Question: Am I able to hire a certified registered nurse anesthetist to administer anesthesia in my practice? Am I able to supervise these services myself? Are there requirements I must meet to be able to do this?
Answer: You are generally able to hire a CRNA to work in your practice if the requirements of both MCL 333.17210 and applicable provisions of Part 6A of the Michigan Administrative Code of Dentistry Rules are met.
Please note: The Michigan Administrative Code rules discussed below became effective in 2023. The new rules allow greater flexibility when engaging a CRNA on a collaborative basis than did the former rules governing engagement of a CRNA in your practice.
MCL 333.17210 (which became effective Oct. 11, 2021) generally allows a CRNA to provide anesthesia and analgesia services to patients without supervision if he or she:
- (1) Has been practicing as a CRNA for at least three years and has practiced in a health care facility (which is defined to include a dental office) for a minimum of 4,000 hours, or (2) has a Doctor of Nurse Anesthesia Practice degree or Doctor of Nursing Practice Degree; and
- Is collaboratively practicing in a patient-centered care team, which includes practicing and communicating with health care professionals involved in the patient-centered care team to optimize the overall care delivered to the patient. The patient-centered care team must include a qualified health care professional (which is defined to include a dentist who has completed the necessary education, training, and experience in anesthesia care or pharmacology, or has experience with procedures requiring anesthesia).
In addition, the dental office where a CRNA provides these services must have policies in place relating to the provision of these services and ensuring that a dentist or other qualified health care professional is immediately available in-person or through telemedicine to address any urgent or emergent clinical concerns. You may hire a CRNA on an employment or on an independent contractor basis. However, if you choose to engage a CRNA on an independent contractor basis, MCL 333.17210(4) requires that you ensure that the CRNA or the CRNA’s employer maintains malpractice insurance coverage.
Both Michigan Administrative Code Rule 338.11601(2) (applicable to providing deep sedation) and Rule 338.11602(2) (applicable to moderate or minimal sedation) became effective Oct. 2, 2023. These rules apply when a general dentist not holding a specialty license in dental anesthesia or oral and maxillofacial surgery hires and is working collaboratively with a CRNA. In this case, both the dentist and all allied dental personnel and dental therapists who are directly involved in procedures where the CRNA is providing anesthesia must be certified in basic cardiac life support for health care providers with a hands-on component. The certification must be from an agency or organization that grants certification pursuant to standards substantially equivalent to the standards adopted in Rule 338.11603(2). That Rule refers to the standards for credentialing in basic cardiac life support for health care providers with a hands-on component set forth by the American Hearth Association in the standards and guidelines published in 2020 American Heart Association Guidelines for Cardiopulmonary Resuscitation and Emergency Cardiovascular Care(goes to new website). A certification in basic cardiac life support (with or without pediatric advanced life support) for health care providers from the American Heart Association with a hands-on component from the American Heart Association will meet the requirements of these rules.
This article originally appeared in the September 2024 edition of the Journal of the Michigan Dental Association.
