I'm reading the petition to consider changes of the current sedation regulations and would ask that the parties that will be deciding this important matter to consider the implications of this petition carefully.  Thank you for reviewing my response.

First, Mr. Haddad's request to eliminate the distinction between conscious sedation and deep sedation "since deep sedation is a likely result" does not agree with the training I received, the research I have reviewed or the clinical experience of the dentists in my practice.  I would ask that the Board of Dentistry do a thorough review of the research to verify the truth of this claim by Mr. Haddad.  I am not sure it can be scientifically supported.  Additionally, my training and my specialty board define deep sedation as a category of conscious sedation, not a separate form of sedation.  Mr. Haddad appears to be comparing to a level of conscious sedation to conscious sedation, not a logical comparison.  A truer comparison would consider relatable categories; these are not since deep sedation is indeed a distinct level within conscious sedation. 

Second, I would be in favor of some sort of permit process as long as a large financial burden is not placed on the practitioner and this inspection process can be completed in a timely fashion, neither of which I am certain a bureacratic agency can guarantee.  I would hate to have to give up my ability to perform mild and moderate sedation to benefit so many pediatric patients in my area because I couldn't afford the cost of yet another license or renewal fee.  The costs associated with practicing dentistry already are high, particularly for a practice such as mine that accepts Medicaid.  Adding an additional fee makes it extremely difficult to justify the service, even though conscious sedation is greatly needed. 

Third, isn't the Board of Dentistry already tasked with assisting the profession and the public with issues relating to anxiety/pain control/sedation in dentistry?  The Board has published guidelines and requirements, they review cases related to these subjects and have access to qualified expert witnesses as needed.  What additional benefits would Mr. Haddad expect another committee to provide?

I would suggest that the Board rather than deleting the distinction between conscious sedation and deep sedation spend time more clearly defining the definitions of the varying levels of conscious sedation since conscious sedation has varying levels from mild to moderate to deep rather than eliminating the class of procedures currently defined as conscious sedation.  Deep sedation is a level of conscious sedation and needs to be considered within the confines of conscious sedation.  Deep sedation is currently placed alongside general anesthesia in the Virginia guidelines which is confusing to many people.  Conscious sedation by the AAPD guidelines is broken into 3 levels (minimal:  drug induced state in which patients respond normally to verbal commands, ventilatory and cardiovascular functions are unaffected; moderate:  drug induced depression of consciousness with the ability to maintain a patent airway, maintain purposeful response to stimulation and spontaneous ventilation is adequate;  deep: drug induced depression of consciousness during which patients cannot be easily aroused but respond purposefully after repeated verbal of painful stimulation, ability to maintain ventilatory function may be impaired and patient may require assistance in maintaining a patent airway).  If Virginia is going to allow practitioners to perform conscious sedation, then all 3 levels of sedation should be listed and considered within the criteria/requirements for conscious sedation and general anesthesia should be considered separately with its criteria/requirements (even if they are the same as general anesthesia) to reduce the confusion.  Something as simple as changing the title of section 18VAC60-20-120 from "Requirements to administer conscious sedation" to "Requirements to administer mild or moderate conscious sedation" along with the definitions that set a standard for this category would be most helpful.  Change the title of 18VAC60-20-110 from "Requirements to administer deep sedation/general anesthesia" to "requirements to adminster deep conscious sedation/general anesthesia" would keep these sections parallel in content and definition.  It would hopefully help reduce confusion as well.

I appreciate the opportunity to comment.