Welcome to the AAOMS Advocacy Insider, the exclusive publication for members of AAOMS’s grassroots program, the OMS Action Network. Visit AAOMS.org/Action for more information on the OMS Action Network and past editions of the AAOMS Advocacy Insider.

Items of Note

New AAOMS paper addresses CRNA role in dental offices

A newly released white paper from AAOMS highlights the organization's ongoing dedication to patient safety and excellence in dental anesthesia care. While acknowledging the important role of CRNAs, the paper emphasizes that dental offices present unique challenges that require anesthesia providers to have specialized training in dentistry. AAOMS asserts that CRNAs should only administer anesthesia in dental settings under the supervision of a dentist or physician with appropriate dental anesthesia training. The white paper is intended to support advocacy efforts at both the state and local levels.

AAPD introduces model rules for pediatric moderate sedation

The American Academy of Pediatric Dentistry (AAPD) has released model anesthesia regulations intended for adoption by states. However, the proposed language – focused solely on moderate sedation – lacks critical details. Key concerns include:

• A pediatric dentist could be authorized to perform parenteral moderate sedation even if their residency only included training in enteral sedation.
• "Pediatric" is defined as ages 0–12, which may not align with other regulatory or clinical standards.
• Permit approval relies on written attestations of competency from residency or continuing education course directors, raising concerns about potential conflicts of interest.
• The regulations equate recommendations from the American Academy of Pediatrics (AAP) with those from dental-specific organizations like the AAPD and ADA, potentially diluting the authority of dental-focused guidelines.
• Many requirements use vague language, such as “regularly,” without specifying timelines for compliance or review.

AAOMS continues to review these model regulations and engage with key stakeholders.

ELSA reintroduced in the 119th Congress

The Ensuring Lasting Smiles Act (ELSA), sponsored by Senators Tammy Baldwin (D-Wis.) and Jodi Ernst (R-Iowa), along with U.S. Reps. Kim Schrier, MD (D-Wash.) and Neal Dunn, MD (R-Fla.), is expected to be reintroduced later today for the 119th Congress. 

ELSA would correct inequities in health insurance coverage for the treatment of patients with congenital craniofacial anomalies. This legislation was last introduced in the 117th Congress, passing in the House in April 2022. In preparation for its reintroduction in the 119th Congress, AAOMS has been working with bill sponsors and a broad coalition of provider and patient advocacy organizations to incorporate congressional feedback and strengthen ELSA’s language. 

AAOMS members are encouraged to participate in a grassroots campaign to urge members of Congress to cosponsor ELSA. Help ELSA get over the finish line!

State Updates

N.H. anesthesia regulations finalized, efforts ongoing

On April 18, the New Hampshire Joint Legislative Committee on Administrative Regulations (JLCAR) approved the revised rules package submitted by the New Hampshire Board of Dental Examiners (NHBDE), marking a key step in modernizing the state’s anesthesia regulations. The final rules establish a long-debated pediatric permit and require facility permits for each location where anesthesia is administered. The Dental Board officially adopted the package on May 5, with the rules set to take effect 90 days from that date. Additional guidance and processes for implementation remain pending as of this report, and OMSs are recommended to frequently check the NHBDE website for updates.  

Ill. Pediatric dentists propose moderate sedation changes

The Illinois Society of Pediatric Dentists has proposed an amendment to the dental board makeup bill that would modify the prerequisites for obtaining a moderate sedation permit. Under current Illinois law, all applicants must demonstrate 20 personal patient experiences administering moderate sedation in addition to completing formal training through a CODA-accredited residency or other approved program. The proposed change – though limited – would restrict this experiential requirement to dentist anesthesiologists, allowing pediatric dentists to qualify by completing a CODA-accredited program alone. This proposal has raised concerns, as many pediatric dental residencies reportedly do not provide the minimum number of patient experiences required by CODA standards. The Illinois Society of Pediatric Dentists argues that OMSs are only required to complete a CODA-accredited residency to obtain a deep sedation/general anesthesia permit. The Dental Board and the Illinois State Dental Society oppose the proposed amendment.

Colorado sunset review bill signed into law

On May 5, Gov. Jared Polis signed SB25-194, the Colorado Dental Practice Act Sunset Review Bill, into law. The legislation extends the Colorado Dental Board for an additional nine years and includes several significant updates. Of note, the Colorado Society of Oral and Maxillofacial Surgeons played a key role in shaping two major provisions in the bill’s final language:

• Itinerant Practice: Requires itinerant surgery providers to establish follow-up and post-procedure care plans with licensed surgical specialists located within a reasonable distance of the initial care site. These plans must not designate hospital emergency rooms or urgent care centers for follow-up care. Written protocols for emergency care are also required.
• Dental Board Membership: Mandates the inclusion of an OMS on the Dental Board, effective July 1, 2031.

Additional provisions of note include: 

• Teledentistry: Expands the definition of dentistry to include both physical and digital impressions.
• Specialty Recognition: Aligns recognized dental specialties with those defined by the National Commission on Recognition of Dental Specialties and Certifying Boards or the U.S. Department of Education.
• Immunization Authority: Authorizes dentists to administer respiratory and oral health immunizations, including HPV vaccines, to individuals aged six and older.
• Neuromodulators and Dermal Fillers: Permits dentists and dental hygienists to administer these treatments to established dental patients.
• E-Prescribing: Grants licensed dentists the authority to prescribe medications and orders electronically.
• Anesthesia Permitting: Establishes an expedited application and permitting process for individuals who have completed accredited residency or postdoctoral training in moderate sedation, deep sedation, or general anesthesia in accordance with industry standards.

The final language will take effect 90 days following the adjournment of the general assembly. 

Florida bans fluoride statewide

Florida lawmakers approved SB 700, the Florida Farm Bill, which includes language prohibiting the use of certain additives in water systems, effectively banning community water fluoridation statewide. The bill awaits Gov. Ron DeSantis’s (R) signature, and he has signaled support. Florida would become the second state this year to enact such a ban, following Utah. Public health advocates have raised concerns, citing fluoride’s role in preventing tooth decay. Similar legislation is pending in Louisiana, while Kentucky recently repealed its statewide fluoridation mandate, leaving the decision to local communities.

Insurance changes adopted in states

North Dakota Gov. Kelly Armstrong (R) signed several bills aimed at improving dental insurance practices. HB 1481 establishes a minimum dental loss ratio of 75 percent, requiring insurers to spend at least that portion of premiums on patient care or issue refunds to policyholders. SB 2280 imposes deadlines for prior authorization decisions to help reduce administrative delays. SB 2375 allows insurers and dental providers to voluntarily negotiate on non-fee-related matters, such as quality standards and administrative processes.

The Washington House and Senate passed HB 1535/SB 5351, requiring payors to disclose credit card payment fees and offer a no-fee alternative. The bill also directs the Office of the Insurance Commissioner to convene stakeholders to review dental loss ratios and payment practices, with a report due by June 30, 2026. The bill awaits action by Gov. Bob Ferguson (D).

Arkansas passed HB 1241 mandating Medicaid coverage for craniofacial and anesthesia-related dental services at CODA-accredited facilities. The bill caps reimbursement at $3,750 per episode and $5,000 annually per adult patient needing complex care with sedation. Currently, only the state’s soon-to-open dental school qualifies under this provision.

CRNAs granted quasi-independent status in W.Va. 

With the passage of SB 810, CRNAs in West Virginia gained quasi-independent practice authority. Although the bill specifies that CRNAs do not have full independent practice, it permits them to work in cooperation with, rather than under the direct supervision of, a physician, dentist, or podiatrist. Dentists must still obtain sedation permits when collaborating with a CRNA.

Federal Updates

Executive order seeks reforms to higher ed accreditation 

President Trump signed an executive order on April 23 that calls out the current higher education accreditation system, specifically referencing the Liaison Committee on Medical Education and the Accreditation Council for Graduate Medical Education, for failing to ensure quality education, and instead, promoting discriminatory practices under the guise of diversity, equity, and inclusion (DEI). It orders the Department of Education and other federal agencies to investigate and take action against accreditors and educational institutions that impose DEI-related standards deemed unlawful and calls for student-focused accreditation principles that prioritize educational value, program outcomes, academic freedom, and legal compliance. Additionally, it calls on the ED Secretary to implement reforms to increase competition among accreditors and oversight of the accreditation recognition process. AAOMS will be monitoring these efforts for potential impact on OMS residency training programs.

Trump Administration proposed significant HHS cuts

The Trump Administration on May 2 released its FY 2026 “abbreviated” budget request, which seeks $33 billion – or 26.2 percent – in cuts for HHS. The full budget request is anticipated to be released later this month. The administration recommends cuts to most HHS agencies, with the largest reductions targeting the NIH, and others impacting oral health programs. The president’s budget request marks the start of the annual appropriations process. While the request does not carry the weight of law, it signals the administration’s fiscal policies priorities, which the Republican-controlled Congress may closely follow. AAOMS signed on to a coalition letter urging congressional appropriators to reject the proposed cuts.

AAOMS weighs in against possible pharmaceutical tariffs

AAOMS submitted a letter in response to the Trump Administration’s request for stakeholder input regarding the potential imposition of tariffs on pharmaceutical products. In the letter, AAOMS noted the association’s opposition to such tariffs, citing concerns about higher costs for providers and patients, as well as the risk of increased drug shortages resulting from supply chain disruptions.

House committees mark up reconciliation bills

Six House committees, including the Education and Workforce Committee, completed markups of their legislation stemming from the budget reconciliation resolution that passed last month. In the meantime, the House Energy and Commerce Committee and the House Ways and Means Committee have postponed their markups—originally scheduled for the week of May 5—to the week of May 12. Republican leaders are still negotiating how to find $880 billion in Medicaid savings from the Energy and Commerce Committee, while the Ways and Means Committee must hold off on finalizing tax provisions until it’s clear whether those savings goals have been met.

Legislative Sessions

States currently in regular session

Alabama, Alaska, Arizona, California, Colorado, Connecticut, Delaware, Florida, Hawaii, Illinois, Iowa, Louisiana, Massachusetts, Michigan, Minnesota, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, Texas, Vermont, Wisconsin

States currently in special session

Maine