting their scope of practice.

The Current Landscape: A Patchwork of Restrictions

The scope of practice for Registered Dental Hygienists is far from uniform. It is, in fact, a complex and often contradictory patchwork of regulations that varies significantly from state to state, and even country to country [2]. While the core responsibilities of an RDH generally include preventive care, treatment of periodontal disease, and patient education, the specifics can differ dramatically [1].

For instance, some states permit RDHs to perform procedures such as the placement of subgingival agents, periodontal therapy, and even initial examinations of teeth and surrounding tissues, without supervision of a dentist [1]. However, these hygiene procedures are not universally allowed, leading to a situation where a highly skilled RDH in one state might be legally prohibited from performing a procedure that their equally qualified counterpart in a neighboring state routinely executes. This disparity is often governed by the level of supervision required, with some states allowing general supervision (where a dentist does not need to be physically present) while others mandate direct supervision [1].

These regulations are primarily determined by state dental boards, which are governmental agencies established by state legislatures [1]. The composition of these boards is critical to understanding the regulatory environment. Our research reveals a consistent pattern: dentists hold a significant majority on these boards, outnumbering dental hygienists by a substantial margin. For example, the Louisiana State Board of Dentistry has 13 dentists and only 1 dental hygienist, with no public members. Similarly, the Georgia Board of Dentistry comprises 13 dentists, 2 dental hygienists, and 1 consumer member [3]. Even in states with more balanced representation, such as Colorado (6 dentists, 3 dental hygienists, 3 public members), dentists still constitute the largest professional group [3].

This disproportionate representation raises immediate questions about potential biases in regulatory decision-making. When the majority of a regulatory body consists of members from one profession, there is an inherent risk that regulations may be shaped to protect the economic interests of that dominant group, rather than solely focusing on public health needs or optimizing the utilization of all dental professionals. This structural imbalance sets the stage for the financial conflicts of interest that often underpin the limitations placed on RDHs.

Beyond Safety: Unmasking the Financial Motives

When discussions arise about expanding the scope of practice for dental hygienists, the argument of patient safety is frequently invoked as the primary justification for maintaining restrictive regulations. While patient safety is, without question, paramount in healthcare, a closer examination reveals that this argument often serves as a convenient veil for underlying financial motivations and conflicts of interest within the dental profession.

Evidence strongly suggests that organized dentistry, primarily represented by dental associations, engages in significant lobbying efforts to influence legislation and regulatory policy. The American Dental Association (ADA), for instance, actively advocates for what it deems "matters to dentists and their patients," and its lobbying accomplishments are publicly documented [12]. More pointedly, reports indicate that dental societies have spent substantial sums on lobbying to influence policy, with one dental society spending over $55,000 on lobbying activities within a few years [4]. These efforts are not merely abstract; they directly impact the legislative landscape that defines the RDH scope of practice.

This lobbying is often directed at preventing the expansion of RDH duties. A telling example is the direct opposition from dentists to states' efforts to create mid-level dental providers. The stated reason for this opposition is often "safety" [5]. However, this claim becomes questionable when juxtaposed with the economic realities of dental practice. Studies have consistently shown that dental practices that effectively utilize expanded function allied dental personnel, including RDHs, tend to treat more patients, generate higher gross billings, and achieve greater net incomes [7]. Furthermore, investing in preventive dental hygiene services leads to overall healthcare cost savings for consumers [8].

These findings present a compelling counter-narrative to the safety argument. If expanding the RDH scope of practice leads to increased productivity, improved access to care, and cost efficiencies, then why the persistent resistance? The answer, as articulated by some within the profession, is that "Economic systems shape dental policy more than clinical intentions do. Organized dentistry suppresses hygienist autonomy to maintain financial interests [6].” This powerful statement suggests that the limitations placed on RDHs are not primarily about their competence or patient safety, but rather about protecting the economic territory of dentists.

The disproportionate representation of dentists on state dental boards further compounds this issue. With dentists holding a clear majority on most regulatory bodies, there is an inherent structural conflict of interest. These boards, responsible for defining and enforcing the scope of practice, are largely composed of individuals whose financial interests could be directly impacted by the expansion of RDH autonomy. This creates an environment where regulations may be designed or maintained to safeguard the financial well-being of the dominant professional group, even if it means underutilizing a highly skilled workforce and potentially limiting public access to affordable dental care.

Therefore, while patient safety is a legitimate concern, it is crucial to critically evaluate whether it is genuinely the sole or primary driver behind current RDH scope of practice limitations. The evidence points to a significant influence of financial incentives and professional self-interest, which often manifest as resistance to change and the perpetuation of restrictive regulations.

Highly Trained, Underutilized: The True Capabilities of RDHs

The argument that limiting the scope of practice for Registered Dental Hygienists is necessary for patient safety often overlooks the rigorous and comprehensive education and training that these professionals undergo. Far from being dental assistants (who have limited or no educational requirements), RDHs are highly skilled, licensed clinicians equipped with a deep understanding of oral health, disease prevention, and therapeutic procedures.

To become an RDH, individuals must complete an accredited dental hygiene program, typically an Associate's Degree, though many pursue Bachelor's or Master's degrees [9]. These programs, usually lasting two to three years, are far from superficial. Their curricula encompass a broad range of subjects, including general education, foundational sciences, and specialized dental courses such as dental anatomy, oral pathology, and radiography [9]. Crucially, a significant portion of their training is dedicated to dental hygiene science, covering oral health education, preventive counseling, and patient management [9].

Beyond theoretical knowledge, RDH education emphasizes extensive clinical instruction. Students gain hands-on experience in laboratories and real-world clinical settings, often in small group environments, ensuring practical proficiency [9]. This rigorous training culminates in mandatory national and regional board examinations, which assess both written knowledge and clinical skills, ensuring a standardized level of competency across the profession [9].

Furthermore, many RDHs pursue additional certifications and training in public health and expanded functions, demonstrating their commitment to continuous learning and advanced practice. For instance, the administration of local anesthesia is a common expanded function for which RDHs receive specific, accredited training and must pass dedicated clinical examinations [10]. Similarly, many RDHs are trained and certified in restorative procedures, such as placing and finishing fillings. Programs offering this training are often extensive, involving dozens of hours of didactic and laboratory instruction, exceeding state board requirements [11]. The American Dental Hygienists' Association (ADHA) actively advocates for RDHs to perform these restorative services, underscoring their confidence in the hygienists' capabilities [1].

When the full scope of an RDH's education and training is considered, the "safety" argument for restricting their practice begins to unravel. RDHs are not only trained to perform a wide array of preventive and therapeutic procedures but are also assessed through stringent examinations to ensure their competence. Their expertise in areas like periodontal therapy, oral disease screening, and patient education is foundational to public oral health.

It is important to distinguish between a comprehensive dental diagnosis, which is the purview of a dentist, and a dental hygiene diagnosis. RDHs are trained to assess and identify patient needs related to oral health and hygiene, allowing them to develop and implement appropriate care plans within their scope of practice. This distinction highlights their ability to make informed clinical judgments and manage patient care effectively.

In essence, the skills and knowledge possessed by RDHs are often far greater than what current regulations permit them to utilize.  By limiting their ability to perform procedures for which they are demonstrably trained and competent, regulatory bodies are not only underutilizing a valuable healthcare resource but also potentially hindering access to care, particularly in underserved areas. The safety argument, while superficially appealing, often fails to account for the depth and breadth of an RDH's professional preparation.

The Path Forward: Advocating for Autonomy and Access

The current regulatory landscape, characterized by restrictive scopes of practice and potential financial conflicts of interest, creates a significant barrier to optimizing oral healthcare delivery. To truly unleash the full potential of Registered Dental Hygienists and improve public health outcomes, a fundamental shift in perspective and policy is required. This shift must prioritize patient access to care and the efficient utilization of highly trained professionals over the protection of narrow economic interests.

1. Reforming Regulatory Boards Through Antitrust Concerns: A critical first step is to address the imbalanced composition of state dental boards. Regulatory bodies should reflect the diversity of the dental profession and include a more equitable representation of dental hygienists, as well as independent public members who can advocate solely for consumer interests. This would help mitigate conflicts of interest and ensure that regulatory decisions are made with a broader perspective on public health needs, rather than being dominated by the interests of a single professional group. Furthermore, the legal landscape surrounding dental boards has been significantly shaped by antitrust concerns. The landmark Supreme Court case North Carolina State Board of Dental Examiners v. FTC (2015) established that state occupational licensing boards, when composed predominantly of market participants, are not immune from antitrust laws unless actively supervised by the state [3, 13, 14]. This ruling highlights the potential for anti-competitive behavior when a board dominated by dentists restricts the scope of practice for dental hygienists, effectively limiting competition in the dental market. This legal precedent provides a strong impetus for states to consider establishing independent boards of dental hygiene, composed primarily of dental hygienists and public members, to regulate their own profession. Such a structure would reduce the inherent conflict of interest and ensure that regulations are based on public health needs and professional competency, rather than economic protectionism.
2. Evidence-Based Scope of Practice: Regulations governing the RDH scope of practice must be based on objective evidence of education, training, and competency, not on outdated traditions or economic protectionism. As demonstrated, RDHs are rigorously trained in a wide array of procedures, including local anesthesia and restorative functions [10, 11]. Policies should be updated to allow RDHs to perform all procedures for which they are educated and clinically competent, thereby maximizing their contribution to patient care.
3. Promoting Collaborative Practice Models: Encouraging and enabling collaborative practice models, where RDHs can work more autonomously, under physician supervision, or under general supervision, is essential. This would allow RDHs to establish practices in underserved areas, reach vulnerable populations, and provide much-needed preventive and basic restorative care, thereby expanding access to dental services. Such models have been shown to increase productivity and net income for dental practices, demonstrating a win-win scenario for both providers and patients [7].
4. Transparency in Lobbying and Advocacy: Greater transparency is needed regarding the lobbying activities and financial contributions of dental associations. Public awareness of how these organizations influence legislation can empower policymakers and the public to demand regulations that serve the greater good rather than specific professional interests. When lobbying efforts are clearly aimed at restricting the scope of practice for trained professionals, it raises legitimate questions about their true intent.
5. Educating the Public and Policymakers: There is a vital need to educate both the public and policymakers about the extensive training and capabilities of RDHs. Dispelling misconceptions about their role and highlighting their potential to improve oral health outcomes can build support for legislative changes that expand their scope of practice. Emphasizing the economic benefits—both for dental practices and for consumers through cost savings—can also be a powerful argument for reform [8].

By embracing these changes, we can move towards a system where RDHs are empowered to practice to the top of their abilities, leading to a more efficient, accessible, and equitable oral healthcare system for all. The focus must shift from protecting professional silos to fostering a collaborative environment where every dental professional can contribute fully to the health and well-being of the community.

Conclusion

The debate surrounding the scope of practice for Registered Dental Hygienists is more than just a professional turf war; it is a critical discussion about public health, access to care, and the efficient utilization of a highly skilled workforce. The evidence is clear: RDHs are extensively educated and rigorously trained to perform a wide range of preventive and therapeutic procedures, including many that are currently restricted by outdated or financially motivated regulations.

The persistent limitations on their scope of practice, often justified by vague safety concerns, appear to be more closely tied to the economic interests of established dental associations and the disproportionate representation of dentists on regulatory boards. This dynamic not only stifles the professional growth of RDHs but also creates unnecessary barriers to care, particularly for underserved populations who could greatly benefit from expanded access to dental hygiene services.

It is time to move beyond protectionist policies and embrace a future where RDHs are empowered to work to the top of their abilities. By reforming regulatory structures, basing scope of practice decisions on evidence of competency, promoting collaborative care models, and fostering greater transparency, we can unlock the full potential of the dental hygiene profession. This will not only benefit RDHs but, more importantly, will lead to a healthier, more equitable, and more accessible oral healthcare system for everyone. 

References

[1] American Dental Hygienists' Association. Scope of Practice. https://www.adha.org/advocacy/scope-of-practice/ 

[2] Today's RDH. (2023, January 18). 50 States of Dentistry: Hygienists' Different Responsibilities Across.... https://www.todaysrdh.com/50-states-of-dentistry-hygienists-different-responsibilities-across-the-country/ 

[3] Pacific Legal Foundation. Industry Capture of Dental Boards 10 Years after NC Dental. https://pacificlegal.org/industry-capture-of-dental-boards-10-years-after-nc-dental/ 

[4] Dental Hygienists' Scope of Practice Battle Sounds Strangely Familiar. (2021, October 26). Daily Nurse. https://www.dailynurse.com/dental-hygienists-scope-of-practice-battle-sounds-strangely-familiar/ [5] Governing. (2011, December 20). Why Are Dentists Opposing Expanded Dental Care?. https://www.governing.com/archive/gov-why-are-dentists-opposing-expanded-dental-care.html [6] RDH Magazine. (2025, July 8). The case for dental hygienists' autonomy: The economics of dentistry. https://www.rdhmag.com/career-profession/alternative-practice/article/55293010/the-case-for-dental-hygienists-autonomy-the-economics-of-dentistry 

[7] PubMed. Economic impact of dental hygienists on solo dental practices. https://pubmed.ncbi.nlm.nih.gov/22855590/ 

[8] Journal of Dental Hygiene. The Economic Impact of Preventive Dental Hygiene Services. https://jdh.adha.org/content/jdenthyg/79/1/11.full.pdf 

[9] All Allied Health Schools. Learn How to Become a Dental Hygienist: Education & Licensing. https://www.allalliedhealthschools.com/specialties/how-to-become-a-dental-hygienist/ 

[10] CDCA-WREB-CITA. Local Anesthesia. https://adextesting.org/local-anesthesia/ 

[11] University of Minnesota. Restorative Expanded Functions: An 80-hour Training Program. https://dentistry.umn.edu/continuing-dental-education/courses/restorative-expanded-functions-80-hour-training-program-september-november-2025/ 

[12] American Dental Association. 2022 ADA Lobbying Accomplishments. https://www.ada.org/-/media/project/ada-organization/ada/ada-org/files/advocacy/ada_2022_lobby_accomplishments.pdf?rev=da0b8ddcb7794f348c1ae9c4a79439d3&hash=5E469403F5EE4ABCA777AC02F9EE83AE 

[13] North Carolina State Board of Dental Examiners v. FTC, 574 U.S. 494 (2015). https://supreme.justia.com/cases/federal/us/574/494/ 

[14] North Carolina Board of Dental Examiners v. Federal Trade Commission. Oyez. https://www.oyez.org/cases/2014/13-534 

[15] Supreme Court Ruling in North Carolina Board of Dental Examiners v. FTC. (n.d.). AAPA. https://www.aapa.org/wp-content/uploads/2017/01/Supreme_Court_Ruling_NC-FTC.pdf 

[16] Federal Trade Commission. (n.d.). Dentistry. https://www.ftc.gov/industry/health-care/dentistry 

AUTHOR: Jamie Dooley, RDH, BIS

Jamie is the founder and certificate program director of the National Network of Healthcare Hygienists (NNHH), the first nonprofit dedicated to positioning dental hygienists as essential members of interdisciplinary healthcare teams. Under her leadership, NNHH launched the world’s first ANSI-accredited certificate program in dental hygiene, followed by additional programs built to the same rigorous standards—establishing a new benchmark for professional education and expanding opportunities for hygienists in hospitals, primary care, and community health. Committed to formalizing post-license credentialing and elevating the RDH role within the medical model, she is driving a national shift toward integrated, prevention-focused care where dental hygienists are recognized as indispensable to every patient’s health.

Connect with her at [email protected]