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Are Diagnosis and Treatment Planning Outside A Dental Hygienists’ Scope of Practice?

I have more than 30 years of experience as a clinical dental hygienist in Massachusetts. I thought that diagnosis and treatment planning were outside of dental hygienists’ scope of practice and that these duties were the purview of dentists only.

QUESTION: I have more than 30 years of experience as a clinical dental hygienist in Massachusetts. I thought that diagnosis and treatment planning were outside of dental hygienists’ scope of practice and that these duties were the purview of dentists only. The dentist I currently work for has asked that I take on these responsibilities. Is this legal?

ANSWER: A dental hygiene diagnosis is different from a dental diagnosis. The American Dental Hygienists’ Association defines a dental hygiene diagnosis as “the identification of an existing or potential oral health problem that a dental hygienist is educationally qualified and licensed to treat; the dental hygiene diagnosis requires analysis of all available assessment data and the use of critical decision-making skills in order to reach conclusions about the patient’s dental hygiene treatment needs.”1 Three states—Colorado, Connecticut, and Oregon—include dental hygiene diagnosis in their practice acts. Seven states—California, Colorado, Iowa, Kansas, Nevada, North Dakota, and Oregon—allow dental hygienists to perform some type of treatment planning.2

Dental hygienists employ critical decision-making skills to reach conclusions about patients’ needs related to oral health and disease that fall within the dental hygiene scope of practice. As one component of the process of care, the dental hygiene diagnosis involves a thorough patient assessment and informed decision making. The dental hygiene diagnosis and treatment plan are then incorporated into the comprehensive diagnosis and treatment plan. The collaborative relationship between dental hygienists and dentists assures that the treatment needs of patients will be identified, addressed, and evaluated.1

According to the Massachusetts Board of Registration in Dentistry, “A dental hygienist may provide dental services that are educational, therapeutic, prophylactic, and preventive in nature as may be authorized by the board and may perform all tasks performed by a dental assistant under the specific type of supervision set forth in 234 Code of Massachusetts Regulations (CMR). A dental hygienist or public health dental hygienist may not perform acts or services that require diagnosis and treatment planning for nondental hygiene services or surgical or cutting procedures on hard or soft tissue, and/or the prescription of medications, unless specifically authorized in 234 CMR 5.07 and 5.12.”As such, in Massachusetts only dentists can provide the final diagnosis and treatment plan.


  1. American Dental Hygienists’ Association. Dental Hygiene Diagnosis: AnAmerican Dental Hygienists’ Association Position Paper. Available Accessed July 29, 2014.
  2. American Dental Hygienists’ Association. Dental Hygiene Practice Act Overview:Permitted Functions and Supervision Levels by State. Available at: Accessed July 29, 2014.
  3. Executive Office of Health and Human Services Massachusetts. DentistryLicensing. Available at: Accessed July 29, 2014.
The Ask the Expert column features answers to your most pressing clinical questions provided by Dimensions of Dental Hygiene’s online panel of key opinion leaders, including: Jacqueline J. Freudenthal, RDH, MHE, on anesthesia; Nancy K. Mann, RDH, MSEd, on cultural competency; Claudia Turcotte, CDA, RDH, MSDH, MSOSH, on ergonomics; Van B. Haywood, DMD, and Erin S. Boyleston, RDH, MS, on esthetic dentistry; Michele Carr, RDH, MA, and Rachel Kearney, RDH, MS, on ethics and risk management; Durinda Mattana, RDH, MS, on fluoride use; Kandis V. Garland, RDH, MS, on infection control; Mary Kaye Scaramucci, RDH, MS, on instrument sharpening; Stacy A. Matsuda, RDH, BS, MS, on instrumentation; Karen Davis, RDH, BSDH, on insurance coding; Cynthia Stegeman, EdD, RDH, RD, LD, CDE, on nutrition; Olga A.C. Ibsen, RDH, MS, on oral pathology; Jessica Y. Lee, DDS, MPH, PhD, on pediatric dentistry; Bryan J. Frantz, DMD, MS, and Timothy J. Hempton, DDS, on periodontal therapy; Ann Eshenaur Spolarich, RDH, PhD, on pharmacology; and Caren M. Barnes, RDH, MS, on polishing. Log on to to submit your question.

From Dimensions of Dental Hygiene. September 2014;12(9):86.


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