CURRENT
EVENTS
MDHA Comments on Proposed Rule 20 CSR 2110-2.120 – Dental Assistants (Periodontal EFDAs)
The Missouri Dental Board's Proposed Rule for a Periodontal EFDA (formerly called the OPA-EFDA) titled Proposed Rule 20 CSR 2110-2.120 – Dental Assistants (Periodontal EFDAs) will be printed in the Sept. 15th edition of the Missouri Register. The rule allows dental assistants scale suprapgingivally and provide “completer periodontal charting. It is important for ALL MO hygienists and dentists opposed to this to send in comments opposing the new Periodontal EFDA rule being promulgated by the Missouri Dental Board by October 15, 2026 to the:
Missouri Dental Board
P.O. Box 1367, Jefferson City , MO 65102-1367
· Fax: (573) 751-8216
· Email: dental@pr.mo.gov
You must list this the title: Proposed Rule 20 CSR 2110-2.120 – Dental Assistants (Periodontal EFDAs) in your comments. We need many, many messages to the MDB as each one will be counted and read. Urge relatives and friends to write. NUMBERS matter! Lots of people need to object to get the MDB’s attention.
Keep watching the MDHA website for more information. Go to Legislation, then to Current Events https://www.missouridha.org/current-events to the OPA-EFDA, now being called the Periodontal EFDA.
The largest issue is the MDHA feels that the MDB does not have the statutory authority to even create this rule. Here are some MDHA short talking points and other legal points that you can use. Pick something relevant to you or tell your story of what you know and why this is a bad idea for Missouri citizens. Start acting Sept. 15h.
In addition, you can also help with our legal fund on the MDHA website at https://www.missouridha.org/donate-1 to help us pay our lawyer to fight this issue. Thank you.
MDHA Legislative Team
FORIMMEDIATERELEASE September 30, 2026
Media Contact: Diann Bomkamp, RDH, BSDH, CDHC, FADHA Legislative Chair,
Missouri Dental Hygienists’ Association 314-484-6121 | dbomkamp@sbcglobal.net
Missouri Dental Hygienists’ Association Sues Dental Board to Stop Rule Letting Assistants Perform Hygiene Procedures Lawsuit says the proposed rule revives a pilot program the legislature let expire JEFFERSONCITY,Mo.–TheMissouri Dental Hygienists’ Association (MDHA) filed suit yesterday in Cole County Circuit Court, asking the court to block a rule proposed by the Missouri Dental Board that would let dental assistants perform supragingival scaling and comprehensive periodontal charting, because Missouri law reserves those procedures to licensed dentists and dental hygienists. The proposed rule, published in the Missouri Register on September 15, 2026, would create a new “periodontal” expanded-function permit for dental assistants. MDHA is joined in the suit by Lori Crawford, a former MDHA president who has been a licensed dental hygienist in Missouri since 1986. “To protect patients, the legislature decided who can perform these procedures, and it wrote that into statute. The Board ran a pilot, the legislature let it expire, and now the Board is trying to make it permanent anyway. That’s not a decision the Board gets to make on its own,” said Diann Bomkamp, Legislative Chair of MDHA. What the law says Under Missouri law, the definition of the practice of dental hygiene includes supragingival scaling (removing hard and soft deposits from teeth above the gumline) and comprehensive periodontal charting (clinically examining teeth and surrounding tissues). Missouri law also bars the Board from adopting any rule that allows dental assistants to perform acts that conflict with dental hygiene practice, except for polishing teeth, placing sealants, and applying fluoride. The lawsuit argues the Board cannot expand delegable functions beyond the three statutory exceptions by rule to include supragingival scaling and comprehensive charting. The expired pilot program In 2022, the General Assembly authorized the Board to temporarily waive the laws governing the dental field to implement pilot projects to test new ways to reach underserved patients. Accordingly, the Board temporarily waived the delegation limits so a small group of dental assistants could perform supragingival scaling and periodontal charting in a pilot that ran from January 2024 to October 2025. The authorizing statute expired on August 28, 2026, and the legislature did not renew it. According to the petition, the pilot’s own results do not support making it permanent. The final report from December 2025 acknowledged the pilot did not show a significant increase in clinic capacity or improved access for patients with more serious periodontal disease. The lawsuit also challenges a provision that would convert former pilot participants into permanent permit holders and allow the Board to begin issuing permits before the rule takes effect, as both are unsupported by the Board’s statutory authority. Finally, unlike the pilot, the proposed rule would not require that patients be told an assistant, rather than a dentist or dental hygienist, is performing their care, or that they consent to it. “I've been a dental hygienist for almost 40 years, and I'm also a patient. Every patient should know who is treating them and have a say in it. The pilot required that. This rule drops it,” said Crawford. What MDHAis askingthe court to do MDHAasks the court to declare the proposed rule invalid and to issue preliminary and permanent injunctions preventing the Board from finalizing the rule or issuing permits under it. Public comment open through October 15 The Board is accepting public comments on the proposed rule through October 15, 2026. MDHA encourages dental hygienists, dentists, and patients to submit comments. Comments may be submitted via email to dental@pr.mo.gov, via facsimile at (573) 751-8216, or via mail to Missouri Dental Board, PO Box 1367, Jefferson City, MO 65102. About MDHA The Missouri Dental Hygienists’ Association is a statewide nonprofit representing licensed dental hygienists in Missouri and a constituent of the American Dental Hygienists’ Association. MDHAisrepresented by Blitz, Bardgett & Deutsch, L.C
Keep up to date on what is happening here in Missouri.
1. Proposed “Periodontal EFDA” Rule Update
On May 14, 2026, the Missouri Dental Board voted 4–3 to move forward with the proposed “Periodontal EFDA” rule, formerly referred to as the OPA-EFDA proposal.
The Missouri Dental Hygienists’ Association (MDHA) maintains that the Missouri Dental Board does not have statutory authority to permanently create this position through administrative rulemaking without legislative authorization. MDHA retained administrative law attorney Chris Pieper to represent the Association’s position before the Board.
MDHA believes the proposed rule raises serious concerns regarding:
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Patient safety
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Education and training standards
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Scope of practice
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Clinical assessment responsibilities
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Statutory authority
Missouri law currently limits scaling and removal of hard and soft deposits from teeth and comprehensive periodontal charting to licensed dentists and licensed dental hygienists. The proposed rule would also allow “Periodontal EFDAs” to complete periodontal charting and supragingival scaling, which is currently performed by licensed dentists and licensed dental hygienists.
The original OPA-EFDA project was established as a temporary pilot project by the Missouri Legislature, with findings intended to be reported back to legislators and the Missouri Dental Board. MDHA maintains that major scope-of-practice changes should proceed through the legislative process.
The proposal now moves into Missouri’s formal rulemaking process, including review by the Joint Committee on Administrative Rules (JCAR).
MDHA will continue providing updates and guidance as this process progresses.
2. MDHA Legislative Legal Fund
MDHA has established a Legislative Legal Fund to support continued legal advocacy and representation regarding this issue. Please, consider donating to help cover legal fees.
The Missouri Dental Hygienists’ Association maintains that the Board does not have legal authority to expand duties beyond the existing pilot project and has retained legal counsel to represent the Association. Our attorney’s letters outlining these concerns, including the pilot project’s failure to meet stated goals, has been submitted to the Board.
3. Expanded Public Health Settings Update
The Missouri Dental Board unanimously approved a proposed rule expanding the public health settings where dental hygienists may practice without dentist supervision under Section 332.311, RSMo. Potential expanded settings include, public and private schools, Missouri Special Olympics, additional nonprofit and community health settings, mental health settings, state courts administrator.
MDHA encourages every Missouri dental hygienist to submit a brief letter in support of this important rule. Expanding public health settings will improve access to preventive oral health services for underserved Missourians.
A sample letter below can be personalized before submitting.
Submit your comments by August 14, 2026
Email: dental@pr.mo.gov
Mail:
Missouri Dental Board
PO Box 1367
Jefferson City, MO 65102
Fax: (573) 751-8216
No public hearing is scheduled.
4. Have you heard about the pilot programs that the Missouri Dental Board have approved? Click the button below to learn about the current Nursing Home Pilot Project with Telehealth and the proposed Oral Preventive Assistant "OPA" Pilot Project.
5. The Dentist and Dental Hygienist Compact bills
Passage of this legislation is anticipated by MDHA in 2027.
6. Local Anesthesia Under General Supervision — Passage Update
The proposed rule change allowing dental hygienists to administer local anesthesia under general supervision was finalized on October 1, 2024, and published in the Missouri Register. The rule officially took effect on November 30, 2024.
While this is an exciting step forward, there are still several actions that must take place before implementation in the office.
Read below for the final rule wording and review the American Society of Anesthesiologists (ASA) Classifications, which will guide the enforcement of this change.
7. School Expansion:
Over the past several years, COVID-19 significantly impacted Missouri’s oral-health workforce, and recovery remains incomplete. According to the Missouri Department of Health and Senior Services, the state experienced a 5–12% reduction in dental assistants and a 5–8% reduction in dental hygienists.
Compounding this workforce loss, Missouri has seen a substantial decline in dental hygiene education capacity. Since 2016, four of the state’s ten dental hygiene program sites have closed. These closures include two distance-education sites in Rolla and Sikeston, Missouri (2018), which served critical rural areas; the Missouri College site in St. Louis (2016); and a distance-education site at Hillyard Technical College in St. Joseph, which partnered with North Central Missouri College in Trenton (2020). As a result, Missouri began losing graduates as early as 2016, reaching a deficit of approximately 60 dental hygiene graduates per year by 2020. Over the past five years, this equates to a loss of more than 300 potential dental hygiene graduates statewide.
In response, the Missouri Dental Hygienists’ Association (MDHA) engaged with dental hygiene programs across the state, providing workforce data and manpower projections to support program expansion where feasible. These efforts have yielded measurable progress:
1. Concorde Career College now admits a new cohort every eight months and has increased class size from 24 to 32 students per cohort.
2. St. Louis Community College expanded its longstanding Forest Park program by opening an additional site at Florissant Valley in fall 2025, doubling student capacity from 32 to 64. This expansion was made possible through Proposition R, a voter-approved property tax levy passed in 2021.
3. State Fair Community College opened an additional site in Columbia using grant funding, enrolling 10 new students in 2025, in addition to its Sedalia cohort of 10–12 students admitted every other year. Planned clinic expansions at the Sedalia site, including additional operatories, are expected to increase total enrollment capacity to 24 students per class across both locations.
4. Ozark Technical College is exploring expansion of its dental hygiene program through a distance education site at Jordan Valley Community Health Center, potentially adding 8 students in Fall 2026, with possible funding support from the Delta Dental Foundation of Missouri.
5. Missouri Southern State University plans to petition its Board of Regents in April 2026 to expand its dental hygiene program, with an estimated $2 million needed to support clinic and program growth.
Quick Takeaway
Missouri currently graduates approximately 250–260 dental hygienists per year; with recent and proposed program expansions, this could increase by ~65–70 additional graduates annually, bringing the potential total to approximately 315–330 graduates per year (pending full implementation and funding).
Increasing the number of graduates from accredited dental hygiene programs remains one of the most effective and sustainable strategies to address Missouri’s dental hygiene workforce shortage. Even if an OPA-EFDA bill were introduced and passed, the demand for licensed dental hygienists would persist. Expanding educational capacity is essential to ensuring access to safe, high-quality preventive oral-health care for Missourians.