DOCS Education supports reasonable oral sedation regulations that carefully and thoughtfully balance patient safety with access to care. Having a permit/inspection process and an anesthesia committee are certainly reasonable. Most state boards have anesthesia committees, and 39 of 50 states require conscious sedation permits (3 more will by next year). However, please keep in mind that the recession has stripped away the ability of most states to fund the manpower necessary to hold office inspections quickly AND the inspection process (in other states) was already slower than molasses in January anyway. We believe that a self-inspection by affidavit with the threat of random Board inspections is just as effective (CA, ID, WA, WI do this). However, if the board does adopt an inspection process, then we would recommend peer review by experienced oral sedation volunteer dentists (MD, ME, WV will be doing this). These options will preserve a healthy balance between patient safety and access to care.

As for eliminating the distinction between conscious sedation and deep sedation because deep sedation is a likely result, this is asinine and should be denied outright. While my fellow commentors and I may disagree as to the training that should be required for oral conscious sedation, I doubt any of them believe that the level of sedation known as "conscious sedation" doesn't exist in the spectrum of sedation. Otherwise, there would be a gap between anxiolysis and deep sedation such that a patient went straight from wide awake to practically unconscious without exhibiting the oxymoron we call "conscious sedation" along the way. No state has such an onerous regulation and none are considering it.

Thank you for your time and consideration.