The proposed changes should also be updated to reflect items B.3  and B.4 of the ADA Oct 2016 Sedation guidelines.  For example, under B.3 the equipment recommendations state the following:

"A positive-pressure oxygen delivery system suitable for the patient being treated must be immediately available.

Documentation of compliance with manufacturers’ recommended maintenance of monitors, anesthesia delivery systems, and other anesthesia-related equipment should be maintained. A pre-procedural check of equipment for each administration of sedation must be performed.

When inhalation equipment is used, it must have a fail-safe system that is appropriately checked andcalibrated. The equipment must also have either (1) a functioning device that prohibits the delivery of less than 30% oxygen or (2) an appropriately calibrated and functioning in-line oxygen analyzer with audible alarm.

The equipment necessary for monitoring end-tidal CO2 and auscultation of breath sounds must be immediately available.

An appropriate scavenging system must be available if gases other than oxygen or air are used.

The equipment necessary to establish intravascular or intraosseous access should be available until thepatient meets discharge criteria."

As such, the proposed change does not reflect the need for moderate sedation providers to keep IV access or IO access equipment available.  One of the intents of the updated  ADA guidelines was to enforce the importance of the competency in establishing parenteral access for sedation dentists. This is further supported by the ADA changes to the educational requirements for moderate sedation.

In addition, the appropriate verification of the fail-safes against delivering hypoxic gas mixtures is being addressed by requiring an antihypoxic device or inline gas analyzer. 

Perhaps most importantly though, section B.3 supports the use of checklists in the perioperative period to ensure that equipment is maintained and in working condition prior to delivering anesthesia care.  The use of checklists has been instrumental in the safety of anesthesia care in hospitals and should be encouraged.  For further support of this, please feel free to refer to "To Err is Human" by the Institute of Medicine and "The Checklist Manifesto" by Atul Gawande.

In section B.4,  the ADA guidelines reinforce the use of capnography (end tidal CO2) unless invalidated or precluded, whereas the VA update only requires that capnography be available.  Secondly, the ADA guidelines expressly describe when recovery can be delegated to a dental assistant and the sedationist can leave the room as when the patient returns to a level of minimal sedation.  This too is not addressed in the updates.