DRAFT:

Comments from VANA to Virginia Board of Dentistry

Elaine J. Yeatts

Agency Regulatory Coordinator

9960 Mayland Drive

Suite 300

Richmond, VA  23233

elaine.yeatts@dhp.virginia.gov

Dear Ms. Yeatts,

On behalf of the Virginia Association of Nurse Anesthetists (VANA), I would like to submit comments regarding a proposal to Amend 18 VAC 60-20, Regulations Governing the Practice of Dentistry and Dental Hygiene submitted by Robert J. Haddad and open for public comment until July 22, 2009.

This proposal is “To amend regulations to: 1) eliminate the distinction between conscious sedation and deep sedation since deep sedation is a likely result; 2) institute a permitting process with inspection of dental offices to ensure they are appropriately equipped to handle an emergency situation; and 3) create an Anesthesia Review Committee to assist the profession and the public with issues relating to anxiety/pain control/sedation in dentistry.”

VANA is the professional association representing Certified Registered Nurse Anesthetists (CRNAs) in Virginia.  As you are aware, CRNAs provide more than 65% of anesthesia care in Virginia, and in the United States, in all patient care settings, from hospitals to ambulatory surgery centers to office based practices.  The safety record of CRNAs and the importance of anesthesia care was recognized by the Board of Medicine in its regulations on Office Based Anesthesia (18 VAC85-20-310 through 390), in which personnel, equipment and procedural requirements were delineated for management of different levels of sedation and general anesthesia for procedures conducted in office settings.  The foundation of the Virginia’s legislature’s requirement for these regulations was concern over patient safety in physician office practice in Virginia.  These regulations required that sedation and/or general anesthesia in an office based practice could not be provided by the operating physician, and that the personnel providing this care had to be appropriately trained and licensed.  In this, the Board of Medicine diverged directly from current practice in dental offices.

VANA believes that, as the Board of Dentistry considers the petition submitted by Mr. Haddad, it carefully consider not whether different requirements for administration of conscious sedation vs. deep sedation are appropriate, and that a “permitting process with inspection of dental offices to ensure they are appropriately equipped to handle an emergency situation”, but, even more important, that regulations require that emergency situations can be avoided, whenever possible, by requiring appropriately trained and licensed personnel are required to be responsible for the administration of sedation and anesthesia, specifically other than the operating dentist.  Only when patients have the protection of knowledgable, skilled and appropriately licensed anesthesia personnel solely dedicated to their anesthesia care when they are undergoing procedures, can they be assured of the safest possible care.

VANA agrees with the petitioner that the Board should “create an Anesthesia Review Committee to assist the profession and the public with issues relating to anxiety/pain control/sedation in dentistry.” VANA stands ready to assist in elucidating the critical issues that will determine how to best assure the anesthesia safety of all patients in Virginia.

If we can be of assistance, please do not hesitate to contact me.

H.M. (Mike) Black, CRNA, President