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American Dental Education Association


Volume 3, No. 92, July 29, 2025

ED Releases “Dear Colleague” Letter Regarding Certain Provisions of the One Big Beautiful Bill
 
The Department of Education (ED) issued a Dear Colleague Letter [ [link removed] ] (DCL), providing guidance on the newly enacted One Big Beautiful Bill Act, signed by President Donald Trump in early July.
While much of the Act’s significant impact on higher education is scheduled to take effect on or after July 1, 2026, the DCL outlines several key provisions that became effective immediately upon the bill’s signing.
 
Among the changes of interest to the oral health community that are now in effect are revisions to the income-based repayment (IBR) plan, changes to eligibility under the Public Service Loan Forgiveness (PSLF) program and loan limits for part-time students.
 
The One Big Beautiful Bill Act eliminates the requirement for borrowers to show partial financial hardship to qualify for the IBR plan, making more borrowers eligible immediately. Those with loans from July 1, 2014, to July 1, 2026, who were previously ineligible can now access IBR’s more favorable terms, such as payments at 10% of discretionary income with loan forgiveness after 20 years, instead of the less generous Income Contingent Repayment plan.
 
The bill also amends the PSLF program to allow for payments made under the newly created Repayment Assistance Plan (RAP) to count toward loan forgiveness, if all other eligibility criteria are met. The RAP was created by the Act and will take effect July 1, 2026. This PSLF provision is effective upon enactment, meaning that whenever ED launches the RAP program, borrowers will be able to immediately get credit for PSLF under RAP.
 
Finally, the Act mandates a proportional reduction in annual student loan limits for students enrolled less than full time, based on the extent of their part-time enrollment. ED is developing a reduction schedule that will be released for public comment and finalized later this year. Starting in the 2026–27 academic year, institutions will be required to use this schedule to adjust loan limits for all students not enrolled full time.
 
Despite the immediate enactment of some provisions, many questions remain about how these changes will be implemented. The Department acknowledged this uncertainty and stated in the DCL that it will release additional regulations and guidance for these provisions and other aspects of the law later this year.

Reagan-Udall Foundation and FDA Hold Public Meeting on Ingestible Fluoride for Kids
 
On July 23, the Food and Drug Administration (FDA), in collaboration with the Reagan-Udall Foundation, held a public meeting to gather input on the use of orally ingestible fluoride supplements.
The meeting followed the FDA’s May announcement [ [link removed] ] that it is considering removing these unapproved products from the market.
Please find the master slide deck from the meeting here.
[ [link removed] ]
 
Dr. George Tidmarsh, the newly announced FDA Director of the Center for Drug Evaluation and Research, expressed the need for balancing risk and benefit. He criticized the initial presentations in the meeting that were favorable towards fluoride supplements.
 
Dr. James Bekker, of the University of Utah School of Dentistry emphasized that fluoride is a naturally occurring nutrient essential for oral health, noting that both deficiency and excess can pose risks.
He underscored the importance of shared decision-making between health care providers and patients to determine appropriate fluoride use based on individual needs and local water fluoridation levels.
Citing Utah as an example, where some communities have recently discontinued water fluoridation, Dr.
Bekker highlighted the growing reliance on ingestible fluoride supplements as a necessary alternative for pediatric oral health.

 
Presenters raised concerns about potential neurocognitive effects of fluoride exposure.
Dr. Griffin Cole, who represented the International Academy of Oral Medicine and Toxicology, argued that fluoride is only effective topically and called for the FDA to remove ingestible supplements, citing a meta-analysis linking fluoride to lower IQ.
In contrast, Dr. Susan Fisher-Owens, of University of California, San Francisco, School of Medicine, stressed the need to weigh risks and benefits in pediatric care, noting that many pediatric drugs, including fluoride, lack FDA approval.
She questioned the reliability of fluoride-IQ studies and noted that mild fluorosis is not harmful and may reflect appropriate exposure.
 
The meeting concluded with members of the public offering comment. Many of the commentors were supportive of fluoride supplements for the pediatric population.
 
ADEA strongly supports continued access to ingestible fluoride supplements and filed written comments [ [link removed] ] ahead of this meeting.
 
The FDA will take both oral and written comments from this public meeting into consideration and is aiming to conclude its review of ingestible fluoride supplements by the end of October.

21 Democratic Governors Sue HHS Over New ACA Eligibility and Enrollment Rule
 
A coalition of 21 Democratic-led states has filed a lawsuit [ [link removed] ] against the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS), challenging a new final rule [ [link removed] ] they argue would significantly limit access to health coverage under the Affordable Care Act (ACA). Filed July 17 in the U.S. District Court for the District of Massachusetts, the suit targets a final rule set to take effect Aug.
25. The states are seeking preliminary relief to halt the rule before it is implemented.
They argue the rule’s changes would result in up to 1.8 million people losing coverage, increased out-of-pocket expenses and would impose administrative burdens that deter enrollment.
Furthermore, plaintiffs believe that the regulation undermines years of progress in ACA enrollment, which reached over 24 million this year.
 
The rule introduces stricter eligibility verification, shortens enrollment periods and removes gender-affirming care as an essential health benefit.
Among the key issues raised in the complaint is the rule’s elimination of coverage for gender-affirming care, which the states argue directly conflicts with their own laws mandating such coverage.
The rule also modifies exchange eligibility rules, reducing the open enrollment window by one month and eliminating a special enrollment period for low-income individuals. It further restricts leniency for applicants who struggle to verify their income or reconcile tax data, potentially stripping away subsidies and making coverage unaffordable for many.
 
The states claim the rule is “arbitrary and capricious” and would impose substantial costs on states by increasing the number of uninsured individuals who would then rely on state-funded health care programs, such as Medicaid and emergency services. They also warn that the rule will create unrecoverable costs related to technology upgrades, staff training and public outreach, and reduce tax revenue from insurance premiums.
 
The lawsuit also accuses HHS of violating the Administrative Procedure Act by rushing the rule through passage with only 23 days for public comment, despite public requests for more time.
 
HHS defends the rule as a measure to reduce fraud and prevent unauthorized enrollments.

ED Announces Investigation of Universities for Offering Scholarships Exclusive to DACA Students
 
On July 23, the Department of Education (ED) announced [ [link removed] ] that its Office for Civil Rights (OCR) has launched investigations into five universities—University of Louisville, University of Nebraska, University of Miami, University of Michigan and Western Michigan University—for allegedly offering scholarships exclusively to Deferred Action for Childhood Arrivals (DACA) or undocumented students.
ED argues that such programs violate Title VI of the Civil Rights Act, which prohibits discrimination based on national origin.
The investigations were initiated in response to complaints filed by the Equal Protection Project of the Legal Insurrection Foundation.
ED also indicated it will review other scholarships designated for LGBTQ+ students, as well as those intended for African American, Hispanic and Native American students.

ED Announces Negotiated Rulemaking for Implementation of the Trump Administration’s Student Loan Reforms
 
The Department of Education (ED) announced [ [link removed] ] , on July 25, that it will convene two advisory committees as part of a new round of negotiated rulemaking.
This rulemaking is necessary to implement recent statutory changes to the Title IV, Higher Education Act programs included in Pub.
L. 119-21 [ [link removed] ] , known as the One Big Beautiful Bill (OBBB) Act, that President Trump signed into law on July 4.
 
As part of this process, the Department will hold a virtual public hearing Thursday, Aug. 7, to gather public input on implementing the OBBB Act before drafting new proposed regulations. To view the virtual public hearing livestream on Aug. 7, register here. [ [link removed] ] The hearing runs from 9:00 a.m. – 4:00 p.m. ET.
 
Additionally, written comments will be accepted through Monday, Aug. 25. Information regarding submitting comments can be found here [ [link removed] ] under the Addresses section.
 
This notice also provided information on the nominating processes for the negotiated rulemaking advisory committees. ED is creating two advisory committees: the Reimagining and Improving Student Education (RISE) committee, which will focus on federal student loan reforms, and the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) committee, which will address issues related to institutional and program accountability and the Pell Grant program.
 
Nominations for committee members serving on the RISE Committee may be sent via email to [email protected] [ mailto:[email protected] ] by Aug. 25.
 
Additional information about the nomination process, the constituency groups who can be nominated and the negotiation schedules can be found here [ [link removed] ] toward the bottom of the page.
 
Nominations for committee members serving on the AHEAD Committee may be submitted to the via email to [email protected] [ mailto:[email protected] ] by Aug. 25. Additional information about the nomination process, the constituency groups who can be nominated and the negotiation schedules can be found here [ [link removed] ] toward the bottom of the page.

Some Bills Moving Through the California Legislature May Impact Oral Health Providers and Dental and Allied Dental Education
 
Several bills that may be of interest to ADEA members are currently moving through the California Legislature. Summaries of bills that have passed at least one chamber of the legislature and appear to be headed for the floor of the second chamber can be found below:
 • SB 351 [ [link removed] ] prohibits a private equity group or hedge fund involved in any manner with a physician or dental practice from interfering with the professional judgment of physicians or dentists in making health care decisions.
The bill also prohibits these groups from exercising power over specified actions, including decisions regarding employment of health care providers, contractual relationships with third-party payers, clinical competency parameters under which a provider enters into contractual relationships with other providers, coding and billing procedures for patient care services and approving the selection of medical equipment.

 • SB 503 [ [link removed] ] requires developers and deployers of artificial intelligence (AI) systems to identify AI systems used to support clinical decision-making or health care resource allocation that are known or have a reasonably foreseeable risk of biased impacts in the system’s outputs, resulting from use of the system in health programs or activities, and to make a reasonable effort to mitigate biased impacts.
 • SB 307 [ [link removed] ] requires the Trustees of the California State University (CSU) and requests the Regents of the University of California (UC) to ensure that an undocumented student’s inability to satisfy their academic requirements due to an immigration enforcement activity at their institution does not affect the student’s nonresident tuition exemption.
The bill also requires the CSU and requests the UC ensure that staff and the designated Dreamer Resource Liaisons at each campus assist undocumented students in accessing all financial aid and academic resources available and adopt a systemwide policy to address course grades, administrative withdrawal and reenrollment for undocumented students.
 • AB 695 [ [link removed] ] provides an exemption from nonresident tuition for community college students who were deported on or after Jan. 1, 2025, and later reenroll in either an online or in-person community college program, if the student was previously enrolled and was not paying nonresident tuition at the time of their departure.

Universal Licensure Law Takes Effect in West Virginia
 
A new law [ [link removed] ] in West Virginia took effect earlier this month that creates universal licensure in the state.
Under the law, the state’s licensing boards are required to issue an occupational or professional license without examination to a resident of the state or a military spouse who holds a license that is in good standing in another U.S. jurisdiction. All licenses issued under the law must be in the discipline applied for and at the same practice level as the license held in the other state, as determined by the board of examination or registration.
Additionally, all dentists and dental hygienists who seek a license under the law must have passed a clinical hand skills examination.

 
At least 18 other states [ [link removed] ] have passed some type of universal licensure law. Requirements for oral health professionals vary among states. Please reach out to [email protected] [ mailto:[email protected] ] if you have questions about a specific state.

ADEA Advocacy in Action
This appears weekly in the ADEA Advocate to summarize and provide direct links to recent advocacy actions taken by ADEA. Please let us know what you think and how we might improve its usefulness.
 
Issues and Resources
 • ADEA report [ [link removed] ] on teledentistry
 • ADEA report [ [link removed] ] on the Impact of the COVID-19 Pandemic on U.S. Dental Schools
 • ADEA policy brief [ [link removed] ] regarding overprescription of antibiotics
 • For a full list of ADEA memos, briefs and letters click here [ [link removed] ] .

Key Federal Issues [ [link removed] ]

ADEA U.S. Interactive Legislative and Regulatory Tracking Map [ [link removed] ]

Key State Issues [ [link removed] ]

The ADEA Advocate [ [link removed] ] is published weekly. Its purpose is to keep ADEA members abreast of federal and state issues and events of interest to the academic dentistry and the dental and research communities.
 
©2025
American Dental Education Association
655 K Street, NW, Suite 800
Washington, DC 20001
Tel: 202-289-7201
Website: www.adea.org [ [link removed] ]

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B. Timothy Leeth, CPA
ADEA Chief Advocacy Officer
 
Bridgette DeHart, J.D.
ADEA Director of Federal Relations and Advocacy
 
Phillip Mauller, M.P.S.
ADEA Senior Director of State Relations and Advocacy
 
Jema Stubblefield
ADEA Senior Manager of State Relations and Advocacy
 
Colin Donnelly, M.P.S
ADEA Legislative Analyst
 
Contact Us:
[email protected] [ mailto:[email protected] ]

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