Dear Ms Yeatts,
The VANA’s comments reflect the same priority order as presented by Mr. Bitting in the Petition.
VANA generally supports the use of HFPS and agrees that simulated patient technology will improve the quality of training in effective dentistry sedation techniques; however, VANA’s support is based on the assumption that HFPS training provides rescue and airway management practice, as well as practice in the recognition of patient deterioration.
Moderate Sedation Dose: VANA does agree with the DOCS that a doctor should be allowed to check on other patients or attend to a dental emergency while an appropriately trained individual monitors the patient; however, VANA is concerned that the absence of the doctor is based on the dose administered, and not on the patient’s response to the medication administered.
DOCS comments reflect an assumption that, given the same relative dose of sedative medication, all patients will respond similarly. Unfortunately, VANA’s experience indicates otherwise, and what for one patient could be a positive response to a particular dose, could result in death for another patient.
Additionally, VANA is concerned with the lack of uniformity among the varying health regulations related to anesthesia administration. For instance, VANA notes the term “minimal conscious sedation” equals a level of anesthesia administration on par with what physicians call “light sedation.” As defined in
Further, the standards for who may act as a qualified individual differ significantly between medical and dental practices. Current office-based anesthesia regulations governing the Practice of Medicine, Osteopathy, Podiatry and Chiropractic require an MD who administers conscious sedation to be assisted by a licensed nurse. This standard is significantly more stringent that the regulations Governing the Practice of Dentistry and Dental Hygiene which require the dentist have a “second person” who qualifies to assist as long as that person has certification in basic resuscitation techniques.
Uniformity among anesthesia safety regulations is a key factor to ensuring a patient’s safety expectations and sense of well being—Anesthesia patients expect the same safety standards in all practice settings, and regardless of whether a procedure is performed in a dental, oral surgeon, or physician’s office, the same anesthesia standards should apply. VANA suggests that the definitions and rules related to anesthesia administration should be made uniform throughout
Minimal Sedation Monitoring: While VANA does not object to an appropriately trained individual or dentist monitoring a minimally sedated patient every five minutes, VANA’s support is based on the premise that the dentist’s absence is a result of the patient’s positive response to the medication, not the dose administered.
Patient safety is, and always has been, the number one priority of nurse anesthetists and VANA recognizes that each patient may have a different reaction and/or response to medication. Thus, VANA believes it is imperative that the monitoring of a patient by a qualified individual should occur only if the dentist’s absence is based on an evaluation of the patient’s response to the medication, and not upon the assumption that the dose administered allows the dentist’s absence.
VANA supports the requirement of an additional fourteen hours of training, including actual practice in airway management as appropriate to the setting. VANA agrees it is important that those administering oral sedation have the knowledge and skill to deal with medically complex patients, including airway management training, so as to better ensure patient safety.
VANA supports the requirement of eighteen hours of training for an appropriately trained individual or a qualified auxiliary, as long as the training includes actual practice experience on an HFPS or live patient.
The VANA appreciates the opportunity to provide comment and if we can be of any further assistance, we ask that you do not hesitate to contact us. Our telephone number is 804-754-4122.
Sincerely,
Paul Werbin, RN, MS, CRNA
VANA President
cc: Ms. Sandra Reen, Executive Director, Virginia
Board of Dentistry