Dear Board Members and others:

I have practiced Oral Conscious Sedation in Virginia since 2003.  I have performed over 500 cases without incident.  The new regulations address several issues that were necessary such as permitting which is great.

But there are two serious problems with the new regulations:

 (1) ECG monitoring is required for mild to moderate oral sedation. This is Overkill for mild to moderate oral conscious sedation.  It is needed for deep sedation.  There needs to be some verbage that differentiates the two.  The intended level of sedation for oral sedation does not have any adverse effect on cardiac function.  If anything, it has a positive impact.

 (2) The dentist cannot leave the operatory during mild to moderate oral conscious sedation.  This is also overkill.  My staff is trained to stay with the patient at all times, while constantly monitoring them.  This is all that is necessary for mild to moderate sedation.

Two other issues that I think need to be considered are:

1. The ADA had a lot of discussion on the sedation protocols several years ago, and came up with a policy after months of discussion with all of the leading experts in the field.  Why is Virginia coming up with regulations that differ from the ADA, when they clearly have not researched the topic to the extent of the ADA or had any national experts give recommendations.
2. The new regulations do not pass the litmus test.  Specifically, patients that are scared and nervous inherently have elevated blood pressure and a greater predisposition to cardiac and/or medical issues.  Sedation lowers the chance these patients will have a problem.  These regulations will allow fewer patients access to sedation services, which will increase the incidence of cardiac and medical emergencies in general dentist’s offices throughout Virginia.

Please reconsider the new regulations, specifically in regards to the points above.  The citizens of Virginia will be the ones hurt the most if these changes go into effect.

Sincerely,

Brad Spano, DDS