Dental Assistant Requirements in Michigan: Registration, X-Ray Rules & Allowed Duties

The definitions rule sets out a registered dental assistant (RDA), a person licensed by the board who performs dental procedures as specified in Table 1, and an unregistered dental auxiliary (UDA), who is unlicensed and performs basic supportive dental procedures as specified in the same table.

A registered dental hygienist (RDH) is a separate, third allied-personnel tier that also appears in Table 1, but it is a hygienist credential, not a dental-assistant one.

An unregistered dental auxiliary carries no license or registration, but before a dentist may delegate any function to a UDA, the UDA must meet two prerequisites: current BLS or ACLS certification with a hands-on component, and at least 1 hour of infection-control training covering handpiece sterilization, personal protective equipment, and CDC guidelines.

A registered dental assistant, by contrast, must be licensed by the board: the applicant submits a completed application and fee, graduates a board-approved program, and provides evidence of passing both a board-approved written and clinical exam with a score of at least 75 on every section.

Part 4A defines three levels a dentist may use to delegate work under Table 1.

Assignment means the dentist designates the patient of record and describes the procedure to be performed; unless the rules require direct or general supervision, the dentist need not be physically present in the office while it happens.

General supervision requires the dentist to designate the patient and also be physically present in the office.

Direct supervision adds a same-day exam of the patient before and after the procedure, on top of that in-office presence.

Table 1 abbreviates the three as A, G, and D.

Table 1 lists dental procedures identified (a) through (uu) and, for each, sets which of assignment, general supervision, or direct supervision applies to a UDA, RDA, and RDH; a dentist or dental therapist may not delegate a procedure to allied personnel outside that table.

Base entries cover instructing patients on appliance care, taking impressions for study models, applying nonprescription topical anesthetic, and sizing orthodontic bands.

A further set of entries — nutritional counseling, charting the oral cavity with a mouth mirror and radiographs, and applying anticariogenic agents such as sealants and fluoride — opens to a UDA only after the UDA completes in-person or virtual training with performance evaluations on that specific function.

Operating dental radiographic equipment is entry (a) on Table 1.

An unregistered dental auxiliary must first complete a course in dental radiography substantially equivalent to one taught in a board-approved program before performing that procedure, after which a dentist may delegate the necessary radiographs for a new patient to a UDA, RDA, or RDH.

Radiography is also one of the named content areas on the RDA licensure exam itself.

Both the RDA and UDA definitions cap each tier's authority at the procedures specified in Table 1 of R 338.11411 — nothing outside that table may be delegated to either.

Within the table, some limits are explicit: removing, adjusting, or replacing orthodontic bands, brackets, and adhesives may only be done with hand instruments, because using a high-speed rotary instrument for that task falls outside the scope of practice of a UDA, RDA, or RDH, and an unregistered dental auxiliary specifically may not place sealants even once trained on other anticariogenic agents.

Assisting and monitoring the administration of nitrous oxide analgesia by a dentist or an RDH is delegable to an RDA or RDH, but only once that RDA or RDH completes an approved course with at least 5 hours of didactic instruction.

The dentist or RDH must preset the nitrous oxide levels, and an RDA may not adjust them — except that in an emergency the RDA may turn off the nitrous oxide and switch the patient to 100% oxygen.

The rule limits an RDA's role in this task to setting up equipment and placing the face mask, not starting or stopping the flow outside that emergency exception.

An RDA (like an RDH) must complete at least 36 hours of board-approved continuing education in the 3 years before their license renews; someone holding both an RDA and RDH license must complete 36 hours split with at least 12 hours devoted to each.

Within those 36 hours, the rule further requires at least 12 hours on clinical issues such as delivery of care, materials, and pharmacology, 12 hours of synchronous instruction, 2 hours on pain and symptom management, 1 hour on ethics and jurisprudence covering delegation of duties, and 1 hour on infection control, with no more than 18 hours earned asynchronously.

The renewal rule applies to the licensed RDA and RDH tiers; it names no continuing-education requirement for the unlicensed UDA.