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How CODA works

Federal recognition requires independent decision-making

Taking notice of the Commission on Dental Accreditation’s recent decision to establish accreditation standards for dental therapy programs, some members have voiced their concerns to the ADA.

Image: Dr. Kiesling
Dr. Kiesling
The ADA is one of CODA’s communities of interest, said Dr. Roger Kiesling, 11th District trustee and the ADA Board of Trustees’ liaison to the commission. But recognition of CODA by the U.S. Department of Education requires the commission to have strict conflict of interest policies that provide for protection from undue influence from any one group, including the ADA.

“CODA is an agency of the ADA, but cannot be controlled by the ADA,” said Dr. Kiesling.

The commission’s role is to serve the public by establishing, maintaining and applying standards that ensure the quality and continuous improvement of dental, advanced dental and allied dental education programs. CODA develops standards for educational programs and makes accreditation decisions about individual education programs. There are more than 1,400 CODA-accredited programs in discipline-specific areas.

CODA has 30 members who represent a broad community of interest, including the ADA, American Dental Education Association, American Association of Dental Boards, each specialty organization, American Association of Hospital Dentists, American Dental Assistants Association, American Dental Hygienists’ Association, National Association of Dental Laboratories, American Student Dental Association and four members who represent the public.

Since 1952, the USDE has granted CODA accreditation authority for dental education programs. This recognition “affirms for the public and government funding and licensure agencies that the commission adheres to good accreditation practice,” said Dr. Kiesling. “The commission must have autonomy to make independent accreditation decisions to maintain this recognition.”

At the same time, accreditation is something the profession should value and protect, said Dr. Kiesling. Accreditation is the ultimate source of consumer protection for students; it’s a prerequisite for many sources of government funding; a prerequisite for many certification examinations; graduation from an accredited program is almost always stipulated by state law as an eligibility requirement for licensure; and it’s vital to dentistry being a self-regulating profession.

Image: Dr. Tonelli
Dr. Tonelli
“ADA input on policy decisions is considered by CODA due to the ADA’s prominence in representing a significant number of the profession and employers of graduates of education programs,” said Dr. Steven Tonelli, chair-elect of CODA.

“The accreditation process is beneficial to the profession of dentistry because one of the factors that makes dentistry a self-regulating profession is the peer-review process for evaluating the quality of dental education, which the commission oversees with credibility and integrity,” said Dr. Tonelli.

“A strong program of accreditation ensures that long-term viability of the profession through support of quality dental education,” Dr. Tonelli added. “It is only through quality education that graduates of dental programs are able to practice successfully and practitioners are able to hire qualified staff.”

Unlike ADA councils and committees, CODA is required under federal law to have representatives of the public that serve as members of the commission to help ensure independence. And CODA must listen to all of its communities of interest and consider all perspectives on an issue before making policy decisions.
Karen Kershenstein, Ph.D., is completing her term as a member of CODA representing the public. She also had a 10-year career directing the accrediting agency recognition process for the USDE.

The USDE conducts reviews for continued recognition at five-year intervals. In 2006 the Secretary of Education found CODA in full compliance with all requirements, and the next scheduled re-recognition is in June 2012. CODA’s independence as an agency is taken into consideration during this process, she said.

“This is one reason why members of the public are brought into the process—so that decisions are not narrowly made by dental educators and practicing dentists,” said Dr. Kershenstein.

“CODA does something else that not all other accreditors do, which I think is strong,” said Dr. Kershenstein. “There are public members on all the review committees to ensure that decisions are appropriate and follow CODA policies and procedures and standards. That is a real strength of CODA in my opinion.”
Having varied stakeholders involved in the decision-making process can lead to political skirmishes at times but CODA’s processes work, said Dr. Larry Nissen, a past commissioner and an oral and maxillofacial surgeon. Along with Dr. Kiesling and Dr. Kershenstein, Dr. Nissen was a member of the Task Force on the Commission on Dental Accreditation, appointed by the ADA in 2007 in response to concerns from several communities of interest. In 2008, the task force issued a report with 34 recommendations addressing CODA’s existing structure, governance, policy, operating procedures and functionality. Among them were calls for enhanced communications between CODA and its communities of interest and an extended meeting format. To date, 31 of the recommendations have been or are in the process of being implemented.

Image: Dr. Nissen
Dr. Nissen
“That study gave CODA an opportunity to look at itself to ensure a process whereby people came from outside organizations but looked at themselves as part of commission and not as a representatives of one interest group,” said Dr. Nissen. “When you’re dealing with policy and accreditation issues, even though your education is such that it comes from a specialty perspective, you have to make decisions based on what is best for the educational process rather than one particular interest group."

“CODA embraced the task force recommendations,” said Dr. Kiesling, who also served on a monitoring committee appointed to watch over implementation of the task force recommendations. “They didn’t see it as ADA controlling CODA but as recognition they could do a better job communicating and developing some operational changes.”

He believes that the changes made in communications and transparency served CODA well when it voted in August to establish accreditation standards for dental therapy programs.

“While there will always be controversial things CODA has to deal with, they have a much better ability now, I believe, to deal with some of the changes that are taking place in dentistry in many different areas, including dental therapy programs,” he said.

CODA Chair Donald Joondeph is appointing a task force to develop new standards for dental therapy education programs, which will report its progress at the August 2012 CODA meeting. As the process unfolds, ADA members will have an opportunity to provide comment.

“ADA member input is solicited on a regular basis along with input from all communities of interest,” said Dr. Tonelli. While the standards on dental therapy programs will not be drafted in time for this year’s Annual Session, the commission routinely holds open hearings during ADA Annual Sessions.

As for the dental therapy program standards, Dr. Tonelli said “it is still very early in the process and the task force has yet to be appointed. We anticipate that a member of the private practice community will be appointed to the task force that will draft the standards.”

Dr. Tonelli believes that CODA is the best agency to develop standards for dental therapy programs.

“The commission has always been looked upon by the federal government and the public as the expert in dental and allied dental education,” said Dr. Tonelli. “However, there are other agencies, especially those agencies that accredit allied medical programs that have aggressively looked to widen their scope.”

Had CODA decided not to establish standards for dental therapy programs, the University of Minnesota—which offers degrees in dental therapy and advanced dental therapy—could have gone to another accrediting agency, he said. If an accrediting agency other than CODA accredits dental therapy education programs, it could embolden those other agencies to look to accredit educational programs in other areas of dentistry, especially in the allied area.

“The dental board in Minnesota is currently ‘accrediting’ the dental therapy programs in that state,” said Dr. Tonelli. “If more states adopt this allied model and the commission does not have standards for the quality evaluation of these other programs, then each dental board will be forced to develop its own ‘standards.’ Dental boards have neither the expertise nor the resources to carry out the accreditation process or develop quality standards. Without commission-directed standards, there is the potential to have a wide range in the scope of practice and a virtually no evaluation of the quality of the programs. This could become an issue affecting patient safety and welfare.”