I have been providing safe, effective oral sedation to patients with high anxiety since 2007 without any issues.  I have maintained the use of a pulse oximeter and had the appropriate emergency equipment available.  I DO NOT understand why an EKG is necessary for moderate oral sedation, and DO NOT agree with this burdensome requirement.  Additionally, the need for the dentist to be in the room during oral sedation is unnecessary when there are properly trained and certified assistants who can monitor the patient appropriately.

I am not providing IV sedation, however, I know oral surgeons who sedate their patients with more intense drugs than the ones I use who do not have EKGs for each patient.  Although I certainly understand the need to protect patients and doctors, this is a cruel choice and undermines the whole concept of minimally invasive oral sedation.  This really will only hurt patients who need care under sedation due to the inability to find dentists, under the new guidelines, to complete their general dentistry needs.  I implore you to change the requirement for having an EKG for moderately sedated patients and make it mandatory only for IV sedation where it is most useful.  The pulse oximeter is quite capable of determining the appropriate stats that require monitoring during traditional oral sedation--especially since the patient is able to breathe on his/her own and answer simple commands. 

PLEASE reconsider your decision, and remove the mandate for the EKG for moderate oral sedation and the requirement for the dentist to remain in the operatory.

Thank you!