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Bracken Killpack: It's Time for CODA to Change

"WSDA has strongly advocated for CODA to eliminate, or less preferably, level its faculty-to-student ratios for dental hygiene and dental assisting education."
Bracken KillpackBracken Killpack
Executive Director, WSDA

This installment of “The Last Word” focuses on what has become my least favorite four-letter word: CODA. Alas, we are not talking about an Academy Award-winning film or a literary epilogue, but instead about the Commission on Dental Accreditation.

WSDA has strongly advocated for CODA to eliminate or, less preferably, level its faculty-to-student ratios for dental hygiene and dental assisting education. We question the inconsistency across CODA standards. While dental hygiene programs must have one instructor for every five students for clinical education, dental therapy and dental assisting programs can operate with one instructor per six students. Furthermore, there is NO required ratio for predoctoral dental education.

There are two big problems with this inconsistency. First, CODA is promulgating accreditation standards where student training in the least invasive procedures has the most restrictive faculty-to-student ratio. Second, the overly restrictive standards effectively reduce the number of new hygienists during a time of serious workforce shortages.

Thankfully, WSDA has been joined by 18 other state dental associations, the ADA’s Council on Dental Education and Licensure, and the 2023 ADA House of Delegates in our effort to address the faculty-to-student ratio issue.

WSDA also has serious antitrust concerns about CODA’s inconsistent and seemingly arbitrary standards; these concerns have been clearly articulated to CODA by WSDA legal counsel on two separate occasions. To be clear, WSDA raised these anti-trust concerns on its own; we have not asked others to join us in doing so.

What has been CODA’s response to this persistent advocacy? To date, the commission has made three attempts to respond. First, CODA simply tried to shut down the request, effectively saying “we don’t agree with you; go away.” For its second attempt, CODA tried to overwhelm states advocating for change by demanding extensive and irrelevant data and then using survey data from educators in an attempt to end discussion of the issue.

CODA is currently in the process of developing its third response. This time, CODA is doubling down on “researching” its way out of addressing its arbitrary standards. Here’s how I summarized CODA’s current progress to my fellow state dental association executive directors:

“If you would enjoy reading a document where CODA twists itself into pretzels about first acknowledging the dental hygiene shortage and then attempting (unsuccessfully) to explain it away, then argues that there’s no need to change faculty-to-student ratios, only to recommend that further study and a literature review is needed, than I would HIGHLY encourage you to read their report. As a public service announcement against self-asphyxiation, I would recommend against holding one’s breath in anticipation of the Review Committee on Dental Hygiene Education coming out with any recommendation other than maintaining their extraordinary 1 to 5 faculty-to-student ratio. I remain amazed with how much rope ADA legal counsel is letting CODA use to tie itself into an antitrust mess.”

CODA is expected to share its latest report and any recommendations for changing standards at its next meeting in August 2024.

After spending two years on the Sisyphean task of trying to change a standard set by a commission that strives to be the antithesis of change, I have come to the conclusion that CODA must be fundamentally disrupted. My conversations with MANY individuals across the country on the topic of CODA indicate that a lot of folks agree with that conclusion – and for a wide range of reasons. CODA is overly bureaucratic, incredibly slow, and prioritizes stability at the expense of innovation. Meeting current accreditation and re-accreditation standards is also extremely expensive. These sentiments have been shared with me on many occasions, often confidentially out of fear of CODA’s wrath.

So, what would disruption look like? Fortunately, CODA is not an independent entity. While its decision-making process is independent of the ADA, the commission is an entity of the American Dental Association. It receives financial, staffing, and other support from the ADA. I implore the ADA to take decisive action to disrupt and revamp the current operations of CODA. I hope to write a future column about CODA’s transition into an accreditor that meets the needs of 21st Century education, instead of fighting to maintain its status as a relic of the 20th Century.

WSDA will determine next steps on its own faculty-to-student ratio advocacy after the commission’s next meeting in August. Stay tuned.

This article originally appeared in Issue 2, 2024 of the WSDA News. The views expressed in all WSDA publications are those of the individual authors and do not necessarily reflect the official positions or policies of the WSDA.