6.3 Inspections, Permit Renewal, Hosting Attestations & Adverse Event Reporting
Key Takeaways
- A New Hampshire dentist must report any adverse event causing death, brain damage, or hospitalization during sedation or general anesthesia to the Board within 15 working days of discovery (RSA 317-A:20-a; Den 304.13).
- After an adverse event report, the Board conducts a root cause analysis, and a corrective action plan, or reasons for not taking action, is due within 60 days of the event.
- Adverse event reports identify the office or facility but not the dental professionals, employees, or patients involved, and the proceedings are privileged and confidential.
- Every 3rd biennial renewal, sedation facilities are re-inspected and permit-holding dentists repeat a simulated emergency management evaluation of at least 5 scenario-based drills (Den 402.01; Den 304.12).
- A hosting facility must submit each qualified provider's attestation to OPLC at least one week before that provider administers anesthesia on site (Den 403.01(b)).
Inspections, Renewal, Hosting, and Adverse Events
Required facility documentation — Den 304.09
Every facility or facility hosting permit holder keeps:
- Written anesthesia consent
- An anesthesia record: date, NPO status, availability of a responsible adult escort, time-based vital signs covering oxygenation, ventilation, and circulation, and drugs and doses with administration times
- An anesthetic emergency record: date, diagnosis of the critical event (such as laryngospasm or cardiac arrest), medical history, time of onset, vitals at onset and continuously, drugs, doses, routes and times, when CPR began and ended, time and manner of transfer, and vitals at transfer
- A site-specific emergency patient transfer form
- A scripted scenario for calling 911
- A written plan of each team member's role in an emergency
- Post-anesthesia instructions
A hosting facility also keeps the qualified provider's signed attestation, the biennial updates, proof of submission to OPLC, and any notice to OPLC that the hosting relationship ended.
Inspections and emergency evaluations — Den 304.10, 304.12, and 402.01
| Event | Requirement |
|---|---|
| Before any sedation at a new facility | Facility inspection by a qualified consultant (initial inspection under Plc 404) |
| Before a dentist's initial sedation permit | Pass a simulated emergency management evaluation (SEME) with an OPLC-contracted qualified consultant: at least 5 scenario-based drills, assessing the dentist's response and staff assignments and roles |
| What inspectors verify | Every Den 304.07 equipment and drug item is on site, and Den 304.09 documentation is complete |
| Every 3rd biennial renewal after the initial permit | Facility re-inspection (Plc 405; RSA 310:6, II) and a repeat SEME for the permit-holding dentist |
| Timing | Inspection and SEME are done together unless the dentist holds only a personal permit |
| Missed deadline | If the dentist fails to schedule or pass the inspection and SEME before midnight on the expiration date, the permit is not renewed, and the failure is misconduct under RSA 317-A:17 (Den 402.01(f)) |
The emergency drills follow the protocols in Appendix 3 of the AAOMS Office Anesthesia Evaluation Manual (9th ed., 2018) (Den 304.01(q)).
Renewal paperwork
At license renewal, sedation permit holders submit current ACLS, PALS, or both, as their permit type requires, and current BLS-HCP (Den 401.02(a)(3)–(4)). Renewals follow Plc 308.09–308.12.
Hosting facility attestations — Den 403.01
- The hosting dentist has each qualified provider who will administer GA, deep sedation, or moderate sedation complete the Attestation of Qualified Providers. The provider supplies name, facility, license type and number, business address and phone, and the permit holder's dated signature attesting that the provider has every Den 304.07 item in the facility each time anesthesia is given.
- The attestation must reach OPLC at least one week before the provider first administers anesthesia there.
- It remains valid until the facility permit expires, and an updated attestation is filed before then.
- The provider attests that the information is true and understands that knowingly false material information is a misdemeanor under RSA 641:3.
- If the hosting relationship ends, the facility notifies OPLC within 15 days.
Adverse events — RSA 317-A:20-a and Den 304.13
| Element | Rule |
|---|---|
| What | Adverse health care events resulting in death, brain damage, or hospitalization in the dentist's office or facility during general anesthesia, deep sedation, or moderate sedation. Den 304.13 adds minimal sedation |
| Who reports | Any licensed dentist |
| When | As soon as reasonably possible, but no later than 15 working days after discovery |
| Contents (Den 304.13(c)) | Procedure; pre-operative physical condition; drugs and dosages; techniques; the adverse occurrence, including signs and symptoms, treatment, and response; and the patient's condition when the procedure ended |
| Anonymity | Identify the office or facility, but not the dental professionals, employees, or patients |
| Board action | The Board conducts a root cause analysis, using the OPLC enforcement division, and issues the report to the dentist |
| Corrective action | The dentist provides a corrective action plan, or reasons for not taking corrective action, within 60 days of the event. If the analysis and plan are already done, include them with the report |
| Protection | Proceedings are privileged and not subject to discovery or subpoena; information given to the Board is confidential and exempt from public access under RSA 91-A |
| Failure | Not reporting or not implementing a corrective plan is misconduct (RSA 317-A:17, II(o); Den 407.01(q)) |
Separately, Den 501.01(f) requires a dentist to inform the Board in writing within 15 working days of any patient mortality associated with dental treatment, whether or not sedation was used.
Emergency exemption report for young children
A qualified dentist who sedates a child 8 or younger under GA or deep sedation without a separate dedicated provider on an emergency basis files an Emergency Exemption form with OPLC within 15 working days. The form covers the procedure, the patient's condition, the personnel, drugs and techniques, any adverse occurrence, and the outcome, and it does not identify the patient (Den 304.08(g)–(h)).
A patient under moderate sedation in a dental office has a cardiac event and is hospitalized. When must the dentist report the event to the Board under RSA 317-A:20-a?
A dental office with a facility hosting permit engages a new CRNA to provide deep sedation starting next month. What does Den 403.01 require before the CRNA's first case?
At a sedation permit dentist's third biennial renewal after the initial permit, what does Den 402.01 require?