ADEA Washington Update

ADEA Submits Comments to Proposed Gainful Employment Final Rule

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

ADEA also noted that students seeking admission to postdoctoral 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."

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