The CDA is calling for the board to adjust its application processing standards to establish that previous conscious sedation permit holders meet the training requirements necessary to obtain moderate sedation permits. The association reasons that the training requirements for both permits are "nearly identical."
The association is also asking the dental board to consider amending its protocol for onsite evaluations for moderate sedation permit holders who previously held a conscious sedation permit. The CDA said that while these evaluations are essential, they can be disruptive to dental offices when duplicative.
Additionally, permit holders must pay the evaluation fee anew, and the inspection must be scheduled with two evaluators and a consenting patient. This is because the onsite evaluation would technically be considered the first assessment under the new permit, the association said.
The CDA said in a statement that it believes the board already has the authority to accept previous inspections conducted before January 2021. The association is also asking the board to honor recent onsite inspections provided to such permit holders for the full six-year period. Additionally, the CDA is asking the board to reconsider whether conscious sedation onsite evaluators are eligible to serve in the same capacity for moderate sedation onsite evaluations.
The dental board made changes to its pediatric dental anesthesia permitting system in early 2022. However, the association said dentists could not apply for the newly established permits until the dental board adopted final regulations implementing the changes, which took place in August 2022.
The CDA said it is communicating with the board on these issues, including providing testimony about the impacts on health equity and access to care at the dental board's February meeting.
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