I am a dentist in Virginia and am writing in regards to a proposed regulatory change by the BOD. This change suggests moving from a 2-person monitoring team to a 3-person monitoring team for the management of IV moderate conscious sedation.

For background, the American Dental Association established the National Commission on Recognition of Dental Specialties in 2017. Recently, this specialty certifying body recognized the American Society of Dentist Anesthesiologist as the 10th specialty in dentistry. A move of historic and future significance for this group of specialized practitioners.

The American Dental Association and the American Society of Dentist Anesthesiologist collaborated to develop guidelines for management of sedation in the dental office. These guidelines were significantly influenced by the medical arena via the American Society of Anesthesiologist. In those guidelines, which can be found on both the ADA and ASDA websites, it clearly states that a 2-person team is the standard of care.

Hundreds of safe IV moderate sedation procedures are performed across the Commonwealth of Virginia every day. It is a vitally important aspect to the delivery of dental care for anxious and apprehensive patients. I am a practicing general dentist that has provided IV moderate sedation for my patients that need it for almost 30 years with the help of a single well trained assistant. While I applaud the addition of certifications and continuing education in the past, the addition of a third person to monitor is unnecessary.  The record of safety speaks for itself. There is no literature to suggest that adding a person to the treatment team will result in elimination of moderate sedation issues as it is already an immensely safe procedure with greater than a 99% successful safety record.

With regards to our current environment involving Covid-19, the unnecessary addition of a third person in the operatory subjects patients and other employees to increased potential exposure.

Furthermore, the economic considerations cannot be overlooked. Dental offices run efficiently and effectively relative to the number of employees required to deliver care and manage administrative tasks. Taking an employee away from their assigned task to simply stare at a monitor is unproductive and quite frankly, unnecessary. The requirement to add an employee for this task simply increases the overhead expenses to run the office. This expense will be passed on to the patient and thus increasing the costs associated with delivery dental care. These types of decisions should have an evidence based approach to support implementation. There is no evidence to support this. Also, I am unaware of any other state in the U.S. that has this requirement.

I strongly oppose the proposed modification to make mandatory a third member of the dental team during IV moderate conscious sedation.

Erik Roper, DDS, MAGD