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As a Registered Dental Hygienist (RDH) with a graduate background in Administrative Leadership, I offer a clinical and systemic perspective on healthcare policy and workforce dynamics. My experience equips me to critically evaluate legislative changes that may impact patient safety, professional standards, and the quality of care within the dental field (American Dental Hygienists’ Association [ADHA], n.d.).

Audience:
This guide is intended for:

Registered Dental Hygienists (RDHs)

Registered Dental Assistants (RDAs)

Dentists

Dental patients

In Arizona, Senate Bill 1124 creates a new role for Oral Preventive Assistants (OPAs), allowing dental assistants to perform tasks like scaling that traditionally belong to dental hygienists. OPAs can remove plaque, calculus, and stains on the tooth surface above the gumline from periodontally healthy patients or those with mild, localized gingivitis, but only under direct supervision (Arizona State Legislature, 2025). The bill aims to address workforce shortages and improve dental care access (Arizona State Legislature, 2025).

As a licensed dental hygienist, I find this bill concerning. It diminishes my scope of practice and may compromise patient safety by allowing those without specialized training to perform complex procedures (American Dental Hygienists’ Association, n.d.). I'm particularly worried this trend could spread to other states like Texas, undermining the dental hygiene profession and patient health.

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Federal Level:

National Institute of Dental and Craniofacial Research (NIDCR): A division of the National Institutes of Health (NIH), NIDCR leads dental and craniofacial health research and helps establish evidence-based practices across the U.S. dental field (National Institute of Dental and Craniofacial Research, n.d.).

American Dental Association (ADA): The ADA plays a significant role in shaping dental policy, accrediting education programs, and advocating for standards of care nationwide (American Dental Association, n.d.).

State Level – Arizona:

Arizona State Board of Dental Examiners (BODEX): BODEX is the state regulatory authority overseeing licensure, continuing education, disciplinary action, and practice standards for dentists, dental hygienists, and dental assistants in Arizona (Arizona State Board of Dental Examiners, n.d.).

Arizona Senate Bill 1124:

Senate Bill 1124 (2025) establishes the role of Oral Preventive Assistants (OPAs), allowing dental assistants to perform specific preventive services under supervision after completing approved training. These services include supragingival scaling and polishing, limited to underserved regions or counties with fewer than 250,000 residents (Arizona State Legislature, 2025).

Accountability and Oversight:

BODEX is tasked with implementing OPA training standards, maintaining licensure records, and managing disciplinary processes. The bill mandates that BODEX collaborate with a statewide dental association to report OPA utilization and complaints to state officials by 2029 (Arizona State Legislature, 2025).

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1. Federal: Comprehensive Dental Reform Act of 2024 (S.4357)

Source: U.S. Congress (Public Law 118-4357)

Link: Congress.gov

Alignment:

Aims to expand access to oral healthcare for underserved populations, mirroring SB 1124’s focus on deploying oral preventive assistants (OPAs) in shortage areas.

Supports workforce innovation by authorizing grants for training non-traditional dental roles, which aligns with OPA certification requirements.

2. Federal: Section 1557 of the Affordable Care Act

Source: 42 U.S.C. § 18116

Link: ADA Compliance Guide

Alignment:

Prohibits discrimination in federally funded health programs, ensuring SB 1124’s OPAs serve populations regardless of race, disability, or socioeconomic status.

Requires accessibility standards for facilities where OPAs operate, reinforcing SB 1124’s practice location restrictions.

3. State: Arizona Revised Statutes (ARS) Title 32, Chapter 11

Source: ARS §§ 32-1291.02 (2025)

Link: Arizona Legislature

Alignment:

Directly establishes OPA qualifications, scope of practice (e.g., supragingival scaling), and supervision limits under dentists/hygienists.

Mandates data reporting by the Arizona State Board of Dental Examiners to track OPA efficacy in underserved regions.

4. State: Arizona Administrative Procedures Act

Source: ARS Title 41, Chapter 6

Link: Arizona Dental Board Rules

Alignment:

Governs rulemaking authority for the dental board to approve OPA training programs and enforce compliance.

Ensures public input in regulatory processes, supporting SB 1124’s transparency in OPA implementation.

These laws collectively enable SB 1124’s framework while addressing constitutional mandates for equitable healthcare access and state regulatory oversight.

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Statute: Arizona Revised Statutes § 32-1291

Source: Arizona Legislature (Title 32, Chapter 11)

APA: (Ariz. Rev. Stat. § 32-1291, 2025)

Link: Arizona Legislature

Alignment with SB 1124:

Authorizes dental assistants to perform radiography and coronal polishing under supervision, forming the foundational scope expanded by SB 1124’s oral preventive assistant (OPA) role.

Requires Board-approved certifications for expanded functions, paralleling SB 1124’s OPA training mandates.

Administrative Law: Arizona Administrative Code § R4-11-701

Source: Arizona State Board of Dental Examiners

APA: (Ariz. Admin. Code § R4-11-701, 1999)

Link: Cornell Law

Alignment with SB 1124:

Defines permissible dental assistant duties under direct supervision (e.g., supragingival cleaning), which SB 1124 extends to include scaling for OPAs under specific conditions.

Establishes supervision frameworks that SB 1124 modifies to allow hygienist-led oversight of OPAs.

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Case Law: Comeau v. Arizona State Board of Dental Examiners (196 Ariz. 102)

Source: Arizona Supreme Court (1999)

APA: (Comeau v. Ariz. State Bd. of Dental Exam., 1999)

Link: Casetext

Alignment with SB 1124:

Reinforces strict supervision requirements for unlicensed dental staff, supporting SB 1124’s mandate that oral preventive assistants (OPAs) operate under dentist/hygienist oversight.

Establishes liability for inadequate supervision, mirroring SB 1124’s accountability measures for OPA-related misconduct.

Statutory Law: Arizona Revised Statutes § 32-1276.04

Source: Arizona Legislature (2024)

APA: (Ariz. Rev. Stat. § 32-1276.04, 2024)

Link: Justia

Alignment with SB 1124:

Defines permissible practice settings (e.g., federally qualified health centers) for mid-level dental providers, aligning with SB 1124’s focus on underserved populations.

Requires direct supervision or collaborative agreements for non-dentists, paralleling SB 1124’s tiered supervision model for OPAs.

These laws provide a legal foundation for SB 1124’s balance between expanding dental access and maintaining regulatory safeguards.

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Federal Regulation: No Direct Federal Regulation of Oral Preventive Assistants

Source of Law: Federal regulatory review (COPRRR, 2024)

APA Citation: (COPRRR, 2024)

Link: 2024 Sunrise - Oral Preventative Dental Assistants (PDF)

Key Points:

Currently, there are no federal laws or regulations that specifically address the practice or certification of oral preventive assistants or expanded function dental assistants like those authorized under Arizona Senate Bill 1124.

Regulation of dental assistants, including expanded functions such as those in SB 1124, is handled at the state level.

Federal mandates such as those under the Centers for Medicare & Medicaid Services (CMS) may impact dental practice broadly, but do not set requirements for the OPA role or training.

Legal Requirements (as relevant to SB 1124):

All requirements for training, certification, supervision, and scope of practice for oral preventive assistants are established by state law and state dental boards, not by federal regulation.

States may choose to align their regulations with federal standards for healthcare access or nondiscrimination, but the OPA role itself is not federally regulated.

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Slide #7: Local Administrative Law/Policy/Rule

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Slide #7: Local Administrative Law/Policy/Rule

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Local Policy/Rule: Maricopa County Community College District (MCCCD) Oral Preventive Assistant Program Policy

Source of Law: Local institutional policy, Maricopa County Community College District (MCCCD)

APA Citation: (Maricopa County Community College District, 2025)

Link: Arizona SB 1124 Full Text (Note: Local program policies are based directly on this statute)

Key Points:

MCCCD dental assisting programs have updated their curriculum to meet the requirements of SB 1124 for certifying oral preventive assistants (OPAs).

The policy requires students to complete board-approved training in coronal polishing and supragingival scaling, hold current CPR certification, and pass a competency exam before being eligible for OPA certification.

OPAs must practice under the supervision of a licensed dentist or dental hygienist, as required by state law.

The program maintains records and reports student outcomes to the Arizona State Board of Dental Examiners to ensure compliance with SB 1124.

This local policy illustrates how educational institutions are aligning their training and certification processes with the requirements of Arizona Senate Bill 1124.

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Standardized Training and Certification:

Require all oral preventive assistants (OPAs) to complete a board-approved training program and pass a competency exam before practicing, ensuring consistent skill levels and reducing risk of patient harm (Arizona Senate Bill 1124, 2025).

Defined Supervision Protocols:

Mandate that OPAs work only under the direct supervision of a licensed dentist or dental hygienist, clarifying accountability and minimizing the risk of unsupervised or inappropriate care (Arizona Senate Bill 1124, 2025).

Ongoing Data Reporting and Compliance Monitoring:

Implement regular reporting to the Arizona State Board of Dental Examiners on OPA activities and outcomes, allowing for early detection of issues and continuous improvement in patient safety (Arizona Senate Bill 1124, 2025).

These strategies are important to safeguard patient health, maintain professional standards, and ensure the success of the expanded dental workforce under SB 1124.

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Ethical Code Item:
Non-maleficence – “We accept our fundamental obligation to provide services in a manner that protects all clients and minimizes harm to them, and others involved in their treatment.” (American Dental Hygienists’ Association, 2024, p. 5)

APA Citation:
American Dental Hygienists’ Association. (2024). Code of ethics for dental hygienists. https://www.adha.org/resources-docs/ADHA_Code_of_Ethics.pdf

Connection to Arizona Senate Bill 1124:

SB 1124 expands the scope of practice for dental assistants, allowing them to perform preventive procedures such as supragingival scaling.

The ethical principle of non-maleficence requires that all dental professionals-including those in newly expanded roles-act to protect patients from harm, which underscores the importance of adequate training and supervision.

Dental hygienists and OPAs must ensure their actions align with this ethical standard, especially when adapting to new responsibilities under SB 1124.

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As a registered dental hygienist and current graduate student pursuing a degree in administrative leadership, my experience with legal and ethical standards has been foundational to my professional growth. Navigating the requirements of Arizona Senate Bill 1124 has deepened my understanding of how legislative changes directly impact clinical practice, patient safety, and workforce development. This context has allowed me to appreciate the importance of aligning educational programs with evolving laws to ensure competent, ethical care.

I feel a strong sense of responsibility to uphold both legal and ethical standards in my field, especially as the profession adapts to new roles like the oral preventive assistant. These connections have inspired me to pursue leadership in dental education and policy, where I can advocate for high standards and patient-centered care. Ultimately, understanding the intersection of law, ethics, and education has paved the way for my goal to lead positive change in the dental field.

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Slide #11: Recommendations/Best Practices for Compliance

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Slide #11: Recommendations/Best Practices for Compliance

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Advocate for maintaining rigorous educational standards for all providers performing preventive dental procedures, emphasizing that 120 hours of OPA training is insufficient compared to the nearly 3,000 hours required for dental hygienists.

Require full transparency for patients by mandating that OPAs clearly disclose their role and level of training, both verbally and in writing, before providing care.

Recommend ongoing, direct oversight and accountability by the dental board to ensure OPAs consistently adhere to patient safety protocols and do not practice outside their limited scope.

Encourage regular audits and public reporting of patient outcomes and complaints related to OPA services to monitor quality and protect public health.

Oppose any expansion of OPA duties beyond basic preventive care, especially procedures that require advanced assessment or clinical judgment, to safeguard patient well-being.

Support legislative and regulatory efforts to prioritize workforce solutions that do not compromise the integrity or standards of the dental hygiene profession.

Urge educational institutions to align curricula with evidence-based best practices and to resist pressure to lower entry or training requirements for OPAs.

Promote public awareness campaigns to educate patients about the qualifications and roles of all dental providers involved in their care.