The KY board has revised its original draft O-regs. The revision contains many of the KDA's suggestions. It has two problems:
(1) for adult moderate oral sedation, the applicant will be required to document 3 live patient cases. The use of live patient cases for oral sedation training involves many logistical and ethical issues. First, there aren't any oral sedation courses that utilize live patients. Second, of the states that have adopted the 3-live-patient requirement (ME, NC, ND, NH), only NC has promoted a sensible way to accomplish the cases: After training, the dentist sends in his/her permit application to the board and THEN performs the 3 live cases in his/her own office on his/her own patients then makes those 3 charts available to the board-appointed inspector during the office inspection process. At least this complements the training process. The other three states require the dentist to go to a permitted dentist's or oral surgeon's office to observe 3 live cases, and the permitted dentist or oral surgeon writes a letter to the board. This is cumbersome and the oral surgeon is likely doing IV, which doesn't help the learning process much. The KY board should remove the 3-live-patient requirement or, alternatively, do what NC does.
(2) Pediatric minimal sedation could only be done with a II-P permit, which can only be acquired by completing a pediatric residency. This wreaks of restraint of trade, but more importantly, it will crush pediatric access to care because there aren't enough pediatric dentists, especially in rural areas where there may not be any. The KY board should remove the age delineation for minimal sedation so GPs can provide treatment to this fastest growing underserved portion of the dental population. A pedodontist on the KDA's anesthesia committee seems to agree with this analysis.
The KY board is strongly listening to the recommendations of the KDA anesthesia committee. Stay involved. This is only the beginning.
John Bitting, DOCS Regulatory Counsel
