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."