Information about the Commission on Dental Accreditation's activities is available to everyone. The Commission meets twice a year, usually in the winter and the summer. Following each meeting the communities of interest are notified via email that the CODA Communicator, currently a web-based newsletter, is available on the Commission’s website; this newsletter is available to all of CODA’s communities of interest.
If you have not received an issue of the CODA Communicator, please contact Mr. Gregg Marquardt, email@example.com, and he will add your email address to the Commission’s distribution for the next issue.
Additionally, hearings on standards are held at various meetings during which comments may be submitted to CODA on proposed or revised Accreditation Standards. Please review the left navigation, where you can access the proposed accreditation standards out for comment. CODA's meeting materials may also be of interest.
News and Highlights:
CODA Directs Elimination of “Specialty” Terminology
At its February 2, 2018 meeting, the Commission on Dental Accreditation (CODA) took action to remove the word specialty from all CODA documentation, as well as its website, and instead refer to all advanced dental education disciplines as advanced education programs. The Commission concluded that a revision to CODA’s terminology was necessary based upon the following reasons:
The terminology CODA uses is a carryover of the vocabulary used since 1975, when CODA assumed the policies of the Council on Dental Education and designated postdoctoral dental education programs as specialty programs, or general dentistry programs, based solely on the American Dental Association (ADA) Specialty Recognition Process. This does not reflect the changing environment of dental specialty recognition. In particular, over the past fifteen years, numerous state courts have determined that restricting specialty advertising to the “ADA Recognized Specialties” is restriction of free speech and restriction of trade. The Commission believes that the change in terminology decreases its legal risk in this area.
The terminology change comports with the scope of the Commission, as recognized by the United States Department of Education (USDE), which does not include specific language to distinguish between “advanced” and “advanced specialty” disciplines within dentistry. The Commission’s scope of recognition with the USDE is: The accreditation of predoctoral dental education programs (leading to the D.D.S. or D.M.D. degree), advanced dental education programs, and allied dental education programs that are fully operational or have attained “Initial Accreditation” status, including programs offered via distance education.
The Commission is aware that there are misconceptions among many in the communities of interest of the role, if any, that the Commission plays in regards to specialty recognition. The change in terminology clarifies that the Commission accredits education programs, but does not designate which disciplines in dentistry are “specialties.” The Commission’s sole mission is to serve the public and profession by developing and implementing accreditation standards that promote and monitor the continuous quality and improvement of dental education programs.
At its Winter 2018 meeting, the Commission directed CODA staff to identify all necessary CODA materials to be revised, including CODA’s Rules, policies and procedures, Accreditation Standards and supporting documents, and CODA’s website. The Commission also directed staff to submit an Action Plan, to include a high-level schedule of all revisions and a strategy for communicating the implementation of these revisions to CODA’s Communities of Interest. The Commission will consider this Action Plan at its Summer 2018 meeting, to be held August 2-3, 2018. The Commission will continue to keep its communities of interest informed of progress made related to these revisions.
For questions about this Plan, please contact Dr. Sherin Tooks, director, Commission on Dental Accreditation, at firstname.lastname@example.org.
Commission Increases Penalty for Violations of Privacy and Data Security Policy
At its Winter 2018 Meeting, the Commission on Dental Accreditation (CODA) took action to increase the Privacy and Data Security Policy violation fee from $1,000 to $4,000, effective in 2018 upon communication to the educational programs under CODA’s purview, and carried forward in 2019.
This fee change goes into effect on documents submitted to CODA postmarked or emailed on or after
February 19, 2018.
As stated in the Privacy and Data Security Summary for Institutions/Programs document (found at http://www.ada.org/en/coda/policies-and-guidelines/hipaa): to protect the privacy of individuals and to comply with applicable law, the Commission on Dental Accreditation prohibits all programs/institutions from disclosing in electronic or hard copy documents provided to CODA or CODA volunteers, other than on-site during a site visit, certain personally identifiable information; generally, this includes Protected Health Information [PHI] that would be protected under the Health Information Portability and Accountability Act (HIPAA), and Sensitive Personally Identifiable Information [PII] that would be protected under state data breach laws.
Since August 2013, the Commission has assessed a penalty fee to programs or institutions that violate CODA’s privacy and data security policy. However, even with the application of this penalty, many programs and institutions continue to include prohibited data in their submissions. These violations put the program / institution and the Commission at risk.
Some of the institutions that CODA accredits are HIPAA-covered entities, and CODA may be deemed to be their business associate. The government can impose substantial penalties on covered entities and business associates that violate HIPAA. Depending on the violation, the penalties can amount to thousands, or even millions of dollars. The government can also impose burdensome resolution agreements on covered entities and business associates that violate HIPAA. Additionally, many states require breach notification for unauthorized access to PII. A HIPAA or state law data breach or violation can potentially harm individuals and could have reputational as well as financial consequences for CODA.
Therefore, in an effort to further reduce the occurrence of PII and PHI in materials submitted to CODA, plus reduce the severe risk into which such submissions place institutions, programs, and CODA itself, the Commission is taking this action to increase the violation fee to $4,000 per program / per occurrence.
For complete information on the Commission’s Privacy and Data Security Policy, visit http://www.ada.org/en/coda/policies-and-guidelines/hipaa
Adoption of CODA White Paper: Transition to an Operational Structure for Independent Authority
The Commission on Dental Accreditation, during its August 1, 2014 meeting, adopted the Commission on Dental Accreditation White Paper: Transition to an Operational Structure for Independent Authority. The White Paper provides background on the role and responsibilities of the Commission, as well as the history of the Commission and its relationship to the American Dental Association (ADA). The White Paper concludes with information related to a re-examination of the Commission’s relationship with the ADA. Read the Commission’s White Paper: