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Advocacy and Government Relations — June 2014

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The U.S. Department of Education has proposed measures for determining whether certain postsecondary educational programs prepare students for gainful employment in a recognized occupation, as well as the conditions under which these programs remain eligible to receive funds under federal student aid programs. 

The opportunity to comment on these proposed gainful employment regulations has closed. ADEA has responded. With comments developed by the Advocacy and Government Relations Portfolio (ADEA AGR), ADEA points out that these regulations would cause our member institutions considerable time and cost burden to comply with the provisions.

In a May 27 letter to U.S. Secretary of Education Arne Duncan, ADEA respectfully reiterated the proposal’s inapplicability to dental schools awarding advanced professional certificates, which are subject to the proposed regulations. Such programs include allied and advanced specialty certificate programs. ADEA wrote: “the gainful employment requirements were [never] intended to apply to advanced specialty programs that terminate with the awarding of a certificate.”

In the letter, ADEA also noted that students seeking admission to advanced dental education programs are the most competitive students, and advanced dentistry certificate programs are made up of equally high-caliber applicants, many of whom are already “gainfully employed.” ADEA member institutions administering these certificate programs already require high standards for academic and professional performance, while the standard practice of dentistry mandates state licensure and high performance of those applicants who are practicing dentists. 

ADEA also points out that the Commission on Dental Accreditation (CODA) works to maintain the highest professional and ethical standards in the nation’s dental schools and programs, and so the proposed gainful employment provisions are duplicative at best. Through a peer-reviewed process, CODA evaluates the quality of more than 1,300 dental education programs nationwide.

The letter closed by requesting that the Department “reconsider the expense, time burden, and unsuitability of applying the proposed gainful employment regulation to dental schools awarding certificates for specialized oral care."

For a summary of recent federal legislative and regulatory news about oral health, dental education and dental research, read the ADEA Washington Update.

Keep up with recent state legislative and regulatory news about oral health, dental education and dental research in your state with the ADEA State Update.

Duggan Dental