WDA Foundation

Sedation Regulations


Overview

Beginning in 2007, the Wisconsin Dentistry Examining Board began requiring dentists who provide enteral conscious sedation, parenteral conscious sedation or deep sedation/general anesthesia to obtain a sedation permit prior to providing sedation services to their patients.

Permits are issued by the DEB through the Department of Safety and Professional Services for three different levels depending on the type of sedation performed by the dentist: Class I for enteral conscious sedation, Class II for parenteral conscious sedation and Class III for deep sedation/general anesthesia.

No permit is specifically required for anxiolysis or nitrous oxide inhalation (as defined in the regulation), but there are “standard of care” and “office equipment” requirements that apply to all dentists providing anxiolysis or any other sedation service in their practice. All dentists are encouraged to thoroughly review the entire anesthesia rule and ensure current practices comply with regulations for the highest level of sedation utilized. You can view the actual regulation for dentists on the DSPS website.

If a dentist intends for the patient to only reach anxiolysis – which does not require a permit to administer – but the patient accidentally slips into the state of conscious sedation, the dentist will be held responsible for being permitted to the level of sedation that is actually achieved, regardless of intention. Due to this requirement, it would be wise for dentists to be prepared for a patient slipping into a level of sedation that may not have been intended.  Furthermore, all dentists, including those who only use sedation to achieve anxiolysis, must meet the specified standards of care outlined in Administrative Rule DE 11.09.

A DEB-approved sedation permit application can be obtained on the DSPS website. For additional information, contact the DEB’s Kris Hendrickson at Kris.Hendrickson@drl.state.wi.us or 608-266-2112.

To obtain a permit, dentists must submit proof of having completed a DEB-approved anesthesia course or an appropriate graduate level or post-doctoral training in anesthesia. If you attend a course not on the approved DEB list, you may apply for approval by submitting a syllabus that specifies content, hours and clinical cases contained in the training to: Office of Education and Examinations, Department of Regulation and Licensing, PO Box 8935, Madison, WI 53708. There is no guarantee of acceptance of your course, but the materials will be referred to the DEB for review.

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Permit levels

  1. A Class I Permit only allows a dentist to do oral conscious sedation-enteral.
  2. A Class II Permit allows a dentist to do the following: Conscious sedation-parenteral and conscious sedation-enteral. Dentists who hold a Class II permit do not have to obtain a Class I Permit.
  3. A Class III Permit allows a dentist to do all of the following: deep sedation, general anesthesia, conscious sedation-parenteral, and conscious sedation-enteral. Dentists who hold Class III Permits do not have to obtain any other permit.

The general requirements for obtaining a permit at the three specified levels follow.


Requirements

Class I/Conscious Sedation-Enteral Permit

(1) A Board-approved training course which includes:

  • 18 hours of didactic instruction addressing physical evaluation of patients, conscious sedation-enteral, emergency management, and conforms to principles in part 1 or 3 of the ADA “Guidelines for Teaching the Comprehensive control of Anxiety and Pain in Dentistry.”
  • 20 clinical cases using an enteral route of administration, which may include group observation

OR

  • Graduate level training approved by the board that includes the above requirements

AND

(2) Proof of basic cardiac life support certification for health care providers and a board approved course in airway management

OR

Proof of advanced cardiac life support certification

Note if the dentist is sedating patients age 14 or younger, the dentist must provide proof of certification in pediatric advanced life support. The DEB advises that dentists should be permitted one class above the level they intend to use when sedating patients in their practices. This could be interpreted to mean dentists who intend to administer anxiolysis (some dentists use Valium for this purpose) are encouraged to be permitted at the enteral conscious sedation level or Class I.

Class II/Conscious Sedation-Parenteral Permit

(1) Proof of one of the following:

A Board-approved training course which includes:

  • A minimum of 60 hours of didactic instruction addressing physical evaluation of patients, IV sedation, and emergency management
  • 20 clinical cases managing parenteral routes of administration

OR

Graduate level training approved by the Board that includes the above requirements

OR

Has been Wisconsin licensed and administered conscious sedation-parenteral on an outpatient basis for 5 years prior to Jan. 1, 2007

AND

(2) Proof of advanced cardiac life support certification

Note if the dentist is a pediatric specialist, the dentist may substitute proof of certification in pediatric advanced life support.

Class III/Deep Sedation and General Anesthesia

(1) Proof of one of the following:

  • A Board-approved postdoctoral training program in administration of deep sedation and general anesthesia
  • A postdoctoral anesthesiology program approved by the Accreditation Council for Graduate Medical Education
  • One year of advanced clinical training in anesthesiology meeting part 2 objectives of the ADA “Guidelines for Teaching the Comprehensive Control of Anxiety and Pain in Dentistry”
  • Has been Wisconsin licensed and utilizing general anesthesia for at least 5 years prior to Jan. 1, 2007

AND

(2) Proof of advanced cardiac life support certification

Note if the dentist is a pediatric specialist, the dentist may substitute proof of certification in pediatric advanced life support.

Note to Experienced Wisconsin Dentists and Oral Surgeons: If you have been using general anesthesia for at least five years as a Wisconsin licensee prior to Jan. 1, 2007, or if you have been administering parenteral conscious sedation for at least five years as a Wisconsin licensee prior to Jan. 1, 2007, you will be asked to submit an affidavit of work experience, along with proof of current advanced cardiac life support certification with your application. (Pediatric specialists may submit proof of current pediatric advanced life support.) Proof of prior education will not need to be submitted.

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FAQs

Is it correct to assume that a dentist who administers Valium occasionally in his/her office is exempt from the Class I permit unless a patient under his/her care slips from the defined state of anxiolysis into the defined state of conscious sedation (as defined on page 5/”definitions” section of the regulation)?

Yes. The best practice would be to obtain a permit for the sedation level above to avoid any violation of the Code.

What constitutes a “board-approved training program in airway management” for the purpose of obtaining a Class I permit?

For a complete listing of approved courses for Class I and Class II permits as well as for airway management courses, please click here.

Those credential holders who wish to apply for a Class I permit also have the option of completing a course in Advanced Cardiac Life Support (ACLS) or Pediatric Advanced Life Support (PALS); PALS is required for any dentist who sedates children under the age of 14.

What about the other courses approved for Class I permits that do not include an approved course in airway management?

Dentists completing those courses would still need ACLS or proof of completion of an approved airway management course.

How often does the certification for ACLS/PALS (Class II or Class III permits) or airway management (Class I permits) need to be renewed?

At least once every two-year licensure period. When a dentist applies for their initial sedation permit, they must provide proof of having current ACLS or PALS (for pediatric dentists) OR proof of recent completion of a DEB-approved airway management course.  Sedation permits are issued one time only and have the same number as the dentist’s license. Sedation permits are not “renewed” but will be considered current as long as the practitioner’s dental license is current.  When the dentist renews their license, they must attest that they have current CPR certification. They do not have to send in proof. The expiration date for all CPR, ACLS, PALS and Airway Management certifications should be printed on the individual cards, and it is the responsibility of each licensee to make sure that their certification is current at all times. ACLS and PALS courses routinely issue cards with specific expiration dates on them and it is important dentists to make sure their certification in ACLS/PALS and airway management remains current. Dentists who obtained training in airway management and did not receive certification cards with expiration dates should contact their course provider to find out the expiration date for their course. The DEB has indicated that airway management and ACLS/PALS courses would not be valid for longer than two years. 

When dentists are submitting an application for Class II or Class III permit, they can simply submit a copy of either their graduate or postdoctoral graduation diploma or their board certification to the Dentistry Examining Board (DEB) instead of having to ask the training program/educational institution to submit documentation on its curriculum and then be “approved by the board” as stated in 11.06(1)(a)2 or in 11.07(1)(a)1 or 2. Is this correct?

Yes. Credential holders are no longer required to obtain the signature of their training director to verify proof of successful completion of advanced residency training. The Board and the DSPS will accept copies of diplomas and/or board certification degrees as proof of completion of advanced training. If the programs attended are accredited through the American Dental Association Commission on Dental Accreditation and the specialty training includes standardized sedation training, the credential holder will qualify for a sedation permit. The credential holder’s signature on the affidavit holds them accountable for the truth and accuracy in reporting their advanced training.

How does one qualify for the “grandfather clause” for a Class II permit?

In order to qualify for the “grandfather clause” for a Class II permit, the credential holder must be able to demonstrate the utilization of conscious sedation administered parenterally on an outpatient basis for at least five years proceeding Jan. 1, 2007. This includes being able to document the use of parenteral sedation in EACH of the five years (hence the grandfather clause which is based on showing a history to your practice). A total of no less than 20 cases must be documented during the course of the five years (therefore, someone who completes 20 cases in one year is not eligible for the grandfather clause if they cannot show similar practice in the other four years). Credential holders are responsible for reporting the dates and the number of sedations performed-they will be on their “honor” and their signature on the affidavit holds them accountable for the accuracy of their self-reporting. These same requirements also hold true for a Class III permit (deep sedation/general anesthesia).

Individuals cannot qualify for the “grandfather clause” for a Class II or Class III permit if they have been practicing parenteral or deep sedation/general anesthesia in another state without also being licensed in Wisconsin. The grandfather clause can apply, however, if you have been licensed in Wisconsin while also being licensed and practicing in another state. The reason for the difference is that the rule specifically mentions the person has to have been licensed under the current chapter for the previous five years, limiting the clause to those who have held a Wisconsin license in the last five years or longer.

If dentists have taken a 60-hour course that includes 10 clinical cases (e.g. back in 2007, Minnesota offered a course prior with only 10 clinical cases), would the DEB consider working with them on an acceptable way that they could obtain an additional 10 cases in order to meet the requirements (60 hours and 20 clinical cases) for the Class II permit without having to find another 60-hour course that specifically includes 20 rather than 10 clinical cases?

The rule as written will not allow this at the present time. The 10 additional cases are required in order for the course to be approved.

There was information that sedation drugs can be administered intraosseously. Where would/does intraosseous administration of medication fall into your definitions of the routes of administration as currently defined in 11.02(9) – enteral or parenteral or neither?

Intra-osseous administration is considered parenteral administration. (4/3/2007)

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Check the status of your permit

Some WDA members have indicated a delay in receiving their permit after submitting their application.

Dentists can check the status of their application by contacting DSPS staff member Kris Hendrickson at kris.hendrickson@drl.state.wi.us.

DSPS said all applications are entered daily and, once entered, the dentist’s name and ID number will appear on the DSPS application tracking system. If a dentist has sent an application and hasn’t received a permit or confirmation of its receipt, the dentist should contact his/her bank to see if the check to DSPS has cleared.

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