VIA EMAILJanuary 29, 2024
Mr. David Schaibley
Execu�ve Director
North Dakota State Board of Dental Examiners
PO Box 7246
Bismarck, ND 58507
Dear Mr. Schaibley,
On behalf of the 9,000 members of the American Associa�on of Oral and Maxillofacial Surgeons(AAOMS), and the 22 members prac�cing in North Dakota, we appreciate your outreach to solicit
comments on the proposed changes to the state’s dental regula�ons. We commend the North Dakota
State Board of Dental Examiners for its though�ul and balanced amendments. While we had noconcerns with the presented edits, we would like to suggest two addi�onal areas for the Board’s
considera�on that would beneﬁt the oral and maxillofacial surgery (OMS) community.
Oﬃce anesthesia inspec�on cycles
Currently, North Dakota maintains a three-year oﬃce anesthesia site inspec�on cycle, standing as theonly state with such a dura�on. Most states operate on a ﬁve- to six-year renewal cycle. This dura�ono�en aligns with the AAOMS Oﬃce Anesthesia Evalua�on (ﬁve years) or a mul�ple of their own state
anesthesia permit renewal cycle (six years).
AAOMS and the North Dakota Society of Oral and Maxillofacial Surgeons (NDSOMS) recommend
amending the state’s inspec�on cycle to either a ﬁve- or six-year renewal cycle to align with other states'standards. Such a change is likely to op�mize state resources, synchronize with prac��oners' licensing
�melines, adhere to na�onal standards, and reduce administra�ve burdens without compromisingpa�ent safety.
Dental Anesthesia Assistant permits
Currently, North Dakota restricts dental anesthesia assistant roles to those achieving the status of aregistered dental assistant (RDA) or qualiﬁed dental assistant (QDA). While acknowledging this career
pathway for those ini�ally serving as dental assistants, we propose expanding the eligibility to include
healthcare professionals with advanced healthcare training, such as registered nurses (RNs) andemergency medical technicians (EMTs).

NDSBDE – Jan. 29, 2024

In previous discussions with the state, concerns were raised about the Dental Board dicta�ng theprac�ce of non-dental professionals. In response, NDSOMS proposes establishing a separate dental
anesthesia assistant creden�al with educa�on prerequisites limited to the comple�on of a boardapproved dental anesthesia assistant educa�on and training course. (For reference, the Dental
Anesthesia Assistant Na�onal Cer�ﬁca�on Examina�on (DAANCE) – which is recognized by the Board –has historically been taken and passed by dental assistants, RNs and EMTs and these professionals
ac�vely prac�ce alongside OMSs in other states around the country.) Individuals holding the dental
anesthesia assistant creden�al under this proposal would only be authorized to perform dental
anesthesia assistant func�ons, not those of an RDA or QDA, unless mee�ng the exis�ng requirements forthese professions as outlined in the state’s regula�ons.
This proposal maintains the state's current requirements while restructuring the regulatory chapter toaccommodate non-dental auxiliary personnel with the necessary training. It aligns North Dakota withother states that allow non-dental assistants to serve in similar roles with appropriate training.
Moreover, it provides a valuable pathway for paraprofessionals to address widespread dental assistantshortages. NDSOMS is eager to engage in further discussions with the Board on this proposal.
We appreciate the Board’s considera�on of these points and express gra�tude for the opportunity tocomment. We an�cipate ongoing discussions to mutually serve the ci�zens of North Dakota. For anyinquiries, please contact Sandy Guenther, Manager of State Government Aﬀairs and Advocacy
Engagement, at sguenther@aaoms.org or 800-822-6637.
Sincerely,

Mark A. Egbert, DDS, FACSAAOMS President
CC:Michael G. McMahon, DDS, President, NDSOMSCharles A. Crago, DMD, MD, FACS District V Trustee, AAOMS
Karin K. Wi�ch, CAE, Execu�ve Director, AAOMS
William R. Sherwin, JD, Execu�ve Director, NDDASrini Varadarajan, JD, Associate Execu�ve Director, AAOMS