I have been doing mild to moderate conscious oral sedation dentistry for over eight years and have had no problems with the current recommended technique of monitoring the patient with the pulse oximeter.  The recent change in the regulations that will go into effect April 1st, 2013, is not something that has been recommended by the American Dental Association, which has reviewed moderate oral sedation extensively.  I therefore feel that these changes are much more than are needed.  Virginia is the only state which will require these stricter changes and they will decrease the access to dental care for those patients that need to be sedated in order to help them get through their dental treatment.  I ask that you reonsider these regulation changes and have them withdrawn before the activation date of April 1st 2013.                               The requirement to have the dentist present in the room with the patient the entire time the patient is sedated in the office is also an unnecessary requirement.  During the initial and post-op phase of the sedation appointment, or when the dentist needs to check a hygiene patient, the sedated patient can be adequately monitored by a qualified and trained dental assistant or hygienist.  In most dental offices the doctor can be sumoned in a few seconds to address any concerns that might arise.  This requirement is also overkill and should be revoked as soon as possible.