6.1 Sedation Levels, Permit Types & Qualifications (Den 304.01–304.06)
Key Takeaways
- Moderate sedation is drug-induced depression of consciousness in which patients respond purposefully to verbal commands, alone or with light tactile stimulation, with no airway intervention required (Den 304.01(i)).
- New Hampshire issues facility permits, facility hosting permits, general anesthesia/deep/moderate sedation permits, moderate-sedation-only permits, moderate sedation permits with pediatric qualification, and pediatric minimal sedation permits (Den 304.03).
- A moderate-sedation-only permit covers patients 13 and older, while the pediatric minimal sedation permit covers minimal sedation of patients under 13 (Den 304.01(j), (m)).
- A general anesthesia permit requires CODA-accredited dental anesthesiology or oral and maxillofacial surgery training, or equivalent ADA Part III C training, plus current ACLS and PALS and a passed simulated emergency management evaluation (Den 304.04(c)).
- A dentist needs no personal sedation permit when a separate dedicated qualified provider administers the anesthesia exclusively, but the facility must hold a facility or facility hosting permit (Den 304.06).
Sedation Levels and Permit Types
Statutory framework
- Administering dental anesthetics, general or local, is the practice of dentistry (RSA 317-A:20, I(g)).
- A dentist or dental facility that wishes to administer general anesthesia, deep sedation, or moderate sedation must apply to OPLC for the appropriate permit and pay a fee. OPLC requires documentation of competence under the Board's rules, and the rules must require CE as a condition of issuing or reissuing a permit (RSA 317-A:20, II).
- RSA 317-A:12, XII-a directs rules on credentials, applications, on-site evaluations, permit criteria for dentists and facilities, and the physical presence of a qualified provider. RSA 317-A:12, XII-c covers minimal sedation.
- Den 503.07: no dentist may use general anesthesia, deep sedation, or moderate sedation on an outpatient basis except under Den 304.
The current Den 304 was readopted effective August 3, 2025 (Document #14246).
The four depths — Den 304.01
| Level | Responsiveness | Airway and breathing | Cardiovascular |
|---|---|---|---|
| Minimal sedation (formerly anxiolysis) | Responds normally to tactile stimulation and verbal command; cognition and coordination may be impaired | Independently and continuously maintains airway; ventilation unaffected | Unaffected |
| Moderate sedation (formerly conscious sedation) | Responds purposefully to verbal commands, alone or with light tactile stimulation | No interventions needed; spontaneous ventilation adequate | Usually maintained |
| Deep sedation | Not easily aroused; responds purposefully after repeated or painful stimulation | May need help keeping the airway open; ventilation may be inadequate | Usually maintained |
| General anesthesia | Not arousable, even by painful stimulation | Often needs airway assistance; positive pressure ventilation may be required | May be impaired |
A patient whose only response is reflex withdrawal from repeated painful stimuli is not in minimal sedation (Den 304.01(h); RSA 317-A:12, XII-c(a)).
Permit types — Den 304.03
| Permit | Authorizes | Holder |
|---|---|---|
| Facility permit | Administration at that site of GA/deep/moderate, moderate only, or moderate with pediatric qualification, by the permit-holding qualified dentist who keeps the required equipment on site | Facility (qualified dentist named) |
| Facility hosting permit | A qualified provider other than the permit-holding dentist administers at the site and brings additional equipment, drugs, and supplies | Facility (hosting dentist named) |
| GA, deep, and moderate sedation permit | Qualified dentist administers all three levels to patients of all ages at a facility holding the matching facility or hosting permit | Dentist |
| Moderate sedation only permit | Moderate sedation to patients 13 and older | Dentist |
| Moderate sedation permit with pediatric qualification | Moderate sedation to patients of all ages | Dentist with added pediatric training |
| Pediatric minimal sedation permit | Minimal sedation to patients under 13 | Dentist |
A facility may host a qualified provider only up to the level of its own permit (Den 304.03(b)).
Definitions to know: a qualified provider is a qualified dentist, a physician anesthesiologist licensed under RSA 329, or a nurse anesthetist licensed under RSA 326-B:18 (Den 304.01(p)). The hosting dentist is the dentist named on a facility or hosting permit and responsible for that facility (304.01(g)). The operating dentist performs the procedure while a separate qualified provider sedates (304.01(l)).
Baseline requirements — Den 304.02
- Before a sedation permit issues, the dentist must pass a simulated emergency management evaluation (SEME) by a qualified consultant at a New Hampshire dental facility.
- A permit-holding dentist may sedate only at a facility holding a corresponding facility or facility hosting permit.
- A facility must pass a facility inspection by a qualified consultant before its permit issues.
- Permit-holding dentists repeat the SEME every 3rd biennial license renewal, and facilities repeat inspection every 3rd biennial renewal.
Qualifications — Den 304.04
| Permit | Training | Life support | Other |
|---|---|---|---|
| GA, deep, and moderate | Advanced anesthesiology training described in Part III C of the ADA Guidelines for the Use of Sedation and General Anesthesia by Dentists (2016), or a CODA-accredited advanced program in dental anesthesiology or oral and maxillofacial surgery | ACLS and PALS | NH license; passed SEME |
| Moderate only | ADA Guidelines Part III B | ACLS | NH license; passed SEME |
| Moderate with pediatric qualification | ADA Part III B plus Part V of the ADA Guidelines for Teaching Pediatric Pain Control and Sedation (2021) | ACLS, PALS, or both, matching the patient ages treated | NH license; passed SEME |
| Pediatric minimal | ADA Part III A plus the inhalation and enteral minimal sedation objectives in Part IV of the 2021 pediatric teaching guidelines, including airway management and rescue from moderate sedation | — | NH license |
| Facility | — | — | Qualified dentist holds an NH license and a sedation permit; passed on-site inspection |
| Facility hosting | — | — | Hosting dentist holds an NH license; passed on-site inspection |
Applications — Den 304.05
Applications are processed under Plc 304.06–304.10 with fees under Plc 1002.11. The facility application lists the practice name, hosting or qualified dentist, every qualified provider with license type and number, and the site. The dentist application lists each facility where the dentist will sedate, the training basis, BLS-HCP, ACLS, and PALS status, and every clinical staff member's certifications with expiration dates. Every applicant signs an attestation. Knowingly giving false material information is a misdemeanor under RSA 641:3.
Separate dedicated provider — Den 304.06
A dentist does not need a personal sedation permit if general anesthesia, deep sedation, or moderate sedation is administered exclusively by a separate dedicated qualified provider, such as a physician anesthesiologist or CRNA. The hosting dentist must still obtain a facility or facility hosting permit.
Board composition link
RSA 317-A:2, I requires one dentist Board member to hold a current GA and deep sedation permit. The Anesthesia and Sedation Committee (RSA 317-A:2-b) drafts the Board's anesthesia rules (section 1.3).
A dentist wants a permit to provide moderate sedation to adults and teenagers, but never to children under 13. Which permit fits, and what life-support certification does it require?
A dentist arranges for a physician anesthesiologist to provide all general anesthesia in her office; she only performs the dental procedures. What permits are required under Den 304.06?
During a procedure, a patient cannot be easily aroused but responds purposefully after repeated painful stimulation and may need help maintaining an open airway. Under Den 304.01, what level of sedation is this?