Concerns regarding SB 1124 and the introduction of the oral preventive assistant role in Arizona
As a 24-year licensed dental hygienist practicing in Arizona, I am writing in response to Erin Hendricks’ article regarding the oral preventive assistant (OPA) bill that recently passed in my state to address workforce shortages. While the author draws comparisons between the OPA model and the U.S. Air Force’s prophylaxis technician program, this analogy fails under closer examination.
The military model functions within a uniquely closed and controlled environment, where the primary objective is ensuring personnel are deployment-ready—not delivering long-term preventive care or comprehensive oral health management. Military dental clinics serve a captive population without provider choice, operating in a system that is fundamentally different from civilian health-care settings. To compare the two is to ignore the complex clinical realities and patient autonomy that defines dentistry in Arizona.
In fact, Arizona SB 1124 was never compared to the military model during anytime that it was moving through the legislative process. This bill appears to have originated not from the Air Force model, but instead, the bill’s structure bears striking resemblance to a policy outline released by the American Legislative Exchange Council (ALEC) in December 2024—one that appears to prioritize workforce expediency over clinical integrity. While addressing dental workforce shortages is important, it must not come at the cost of patient safety, quality of care, or the rigorous professional standards long upheld by the dental hygiene profession.
Scope of practice
One of the most pressing concerns among dental professionals is the scope of practice assigned to OPAs. The bill permits OPAs to perform supragingival scaling and polishing. However, even in patients with healthy periodontal status, effective prophylaxis routinely requires subgingival scaling to remove calculus and biofilm—essential components in preventing periodontal disease. By omitting subgingival instrumentation, the OPA scope of practice risks rendering preventive care incomplete and clinically ineffective.
Disparity in educational requirements
The disparity in educational requirements is equally alarming. OPAs would receive approximately 120 hours of instruction, a fraction of the nearly 3,000 hours of academic and clinical education required of licensed dental hygienists. Dental hygiene courses are specifically designed to develop precise instrumentation skills, critical thinking, and a deep understanding of systemic health conditions that affect oral care. Coursework in biology, chemistry, microbiology, anatomy, physiology, morphology, periodontology, pharmacology, pathology, radiology, jurisprudence, and infection control equips hygienists to review medical histories thoroughly, identify risk factors, and modify treatment accordingly and comprehensively—all of which are essential to safe and effective patient care. And, only after completing the regulated curriculum may a student demonstrate their competency by passing both national and state board examinations.
The CDT D1110 code
Hendricks also refers to OPAs performing procedures that align with the CDT D1110 code, or what she terms a “routine prophy.” However, the CDT D1110 descriptor for adult prophylaxis includes the removal of plaque, calculus, and stains from all tooth surfaces—both above and below the gumline. Subgingival scaling is, therefore, not only a best practice but a defining characteristic of this procedure. To suggest that supragingival care alone meets this standard is to misrepresent the intent of the code and the expectations of evidence-based care.
Content and implications of SB 1124
Hendricks’ article also mischaracterizes the content and implications of SB 1124. The procedures she references—including taking periodontal measurements and providing certain educational components—are not authorized under the current language of the law signed by Governor Hobbs. As of this writing, key educational and regulatory details have yet to be finalized by the Arizona State Board of Dental Examiners.
The notion that limited training and a restricted scope of services can replace the comprehensive, preventive approach delivered by licensed dental hygienists is deeply troubling. Such a shift threatens to lower the standard of care and mislead patients about the quality of treatment they are receiving. Arizona patients deserve preventive oral health care that is thorough, evidence-based, and delivered by highly trained professionals. While innovative solutions to workforce shortages are worth exploring, they must be implemented responsibly, with patient health and safety as the highest priorities. I urge policymakers, dental professionals, and the public to critically evaluate the long-term implications of this legislation and to advocate for standards that protect the health, dignity, and trust of every patient in Arizona.
Editor’s note: This article first appeared in Clinical Insights newsletter, a publication of the Endeavor Business Media Dental Group. Read more articles and subscribe.
