I would like to make a technical comment, which will be separate from my professional comment, on this proposal.  I believe that it has been made unnecessarily difficult for the general public to ascertain the true changes that are being made to the regulations because there is currently the "Conforming rules to ADA guidelines on moderate sedation" changes that are also in their final stage and Governor's review.  These changes also affect the definitions in the proposal made that is up for commentary.  As such, it takes a careful review of the definitions minimal and moderate sedation to completely grasp the meaning of the proposed text that we have been asked to comment on.

As such, I would strongly encourage anyone to also read and incorporate the changes from "Conforming rules to ADA guidelines on moderate sedation" into their read of this proposal.  The final text is available here: http://townhall.virginia.gov/L/ViewXML.cfm?textid=12406

Thank you,

Jonathan L Wong, DMD, DADBA, DNDBA, FADSA *

Diplomate, American Dental Board of Anesthesia

Diplomate, National Dental Board of Anesthesia

Fellow, American Dental Society of Anesthesia

* The ADA does not recognize Dentist Anesthesiologists as specialists, therefore anesthesiology services are rendered as a general dentist with a general anesthesia permit.