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Educational Standards For New Providers

The Federal Trade Commission ensures the educational standards for dental therapy do not hamper the ability of these clinicians to best serve the public.

As the voice for the dental hygiene profession, the American Dental Hygienists’ Association’s (ADHA) advocacy work has been sharply focused on moving the dental hygiene profession forward. The ADHA, with support from the United States Federal Trade Commission (FTC), was pleased to lead the effort to develop dental therapy education standards for new mid-level oral health practitioners in the US. The ADHA worked with the dental hygiene community nationwide to strengthen the proposed standards and ensure they reflect the evolution of the profession.

2013-2014 American Dental Hygienists’ Association (ADHA) President Denise Bowers, RDH, PhD, (left) speaks with Federal Trade Commission Deputy Director of Policy Planning Tara Isa Koslov (right), while ADHA Executive Director Ann Battrell, MSDH, looks on.
Courtesy of the American Dental Hygienists’ Association

The Commission on Dental Accreditation (CODA) is the sole agency responsible for the accreditation of dental and dental-related education programs conducted at the post-secondary level. In 2009, with the creation of the dental therapist and the advanced dental therapist in Minnesota, CODA was pressed to develop accreditation standards for these new educational programs. Initially, the draft on accreditation standards only presented a nondental hygiene track.

In 2013, during an initial public comment period, CODA sought input from its communities of interest related to the program track for dental therapy. CODA noted that the proposed standards were a nondental hygiene track but could be modified to support a dental hygiene program track.

More than 200 written comments from various stakeholders were submitted during the initial comment period. Several improvements emerged from the written and oral testimony provided by the dental hygiene community and others, including changes in the degree track and length of the program; scope of training; level of supervision; program director requirements; and advanced standing opportunities for dental hygienists.


Competition in health care markets has long been an area of focus for the FTC. I alongside American Dental Hygienists’ Association (ADHA) Executive Director Ann Battrell, MSDH; Director of Education Pam Steinbach, RN, MS; and ADHA’s Washington, DC-based Counsel Karen Sealander were provided the opportunity to brief FTC Chairwoman Edith Ramirez and other FTC officials on the pending dental therapy education accreditation standards. The FTC’s goal to promote competition for the benefit of consumers underlies the commission’s interest in the development of new workforce models. ADHA’s advocacy efforts, coupled with the keen interest of the FTC, proved to be pivotal in the conversation about draft standards.

With recognition that Minnesota had created and developed mid-level oral health providers—noting that several state legislatures have bills pending or planned to create similar programs—the FTC provided 15 pages of written comments to CODA in December 2013.1 The FTC asserted that unnecessary statements on supervision, evaluation, and treatment planning by CODA may limit the effectiveness of the proposed dental therapy standards. The FTC further recommended that CODA develop standards that do not effectively and unnecessarily constrain the discretion of states to determine dental therapy scope of practice and authority. On January 30, 2014, CODA directed the modified proposed Accreditation Standards for Dental Therapy Education Programs be recirculated to communities of interest for review and comment through December 1, 2014.2

The ADHA applauds the FTC’s decision to provide written comments to CODA regarding the proposed standards for dental therapy education programs.2 The FTC works for consumers to prevent fraudulent, deceptive, and unfair business practices, and to provide information to help spot, stop, and avoid them. The commission has a long history of focusing on competition in health care markets. Over time, the FTC has examined dental services in the context of law enforcement actions and policy initiatives in South Carolina, Louisiana, Georgia, and Maine.


The accreditation of the dental hygiene-based model in Minnesota and the subsequent passage of similar legislation in other states are contingent on the dental hygiene community sharing its experience and expertise. New career opportunities are not the only factor at stake. The ability to expand oral health services to those who need it most also depends on these accreditation standards. Let’s ensure that these new standards reflect the best of what dental hygienists have to offer so their scope of practice is not unfairly limited.


  1. United States of America Federal Trade Commission. Correspondence with Commission on Dental Accreditation. Available at: Accessed September 24, 2014.
  2. Commission on Dental Accreditation. Proposed Accreditation Standards. Available at: Accessed September 24, 1014.

From Perspectives on Dental Hygiene, a supplement to Dimensions of Dental HygieneNovember 2014;12(11):18–19.

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