New anesthesia permit issues continue to be identified, prompt CDA advocacy

Moderate sedation permit implementation issues related to training, on-site inspections are relayed to dental board
February 14, 2023
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Quick Summary:
Significant changes to the pediatric dental anesthesia permitting system issued by the Dental Board of California occurred Jan. 1, 2022. While the dental board continues to navigate its first full renewal cycle for the newly established permits, two new implementation issues related to training requirements, on-site inspections and evaluations have been identified for the moderate sedation permit, as this article describes in detail. CDA is advocating for the dental board to make specific adjustments and amendments.

Significant changes to the pediatric dental anesthesia permitting system issued by the Dental Board of California occurred Jan. 1, 2022. However, although the changes, mandated by legislation signed into law in 2018, took effect last year, dentists could not apply for the newly established permits until the dental board adopted final regulations implementing the changes. The board adopted those regulations in August 2022, as CDA earlier reported.

While the dental board continues to navigate its first full renewal cycle for the newly established anesthesia and sedation permits, two new implementation issues have been identified for the moderate sedation permit.

Training requirements

Some dentists applying for the moderate sedation permit are having difficulty obtaining original certificates of completion for training that may have been completed decades ago and used to satisfy the training requirements of the conscious sedation permit. For example, a sedation program may have closed since a dentist originally completed training, or the training course used to apply for a conscious sedation permit is not deemed to be satisfactory for a moderate sedation permit. 

CDA is advocating that the dental board adjust its application processing standards to establish previous conscious sedation permitholders as meeting the training requirements necessary to obtain moderate sedation permits since the training requirements for both permits are nearly identical. 

On-site inspections and evaluators

Some dentists who have recently undergone on-site evaluations for their conscious sedation permit before needing to apply for the moderate sedation permit are now being required to undergo another substantively identical on-site evaluation within the first year of holding the moderate sedation permit. 

On-site evaluations, while essential in helping to ensure patient safety, when duplicative, can be very disruptive to a dental office. In addition to permitholders paying the evaluation fee again, the inspection must also be scheduled with two evaluators and a consenting patient because it would technically be the first one under the new permit. 

This issue is further exacerbated by the fact that dentists previously holding a conscious sedation permit are ineligible to serve as on-site evaluators for the moderate sedation permit because they have not held the new permit for a minimum of three years. Although the dental board made general/deep sedation permit evaluators eligible to serve as moderate sedation permit evaluators as an interim solution, the board’s capacity to perform the required number of on-site evaluations will be severely limited due to the board’s current interpretation of SB 501 and while they work to appoint new evaluators at each board meeting.

CDA is asking the dental board to consider amending the protocol for on-site evaluations for moderate sedation permitholders who previously held a conscious sedation permit. More specifically, CDA believes that the dental board already has the authority to accept previous inspections conducted before January 2021 and is asking the dental board to consider honoring recent on-site inspections provided to conscious sedation permitholders for the length of their full duration (six years). Additionally, CDA is asking the dental board to reconsider whether conscious sedation on-site evaluators are eligible to serve in the same capacity for moderate sedation on-site evaluations.

Next steps and resources

CDA is communicating with the dental board about the issues identified above and provided testimony about the impacts to health equity and access to care at the board’s February meeting. Any developments on these issues will be reported in the CDA newsroom as they become available. 

Access all the new permit requirements and applications on the dental board’s website. Also log in to your CDA account to see the resource Sedation and Anesthesia Permits for an updated table of requirements.

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