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Committee reviews updated dental rules to add dental therapists and allow public-health hygienists to perform SMART technique

May 16, 2025 | Legislative Committee on Administrative Rules/LCAR, Joint, Committees, Legislative , Vermont


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Committee reviews updated dental rules to add dental therapists and allow public-health hygienists to perform SMART technique
The Legislative Committee on Administrative Rules heard a detailed presentation May 15 on proposed updates to the Board of Dental Examiners’ administrative rules, including pathways to license dental therapists, and new authority for licensed public-health dental hygienists to perform silver-modified atraumatic restorative technique (SMART) in specified public-health settings.

The changes are intended to update rules that have not been revised since 2010, implement a statutory authorization for dental therapy, and expand public-health scope of practice to improve access to care in schools and other institutional settings.

Emily Bridal, staff attorney with the Office of Professional Regulation, told the committee the major changes lay out the education and scope of practice for dental therapists, a mid-level credential that can be obtained after becoming a dental hygienist. Bridal said Vermont currently has one licensed dental therapist who does not reside in Vermont and that the updated rules prepare the state’s regulatory apparatus if additional dental therapists apply.

A second significant change implements a 2023 legislative choice permitting public-health dental hygienists to perform limited therapeutic interventions in public-health settings (examples given include schools participating in the 802 Smiles program, nursing homes and correctional settings). The rules require a hygienist to be licensed for three years, to complete a training approved by the Department of Health, and to operate under the general supervision of a licensed dentist (supervision not required to be on-site). Bridal said the therapeutic technique authorized is SMART, described on the record as silver diamine fluoride (SDF) followed by a glass ionomer restoration to reduce the visible staining caused by SDF alone.

Representative Hode asked how training and experience concerns were being addressed. Bridal said the statute requires a hygienist to have three years’ licensure and Department of Health-approved training; the hygienist must exercise judgment and not use the techniques when inappropriate, must inform patients or parents that follow-up with a dentist is needed, and remains subject to professional discipline and standard-of-care rules.

Bridal also described a policy choice to rely on American Dental Association guidelines for some specialty standards (for example, sedation and anesthesia) so rules remain current as clinical practice evolves.

Committee members noted that the underlying legislative decision to allow non-dentists to address certain cavities was the primary point of controversy during rulemaking, though OPR stated it was implementing a clear statutory mandate. No formal vote on the Board of Dental Examiners rules was recorded in the meeting transcript; discussion continued and committee members asked for clarifications.

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