Dear Utah Hygienist,

The Utah Division of Professional Licensing (DOPL) has proposed draft rules that directly impact dental hygiene's scope of practice, educational standards, and patient safety. We need a strong, unified voice to ensure these rules protect public safety and professional standards.

We have a powerful opportunity to submit public comments to help shape our scope within these draft rules. The template is fully ready to go—all you have to do is review the points below and hit send by June 30, 2026.

Here is what we are advocating for in the draft rules and why:

• Re: R156-69-801 (1)(b)(ii) [Public Health Setting Notification]
  • The Ask: Eliminate the requirement to notify DOPL when leaving a public health setting.
  • Why: A lapse in renewal already indicates work has ceased. Forcing an extra notification creates an undue administrative burden on both licensees and the Division.
• Re: 156-69-803a [Unlicensed Individuals]
  • The Ask: Retain the specific term "Unlicensed Individuals" when referring to dental assistants.
  • Why: Removing this language implies dental assistants hold a state license, which misleads the public and misrepresents Utah’s regulatory framework.
• Re: R156-69-808b (2) & R156-69-808c (2) [Prerequisites for Advanced Certification]
  • The Ask: Require a basic, third-party verified dental assisting certification (such as from the Dental Assisting National Board) as a mandatory prerequisite prior to pursuing advanced certifications.
  • The Ask: Explicitly specify that examinations must include a third-party written and clinical component.
  • Why: On-the-job training in a single office lacks the standardized, consistent knowledge base required for advanced procedures like direct restoration and adhesive removal. Independent testing should be done for standardized verification to ensure competency.
• Re: R156-69-808b(2)(b)(iii)(A) [Dentist-Only Instructor Restriction]
  • The Ask: Oppose the rule restricting didactic and preclinical instruction solely to dentists.
  • Why: Historical Precedent/Context: RDH educators have successfully taught these foundational and restorative courses in Utah for decades. CODA Misalignment: Accreditation focuses on teaching methodology, not clinical scope. Dentists are needed for live-patient diagnosis, not classroom lectures. Workforce Crisis: Five of Utah’s six hygiene programs already struggle to hire dentists due to the academic salary gap. This rule will deepen severe faculty shortages.
• Re: 156-69-808b (3) Table 1 [Clinical Hours & Patient Autonomy]
  • The Ask: Clarify the header to distinguish between lab hours and live-patient hours.
  • Why: Students need live-patient experience to navigate real-world clinical challenges (moisture control, patient movement, etc). However, specific restorative materials should not be strictly mandated on live patients, as this violates patient autonomy, informed consent, and beneficence.

The attached message to the Board urges revised rules to reduce unnecessary administrative burdens, preserve accurate terminology about dental assistants’ unlicensed status, and require standardized, third-party certification and testing before granting advanced clinical privileges. It also urges the board not to restrict instruction solely to dentists and to clarify clinical training requirements in a way that supports workforce sustainability, educational flexibility, patient autonomy, and public safety.

Take Action Now! Submit the pre-filled message to the Board to ensure the dental hygienist's voice is heard!

-UDHA & ADHA Leaders