Comments

CODA Comments

Oct 3, 2024
MDA encourages comments on accreditation standards.

The Commission on Dental Accreditation is hosting a hearing on October 10 to enable interested parties to comment on proposed revisions to dental accreditation standards online portal. The purpose of the hearing is to allow the public to comment on the proposed revisions and will not include a presentation. However, to maximize participation, CODA encourages only one representative per organization or institution to register.

This means most members who wish to comment may do so by submitting written comments through an online portal, which the MDA is recommending. Those interested in commenting have until December 1 to submit their remarks for most of the standards; for the standards related to orofacial pain education programs, parties comments are open until June 1, 2025.

CODA will not accept comments via mail or email. All comments must be submitted through the online portal. To learn more, register for the hearing or submit comments online, visit CODA.ADA.org.

What Revisions Are Being Addressed

All accreditation standards currently proposed for revision will be covered in the hearing. These include standards for programs in predoctoral dental education, advanced education in general dentistry, general practice residency education, dental assistant and dental hygiene education and orofacial pain education.

Why This Matters in Missouri 

“The proposed CODA revisions to accreditation policies continue to be a focus for many state associations because they impact our ability to address the severity of workforce shortages,” said Vicki Wilbers, MDA Executive Director. 

In a January 2023 letter to CODA, two main requests were emphasized by 17 state dental associations (including Missouri) related to workforce shortages in dental hygiene and dental assisting:

  • Lowering the faculty-to-student ratio in dental hygiene programs, which currently is 1 dentist to 5 students; and,
  • Removing the requirement to have a baccalaureate degree to be faculty in a dental assisting program

In a September 2023 letter, CODA responded to the states of its actions, and noted it would not develop a policy or process for revising accreditation standards related to dental hygiene program faculty-to-student ratios but did direct adoption of a proposed revision to allow a three-year grace period for the dental assisting faculty baccalaureate degree to be met.

States responded in a follow-up letter to CODA, of which the following is an excerpt in a letter:

“Across the country, we are taking a multifaceted approach to increase the dental hygiene workforce and believe removing the clinical hygiene faculty-to-student ratio and baccalaureate requirement for clinical faculty are important complements to our approach. Not only will the removal of this ratio bring the program requirements into alignment with that of dental education programs, but it will also give dental hygiene programs and their sponsoring institutions the flexibility to increase capacity while providing a possibility for decreasing a program’s per capita operational expenses. While faculty-to-student ratio may be correlated with some measures of quality to the educational experience, there is not a cause and effect between class size and quality education. However, a higher faculty-to-student ratio is a high driver of cost in educational programs.

Additionally, removing the baccalaureate requirement will bring the program requirements into alignment with that of dental therapy and dental education. The baccalaureate requirement serves as a barrier to entry for many qualified individuals whose lived experiences may not have allowed them to complete a baccalaureate degree. Removing the requirement will open clinical instruction opportunities to a broader, more diverse group of instructors.” 

This October 10 virtual hearing will further address these and other revisions. Of note, the 16th District of the ADA has submitted a resolution to this year’s ADA House of Delegates to take a position on the dental hygiene faculty-to-student ratio.

“This review of policies is important to the profession because it makes it harder to find faculty in dental assistant and hygiene education programs when now, more than ever, we need to remove barriers to help ensure a strong dental workforce,” said Wilbers. “I encourage any MDA member who has advocated for workforce changes and improvement in dental hygiene program capacity to submit comments through the online portal.”