White v. Florida Hearing Transcript

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August 21, 1969

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  • Brief Collection, LDF Court Filings. Fisher v. University of Texas at Austin Brief for Amici Curiae, 2015. 764791cc-b19a-ee11-be36-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/56b4ce1b-1464-4b09-83ad-b82504c88a85/fisher-v-university-of-texas-at-austin-brief-for-amici-curiae. Accessed April 29, 2025.

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    No. 14-981

In The

S u p re m e  C o u r t  of tfjr ® ntteb States?

Abigail Noel Fisher,
Petitioner,

v.

University of Texas at Austin , et al.,
Respondents.

On Writ of Certiorari to the 
United States Court of Appeals 

for the Fifth Circuit

BRIEF FOR AMICI CURIAE 
ASSOCIATION OF AMERICAN 
MEDICAL COLLEGES ET AL. 

IN SUPPORT OF RESPONDENTS

Frank R. Trinity Jonathan S. Franklin*
Heather J. Alarcon Counsel o f Record
Association of American Robert Burgoyne 

Medical Colleges John W. Akin
655 K Street, N.W. NORTON Rose FULBRIGHT US LLP
Washington, D.C. 20001 799 9th Street, N.W., Suite 1000
(202) 828-0540 Washington, D.C. 20001

(202) 662-0466 
jonathan.franklin®

nortonrosefulbright.com

Counsel for Amici Curiae



TABLE OF CONTENTS
Page

TABLE OF AUTHORITIES..................   iii
INTEREST OF AMICI CURIAE.................................1
SUMMARY OF THE ARGUMENT......................... ...3
ARGUMENT..........................................................   7

I. DIVERSITY IS A VITAL
COMPONENT OF THE 
EDUCATIONAL MISSION OF THE 
NATION’S MEDICAL SCHOOLS ....................7
A. Physicians Must Understand How

To Serve Diverse Communities..................7
B. The Benefits Of Diversity Are

Indispensable To Achieving Core 
Educational Goals.......................................13

II. MEDICAL SCHOOLS HAVE LONG
RELIED ON HOLISTIC REVIEW FOR 
ADMISSIONS DECISIONS............................23
A. Medical Schools Have A History Of 

Highly-Individualized Admissions 
Practices.......................................................24

B. Although Other Initiatives Have 
Shown Some Success, It Remains 
Necessary For Medical Schools To 
Consider Applicants’ Full 
Backgrounds In Order To Achieve 
The Schools’ Educational Goals............... 29



TABLE OF CONTENTS— Continued
Page

III.PRECLUDING OR LIMITING 
HOLISTIC REVIEW WOULD 
DISRUPT ADMISSIONS PRACTICES 
CRAFTED IN RELIANCE UPON THE
COURT’S PRECEDENTS.............................. 34

CONCLUSION.............................................................38
ADDENDUM



I l l

CASES:
Fishery. Univ. o f Tex., 133 S. Ct. 2411 

(2013)...................................................................... 21
Grutter v. Bollinger, 539 U.S. 306 (2003) ....passim
Payne v. Tennessee, 501 U.S. 808 (1991)............34
Planned Parenthood of SE Pa. v. Casey,

505 U.S. 833 (1992)........................................ 34-35
Regents of the Univ. o f Cal. v. Bakke, 438 

U.S. 265 (1978).............................................passim

STATUTE:
Disadvantaged Minority Health 

Improvement Act of 1990, Pub L. No.
101-527, 104 Stat. 2311 (1990).......   20

LEGISLATIVE HISTORY.
S. Rep. No. 114-74 (2015)......................................... 9

OTHER AUTHORITIES:
Amy N. Addams et al., Roadmap to 

Diversity: Integrating Holistic Review 
Practices into Medical School 
Admission Processes (AAMC 2010)..........passim

Behnoosh Afghani et al., A Novel 
Enrichment Program Using Cascading 
Mentorship to Increase Diversity in the 
Health Care Professions, 88 Acad. Med.
1232 (2013).............................................................30

Akhil Reed Amar & Neal Kumar Katyal,
Bakke’s Fate, 43 UCLA L. Rev. 1745 
(1996)

TABLE OF AUTHORITIES
Page(s)

12



IV

TABLE OF AUTHORITIES— Continued
Page(s)

Am. Ass’n of Colls, of Nursing (“AACN”),
2014-2015 Enrollment and
Graduations in Baccalaureate and
Graduate Programs in Nursing (2015)............. 10

AACN, Cultural Competency in Bacca­
laureate Nursing Education (2008)............  11-12

AACN, Establishing a Culturally 
Competent Master’s and Doctorally 
Prepared Nursing Workforce (2009)...................12

Am. Med. Ass’n, AMA Code of Medical 
Ethics, Op. 9.121, Racial and Ethnic 
Health Care Disparities....................................... 11

Association of American Medical Colleges 
(“AAMC”), 2015 Data Book (2015).....................32

AAMC, Altering the Course: Black Males 
in Medicine (2015)...............  32

AAMC, Applicants, First-Time
Applicants, Acceptees, and Matriculants
to U.S. Medical Schools by
Race /Ethnicity, 2013-2014 and 2014-
2015 {2014)............................................................. 10

AAMC, MCAT and GPA Grid for 
Applicants and Acceptees to U.S.
Medical Schools, 2012-2014
(aggregated) (2014)...............................................25

AAMC, Race /Ethnicity of Applicants to 
U.S. Medical Schools, 2013-2014 and 
2014-2015 (2014).............................................   32

AAMC, The Complexities of Physician 
Supply and Demand: Projections from 
2013 to 2025 (2015).................................................9



V

TABLE OF AUTHORITIES— Continued
Page(s)

AAMC & Ass’n of Schools & Programs of 
Pub. Health, Cultural Competence 
Education for Students in Medicine 
and Public Health (July 2012)......................... 31

Anthony Lising Antonio et al., Effects of 
Racial Diversity on Complex Thinking 
in College Students, 15 Psychol. Sci.
507 (2004)............................................................. 17

William T. Basco Jr. et ah, Assessing 
Trends in Practice Demographics of 
Underrepresented Minority Pediatri­
cians, 1993-2007, 125 Pediatrics 460 
(2010)......................................... ................... ......... 9

Joseph R. Betancourt et al., Defining 
Cultural Competence: A Practical 
Framework for Addressing Racial/
Ethnic Disparities in Health and Health
Care, 118 Pub. Health Rep. 293 (2003)............ 11

Laura M. Bogart et al., Factors 
Influencing Physicians’ Judgments of 
Adherence and Treatment Decisions for 
Patients with HIV Disease, 21 Med.
Decision Making 28 (2001)................................ 16

William G. Bowen & Derek Bok, The 
Shape of the River (1998)....................................33

Kendall M. Campbell et al., USSTRIDE 
Program is Associated with 
Competitive Black and Latino Student 
Applicants to Medical School, Med. 
Educ. Online (May 2014).............. ........ 31



VI

Devon W. Carbado & Cheryl I. Harris,
The New Racial Preferences, 96 Cal. L.
Rev. 1139 (2008).............................................36-37

U.S. Census Bureau, American 
FactFinder.............................................................. 10

Ctrs. for Disease Control & Prevention,
CDC Health Disparities and 
Inequalities Report— United States,
2013, 62 MMWR (Supp.) No. 3 (Nov.
22, 2013)....................................................................7

Arthur L. Coleman et al., Roadmap to 
Diversity and Educational Excellence:
Key Legal and Educational Policy
Foundations for Medical Schools
(AAMC 2d ed. 2014)......................................14, 34

Comm’n on Dental Accreditation,
Accreditation Standards for Dental 
Education Programs (2015)................................22

Comm’n on Osteopathic Coll.
Accreditation, Accreditation of Colleges 
of Osteopathic Medicine: COM  
Accreditation Standards and 
Procedures (2015).......................................... 21—22

Lisa A. Cooper et ah, The Associations of 
Clinicians’ Implicit Attitudes about 
Race with Medical Visit Communication 
and Patient Ratings of Interpersonal 
Care, 102 Am. J. Pub. Health 979 (2012)........16

TABLE OF AUTHORITIES— Continued
Page(s)



V l l

Clemencia Cosentino et al., Impact 
Evaluation of the RWJF Summer 
Medical and Dental Education 
Program (SMDEP) (Mathematica Jan.

TABLE OF AUTHORITIES— Continued
Page(s)

28, 2015)......................   .....30
Dana Dunleavy et al., Medical School 

Admissions: More than Grades and 
Test Scores, 11 Analysis in Brief No. 6 
(AAMC Sept. 2011).................................   24-25

William H. Frey, America’s Diverse 
Future: Initial Glimpses at the U.S.
Child Population from the 2010 Census 
(Brookings 2011)................................................... 10

Liliana M. Garces & David Mickey-
Pabello, Racial Diversity in the Medical 
Profession: The Impact of Affirmative 
Action Bans on Underrepresented 
Student of Color Matriculation in 
Medical Schools, 86 J. of Higher Ed.
264 (2015)..............................................................33

Douglas Grbic & Franc Slapar, Changes 
in Medical Students’ Intentions to 
Serve the Underserved: Matriculation 
to Graduation, 9 Analysis in Brief No.
8 (AAMC July 2010).............................................9

Alexander R. Green et al., Implicit Bias 
among Physicians and its Prediction of 
Thrombolysis Decisions for Black and 
White Patients, 22 J. Gen. Internal 
Med. 1231 (2007) 16



V l l l

Gretchen Guiton et al., Student Body 
Diversity: Relationship to Medical 
Students’ Experiences and Attitudes, 82 
Acad. Med. SI (Oct. 2007 Supp.).......................15

U.S. Dep’t of Health & Human Servs.
(“HHS”), Agency for Healthcare 
Research & Quality, 2014 National 
Healthcare Quality and Disparities 
Report (2015)............................................................8

HHS, Nat’l Comm, of Vital & Health 
Stats., 2005, Eliminating Health 
Disparities: Strengthening Data on 
Race, Ethnicity, and Primary 
Language in the United States (2005).........   12

Lu Hong & Scott E. Page, Groups of 
Diverse Problem Solvers Can 
Outperform Groups of High-Ability 
Problem Solvers, 101 Proc. Natl Acad.
Sci. USA 16385 (2004)..........................................18

Liaison Comm, on Med. Educ., Functions 
and Structure of a Medical School- 
Standards for Accreditation of Medical 
Education Programs Leading to the 
M.D. Degree (2015)..................................16-17, 21

Bruce G. Link, Epidemiological Sociology 
and the Social Shaping of Population 
Health, 49 J. of Health & Soc. Behav.
367 (2008)

TABLE OF AUTHORITIES— Continued
Page(s)

7-8



IX

TABLE OF AUTHORITIES— Continued

Filo Maldonado, Rethinking the 
Admissions Process: Evaluation 
Techniques That Promote Inclusiveness 
in Admissions Decisions, in The Right 
Thing to Do, The Smart 'Thing to Do: 
Enhancing Diversity in the Health 
Professions (Inst, of Med. 2001).............

Leon McDougle et al., A National Long­
term Outcomes Evaluation of U.S. 
Premedical Postbaccalaureate 
Programs Designed to Promote Health 
care Access and Workforce Diversity, 26
J. Health Care for Poor & Underserved 
631 (2015)............................... ...................

Emory Morrison & David A. Cort, An 
Analysis of the Medical School 
Pipeline: A High School Aspirant to 
Applicant and Enrollment View, 14 
Analysis in Brief No. 3 (AAMC Mar. 
2014)...........................................................

Emory Morrison & Douglas Grbic, 
Dimensions of Diversity and Perception 
of Having Learned From Individuals 
From Different Backgrounds: The 
Particular Importance of Racial 
Diversity, 90 Acad. Med. 937 (2015)......

Nat’l Comm’n on Certification of 
Physician Assistants, 2014 Statistical 
Profile of Recently Certified Physician 
Assistants (2015).......................................

Page(s)

24

30

32

15-16

10



X

Nat’l Insts. of Health, Draft Report o f the

TABLE OF AUTHORITIES— Continued
Page(s)

Advisory Committee to the Director
Working Group on Diversity in the
Biomedical Research Workforce (2012).......18--19

Scott E. Page, The Difference: How the 
Power of Diversity Creates Better 
Groups, Firms, Schools, and Societies 
(2007)......      18

Physician Assistant Educ. Ass’n, By the 
Numbers: Matriculating Students 
Survey 2014 (May 2015)...................................... 10

Lewis F. Powell, Jr., Stare Decisis and 
Judicial Restraint, 1991 J. Sup. Ct.
Hist. 13 (1991)........................................................34

Janice A. Sabin et al., Physicians’ 
Implicit and Explicit Attitudes About 
Race by MD Race, Ethnicity, and 
Gender, 20 J. Health Care for Poor &
Underserved 896 (2009)................................... 16

Somnath Saha et al., Student Body 
Racial and Ethnic Composition and 
Diversity-Related Outcomes in US 
Medical Schools, 300 JAMA 1135 (2008)......... 15

Somnath Saha & Scott A. Shipman,
Race-Neutral Versus Race-Conscious
Workforce Policy To Improve Access To
Care, 27 Health Aff. 234 (2008).......................8-9

Heena P. Santry & Sherry M. Wren, The 
Role of Unconscious Bias in Surgical 
Safety and Outcomes, 92 Surg. Clin. N.
Am. 137 (2012).................................................8, 16



XI
TABLE OF AUTHORITIES— Continued

Page(s)
David Satcher, Embracing Culture,

Enhancing Diversity, and 
Strengthening Research, 99 Am. J.
Pub. Health S4 (Supp. 1 2009)..........................19

Valerie I. Sessa & Jodi J. Taylor, Exec­
utive Selection: Strategies for Success 
(Ctr. for Creative Leadership 2000)...................18

Laura B. Shrestha & Elayne J. Heisler,
The Changing Demographic Profile of 
the United States (Cong. Research Serv.,
Mar. 31, 2011)................................   10-11

Ann Steinecke et al., Race-Neutral 
Admission Approaches: Challenges and 
Opportunities for Medical Schools, 82 
Acad. Med. 117 (2007)......................................... 33

David M. Stoff et al., Introduction: The 
Case for Diversity in Research on 
Mental Health and HTV/AIDS, 99 Am.
J. Pub. Health S8 (Supp. 1 2009).....................  19

Lisa A. Tedesco, The Role of Diversity in 
the Training of Health Professionals, in 
The Right Thing to Do, The Smart 
Thing to Do: Enhancing Diversity in 
the Health Professions (Inst, of Med.
2001)................................................................ 12-13

David A. Thomas, The Truth About 
Mentoring Minorities: Race Matters, 79 
Harv. Bus. Rev. 98 (2001)..................................  13

Urban Univs. for HEALTH, Holistic 
Admissions in the Health Professions 
(Sept. 2014)............................................. 25-26, 28



Michelle van Ryn et al., Physicians’
Perceptions o f Patients’ Social and 
Behavioral Characteristics and Race 
Disparities in Treatment Recom­
mendations for Men With Coronary 
Artery Disease, 96 Am. J. Pub. Health 
351 (2006)..............................................................16

Michelle van Ryn & Jane Burke, The 
Effect of Patient Race and Socio- 
Economic Status on Physicians’
Perceptions of Patients, 50 Soc. Sci. &
Med. 813 (2000)..................................................... 16

Monica B. Vela et al., Improving 
Underrepresented Minority Medical 
Student Recruitment with Health 
Disparities Curriculum, 25 J. Gen.
Intern. Med. S82 (Supp. 2 2010)........................ 31

Kara Odom Walker et al., The 
Association Among Specialty, Race,
Ethnicity, and Practice Location 
Among California, Physicians in 
Diverse Specialties, 104 J. Natl Med.
Ass’n 46 (2012).........................................................8

Joel S. Weissman et al., Residents’
Preferences and Preparation for Caring 
for Underserved Populations, 78 J.
Urban Health 535 (2001)...................   8

Dean K. Whitla et al., Educational 
Benefits of Diversity in Medical School:
A  Survey of Students, 78 Acad. Med.
460 (2003)

xii
TABLE OF AUTHORITIES— Continued

Page(s)

20



X l l l

Shanita D. Williams et al., Using Social 
Determinants of Health to Link Health 
Workforce Diversity, Care Quality and 
Access, and Health Disparities to 
Achieve Health Equity in Nursing, 129 
Pub. Health Rep. 32 (2014 Supp. 2 )...........19-20

Robert A. Witzburg & Henry M.
Sondheimer, Holistic Review—Shaping 
the Medical Profession One Applicant 
at a Time, 368 New Eng. J. Med. 1565 
(Apr. 25, 2013)

TABLE OF AUTHORITIES— Continued
Page(s)

20, 28



In  T he

S u p r e m e  C o u r t  of tfje ® n tte b  i§>tatp£

No. 14-981

A bigail N oel Fisher ,
Petitioner,

v.

U niversity  of Texas at  A u stin , et al.,
Respondents.

On Writ of Certiorari to the 
United States Court of Appeals 

for the Fifth Circuit

BRIEF FOR AMICI CURIAE 
ASSOCIATION OF AMERICAN 
MEDICAL COLLEGES ET AL. 

IN SUPPORT OF RESPONDENTS

INTEREST OF AMICI CURIAE
The Association of American Medical Colleges

(“AAMC”) is a non-profit educational association 
whose members include all 145 accredited U.S. 
medical schools; the 17 accredited Canadian medical 
schools; nearly 400 major teaching hospitals and 
health systems, including 51 Department of 
Veterans Affairs medical centers; and 90 academic 
and scientific societies.1 Through these institutions

1 No counsel for a party authored this brief in whole or in 
part, and no counsel or party made a monetary contribution



2

and organizations, the AAMC represents 148,000 
faculty members, 83,000 medical students, and 
115,000 resident physicians. Founded in 1876, the 
AAMC, through its many programs and services, 
strengthens the world’s most advanced medical care 
by supporting the entire spectrum of education, 
research, and patient care activities conducted by its 
member institutions.

AAMC is joined in this brief by twelve 
organizations whose members include schools, 
residency programs, and other institutions involved 
in educating and training health care providers and 
administrators: the American Association of 
Colleges of Nursing, American Association of 
Colleges of Osteopathic Medicine, American 
Association of Colleges of Pharmacy, American 
Dental Education Association, Associated 
Medical Schools of New York, Association of 
Academic Health Centers, Association of 
American Veterinary Medical Colleges, 
Association of Schools and Programs of Public 
Health, Association of Schools of Allied Health 
Professions, Association of University 
Programs in Health Administration, National 
Association of Hispanic-Serving Health 
Professions Schools, Inc., and the Physician 
Assistant Education Association (“PAEA”); 
fifteen organizations whose members include 
physicians and other health care providers: the 
American Medical Association, American 
Dental Association, American Nurses

intended to fund the preparation or submission of this brief. No 
person other than the amici curiae or their counsel made a 
monetary contribution to its preparation or submission. The 
parties have consented to the filing of this brief.



3

Association, American Academy of Family 
Physicians, American Academy of Pediatrics, 
American Academy of Physician Assistants, 
American College of Obstetricians and 
Gynecologists, American College of Physicians, 
American Osteopathic Association, American 
Psychiatric Association, American Public 
Health Association, Association of American 
Indian Physicians, National Hispanic Medical 
Association, National Medical Association, and 
the Society of General Internal Medicine; three 
organizations that represent the interests of medical 
school students: the American Medical Student 
Association, National Medical Fellowships, Inc., 
and the Student National Medical Association; 
and two non-profit organizations dedicated to 
improving health care in Puerto Rican, Latino, and 
Hispanic communities: The ASPIRA Association, 
Inc., and the National Hispanic Health 
Foundation. Additional information regarding 
these organizations is provided in the Addendum to 
this brief.

SUMMARY OF THE ARGUMENT
At its best, the quality of medical care in the 

United States is unmatched throughout the world, in 
large part because of its unparalleled medical 
education institutions. As the gatekeepers to the 
medical profession, medical schools have obligations 
that extend beyond their individual students to 
society at large. Those obligations include redressing 
current disparities in health care, where minority 
patients tend to receive less and lower quality care. 
The Nation’s medical schools must ensure not only 
that graduating physicians will be able to practice 
medicine at the highest levels, but also that



4

Medical schools have learned over many decades of 
experience that these goals cannot be accomplished 
unless physicians are educated in environments that 
reflect the ever-increasing diversity of the society 
they serve. As a result, access to medical education 
has never been determined solely by metrics such as 
test scores and grades. Rather, admission has 
historically been based on a holistic evaluation 
process—including personal interviews—in which an 
applicant’s background is taken into account along 
with myriad other factors.

In 2012, the AAMC, alongside 29 other 
organizations involved with the education of 
physicians and other health professionals, submitted 
a brief to the Court in this case, describing the 
importance of student diversity in health 
professional educational settings and the continued 
need, in the context of selecting a student body to 
achieve an educational institution’s mission, to 
consider race and ethnicity among other factors in 
the admissions process. Those needs have not 
changed. Nor has the responsibility given to 
educational institutions to prepare physicians and 
other health professionals to care for all Americans.

In Regents of the University of California v. Bakke, 
438 U.S. 265 (1978), the Court approved of this 
holistic evaluation process, with Justice Powell 
providing the deciding rationale. As he explained:

Physicians serve a heterogeneous population. An 
otherwise qualified medical student with a 
particular background—whether it be ethnic, 
geographic, culturally advantaged or disadvan­

competent medical care in different practice areas
will reasonably be available to all who need it.



5

taged—may bring to a professional school of 
medicine experiences, outlooks, and ideas that 
enrich the training of its student body and better 
equip its graduates to render with understanding 
their vital service to humanity.

Id. at 314 (Powell, J.). Twenty-five years later, the 
Court specifically endorsed Justice Powell’s rationale, 
after observing that “ [pjublic and private universities 
across the Nation have modeled their own admis­
sions programs on Justice Powell’s views.” Grutter v. 
Bollinger, 539 U.S. 306, 323 (2003); see also id. at 
387 (Kennedy, J., dissenting) (“The opinion by 
Justice Powell, in my view, states the correct rule for 
resolving this case.”).

Justice Powell’s words ring as true today as they 
did thirty-seven years ago. Indeed, the need to train 
the next generation of physicians in a diverse 
educational environment is even more important 
now, as our society has become even more hetero­
geneous. Research shows that when physicians 
understand more about the diverse cultures of their 
patients, physician decision-making is better 
informed and medical outcomes improve. Thus, 
preventing medical educators from continuing to 
consider diversity would not merely impoverish the 
educational experience of all future doctors; it would 
diminish their ability “to render with understanding 
their vital service to humanity.” Bakke, 438 U.S. at 
314 (Powell, J.).

In the thirty-seven years since Bakke, medical 
schools throughout the Nation have been 
implementing and refining holistic methods for 
evaluating applicants of the type approved by Justice 
Powell and later endorsed by the Court. In 
evaluating an applicant’s ability to contribute to and



6

benefit from an enriching educational environment, 
race is considered merely as one of a multitude of 
factors, none of which is dispositive standing alone. 
Although test scores and grades are a significant 
barometer of merit, they have never been 
independently determinative in medical school 
admissions. The goal is not mechanically to admit 
students based on numerical criteria or to mirror the 
country’s demographics, but rather to produce a class 
of physicians best equipped to serve all of society.

There is no proven substitute for this individual­
ized, holistic review that may consider an applicant’s 
race and ethnicity along with all other factors that 
make up his or her background. As this Court 
recognized in Grutter, 539 U.S. at 340, for medical 
schools and other graduate institutions there is 
nothing akin to the State’s “Top 10%” plan, which 
achieves a degree of diversity only because of 
underlying residential segregation in Texas. Health 
professional educators have found no other proxy 
that could substitute for individualized consideration 
of an applicant’s entire background.

Dating to Bakke and continuing through Grutter, 
the Nation’s medical schools have relied on this 
Court’s approval of the legal framework supporting 
their holistic, individualized evaluation process, 
which furthers the schools’ societal obligation to 
ensure that physicians will be competent to serve 
their increasingly diverse patients. Overruling the 
judgment of these expert educators would effectively 
prevent medical schools from fully carrying out that 
obligation, to the detriment of patient health. 
Accordingly, amici urge this Court to take no action 
that would disrupt the admissions processes that



7

have been carefully crafted in reliance on these 
longstanding precedents.

ARGUMENT
I. DIVERSITY IS A VITAL COMPONENT OF 

THE EDUCATIONAL MISSION OF THE 
NATION’S MEDICAL SCHOOLS.

A. Physicians Must Understand How To 
Serve Diverse Communities.

The current picture of health in America is sim­
ultaneously bright and bleak. While we are better 
equipped than ever with biomedical knowledge and 
technology to both avoid disease and prevent early 
death, certain segments of the population have been 
slow to benefit from these advancements.

Significant health disparities exist along lines of 
socio-economic status, urban or rural residence, and, 
most notably, race and ethnicity. See Bruce G. Link, 
Epidemiological Sociology and the Social Shaping of 
Population Health, 49 J. of Health & Soc. Behav. 367 
(2008). Minority populations continue to dispropor­
tionately suffer from numerous health conditions. 
Non-Hispanic black adults, for example, are at least 
50% more likely to die prematurely (i.e., before age 
75) of heart disease or stroke than their non- 
Hispanic white counterparts. The prevalence of 
adult diabetes is higher among Hispanics, non- 
Hispanic blacks, and those of other or mixed races 
than among Asians and non-Hispanic whites. And 
the infant mortality rate for non-Hispanic blacks is 
more than double that for non-Hispanic whites. See 
Ctrs. for Disease Control & Prevention, CDC Health 
Disparities and Inequalities Report— United States, 
2013, 62 MMWR (Supp.) No. 3, at 101, 158, 172 (Nov. 
22, 2013) (www.cdc.gov/mmwr/pdfiother/su6203.pdf).

http://www.cdc.gov/mmwr/pdfiother/su6203.pdf


8

Despite lower rates of uninsured individuals, 
“disparities in quality and outcomes by income and 
race and ethnicity are large and persistent.” U.S. 
Dep’t of Health & Human Servs. (“HHS”), Agency for 
Healthcare Research & Quality, 2014 National 
Healthcare Quality and Disparities Report, at 2 
(2015) (www. ahrq. gov/site s/default/file s/wysiwyg/re se 
ar ch/findings/nhqr dr/nhqdr 14/2014nhqdr .p df) • When 
new technologies emerge to fight disease, minorities 
experience substantially slower and fewer benefits 
than non-minorities. See Link, supra. While some of 
these disparities are due to lower levels of health 
care in minority communities, the disparities persist 
even where access is universal, such as in veterans’ 
care. See Heena P. Santry & Sherry M. Wren, The 
Role of Unconscious Bias in Surgical Safety and 
Outcomes, 92 Surg. Clin. N. Am. 137 (2012).

Moreover, minority communities are both medical­
ly underserved and served disproportionately by 
physicians of their own race or ethnicity. Commun­
ities with high proportions of African-American and 
Hispanic residents are far more likely to have a 
physician shortage, regardless of income levels. See, 
e.g., Joel S. Weissman et al., Residents’ Preferences 
and Preparation for Caring for Underserved 
Populations, 78 J. Urban Health 535 (2001); see also 
Kara Odom Walker et al., The Association Among 
Specialty, Race, Ethnicity, and Practice Location 
Among California Physicians in Diverse Specialties, 
104 J. Nat’l Med. Ass’n 46 (2012). Underserved res­
idents also rely heavily on underrepresented 
minority physicians for their care, because relatively 
few non-minority physicians practice in those areas. 
See Somnath Saha & Scott A. Shipman, Race- 
Neutral Versus Race-Conscious Workforce Policy To



9

Improve Access To Care, 27 Health Aff. 234 (2008); 
William T. Basco Jr. et al., Assessing Trends in 
Practice Demographics of Underrepresented Minority 
Pediatricians, 1993-2007, 125 Pediatrics 460 (2010).

African-American and Hispanic/Latino medical 
school graduates are more likely than their white 
and Asian counterparts to consider serving under­
served communities. A recent study revealed that, 
by the time of graduation, 56% of African-American 
and 42% of Hispanic/Latino students were willing to 
serve the underserved as compared with only 21% of 
Asian and 23% of white students. Douglas Grbic & 
Franc Slapar, Changes in Medical Students’ 
Intentions to Serve the Underserved: Matriculation to 
Graduation, 9 Analysis in Brief No. 8, at 2 (AAMC 
July 2010). A recent Senate Report reached the 
similar conclusion that “ [d]iversity among medical 
school students is associated with * * * greater 
willingness to serve diverse populations,” and found 
evidence to suggest that “minority health profession­
als are more likely to serve in areas with high rates 
of uninsured and areas of underrepresented racial 
and ethnic groups.” S. Rep. No. 114-74, at 42 (2015).

At the same time, it is estimated that by 2025, 
there will be a shortage of between 46,000-90,000 
physicians in the U.S. See AAMC, The Complexities 
of Physician Supply and Demand: Projections from 
2013 to 2025, at v (2015) (https://www.aamc.org/ 
download/426242/data/ihsreportdownload.pdf). Phy­
sician assistants and nurse practitioners are playing 
an increasing role in the health professions 
workforce and are helping to improve access to care. 
In 2014, the number of entering medical school 
students that identified as Black or African- 
American, Hispanic or Latino, or American Indian or

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10

Alaska Native was 12.3%. AAMC, Applicants, First- 
Time Applicants, Acceptees, and Matriculants to U.S. 
Medical Schools by Race/Ethnicity, 2013-2014 and 
2014-2015, at 2 (2014) (www.aamc.org/download/ 
321480/data/factstable 12.pdf) (table 12). As of fall 
2014, approximately 22% of nursing students 
enrolled across program levels were underrepre­
sented minorities. See Am. Ass’n of Colls, of Nursing 
(“AACN”), 2014-2015 Enrollment and Graduations in 
Baccalaureate and Graduate Programs in Nursing 
(2015) (table 9). In 2014, less than 4% of physician 
assistant matriculants identified as Black or African- 
American or American Indian or Alaskan Native, 
and 6% self-identified as Hispanic, Latino, or 
Spanish. See PAEA, By the Numbers: Matriculating 
Students Survey 2014, at 21 (May 2015) (table 39). 
Among recently certified physician assistants, less 
than 4% self-identified as Black or African-American 
or American Indian or Alaskan Native, and 7% self- 
identified as Hispanic, Latino, or Spanish. See Nat’l 
Comm’n on Certification of Physician Assistants, 
2014 Statistical Profile of Recently Certified 
Physician Assistants, at 10 (2015) (tables 4 & 5).

In contrast, Non-Hispanic Black or African- 
American, Non-Hispanic American Indian or Alaska 
Native, and Hispanic or Latino people constitute 
30.5% of the total U.S. population, with that number 
expected to increase.2 It is therefore plain that

2 This calculation is based on data from the U.S. Census as 
of July 1, 2014. See U.S. Census Bureau, American FactFinder 
(factfinder.census.gov/faces/nav/jsf/pages/index.xhtml); see also 
William H. Frey, America’s Diverse Future: Initial Glimpses at 
the U.S. Child Population from the 2010 Census (Brookings 
2011) (http://www.brookings.edU/~/media/research/files/papers/ 
2011/4/06-census-diversity-frey/0406_census_diversity_frey. 
pdf); Laura B. Shrestha & Elayne J. Heisler, The Changing

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11

health professionals of all races and ethnicities must 
learn to better serve the country’s diverse patient 
population in order to reduce disparities in health 
outcomes. See AMA Code of Medical Ethics, Op. 
9.121, Racial and Ethnic Health Care Disparities 
(calling on physicians to recognize and reduce racial 
and ethnic disparities in health care).

The Nation’s medical schools and other health 
professional schools believe that a key component of 
a comprehensive strategy to eliminate the health 
disparities described above is to develop a workforce 
of people from all backgrounds to bridge the current 
differences between providers and patients. In 
addition to graduating physicians with the highest 
medical skills, medical schools also seek to train 
physicians with high levels of “cultural competence.” 
These are physicians who are familiar with the con­
nection between socio-cultural factors and health 
beliefs and behaviors and who have the tools and 
skills to manage these factors appropriately to help 
eliminate socio-cultural barriers to care. See Joseph 
R. Betancourt et al., Defining Cultural Competence: 
A Practical Framework for Addressing Racial/Ethnic 
Disparities in Health and Health Care, 118 Pub. 
Health Rep. 293, 297-300 (2003).

Nursing programs across the country have also 
placed greater emphasis on educating a culturally 
competent workforce. The objective is to educate and 
train students to provide patient-centered care that 
identifies, respects, and addresses differences in 
patients’ values, preferences, and expressed needs. 
See AACN, Cultural Competency in Baccalaureate

Demographic Profile of the United States 18-23 (Cong. Research 
Serv., Mar. 31, 2011).



12

Nursing Education (2008) (www.aacn.nche.edu/ 
leading-initiatives/education-resources/competency 
.pdf); AACN, Establishing a Culturally Competent 
Master’s and Doctorally Prepared Nursing Workforce 
(2009) (www.aacn.nche.edu/education-resources/Cult 
uralComp.pdf). These efforts further the profession’s 
objective of eliminating health disparities that 
nurses must address in a global environment, in 
partnership with other health care disciplines. See 
HHS, Nat’l Comm, on Vital & Health Stats., 2005, 
Eliminating Health Disparities: Strengthening Data 
on Race, Ethnicity, and Primary Language in the 
United States (2005) (www.cdc.gov/nchs/data/misc/ 
EliHealthDisp.pdf).

Medical schools strongly believe that diversity in 
the educational environment is integral to instilling 
in new physicians the cultural competence necessary 
to more effectively serve a diverse society. They are 
committed to creating a diverse educational 
environment because they believe that a diverse 
student body produces educational outcomes that 
ultimately benefit public health. “ [MJuch of the point 
of education is to teach students how others think 
and to help them understand different points of 
view—to teach students how to be sovereign, 
responsible, and informed citizens in a heterogene­
ous democracy.” Akhil Reed Amar & Neal Kumar 
Katyal, Bakkes Fate, 43 UCLA L. Rev. 1745, 1774 
(1996). For medical schools, the educational benefits 
of diversity are fundamentally necessary to improve 
health outcomes throughout the United States. A 
diverse classroom “provide [s] a unique contribution 
to learning, discussion, and understanding that is 
not necessarily attainable elsewhere.” Lisa A. 
Tedesco, The Role of Diversity in the Training of

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13

Health Professionals, in The Right Thing to Do, The 
Smart Thing to Do: Enhancing Diversity in the 
Health Professions 36, 50 (Inst, of Med. 2001). And 
opportunities for students to be mentored by diverse 
medical leaders significantly enhance the learning 
environment. See David A. Thomas, The Truth 
About Mentoring Minorities: Race Matters, 79 Harv. 
Bus. Rev. 98 (2001).

Just as Justice Powell recognized more than three 
decades ago, amici remain convinced that because 
“ [pjhysicians serve a heterogeneous population” they 
must be educated in a medical school that includes 
students of all backgrounds, who bring “experiences, 
outlooks, and ideas that enrich the training of its 
student body and better equip its graduates to 
render with understanding their vital service to 
humanity.” Bakke, 438 U.S. at 314 (Powell, J.). As 
discussed further below, medical schools continue to 
carry out that societal obligation by employing the 
holistic admissions process approved by Justice 
Powell and later endorsed by the Court, which 
properly considers an applicant’s entire background 
without predetermined quotas or outcomes.

B. The Benefits Of Diversity Are 
Indispensable To Achieving Core 
Educational Goals.

Diversity in medical school admissions is not an 
end in itself, but rather a means to achieving core 
educational goals defined by the institution. See 
Amy N. Addams et al., Roadmap to Diversity: 
Integrating Holistic Review Practices into Medical 
School Admission Processes, at ix (AAMC 2010) 
(https://members.aamc.org/eweb/upload/Roadmap%2 
0to%20Diversity%20Integrating%20Holistic%20Revi 
ew.pdf). While diversity may include race, ethnicity,

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14

and gender, it is a “student-specific, multi­
dimensional concept” that “may encompass other 
dimensions of experiences and attributes” including, 
among other things, an applicant’s having overcome 
hardships or cultural barriers, languages spoken, 
socioeconomic status, and geography. Id.

This flexibility means that diversity is not a “one- 
size-fits-all” concept. Just as it can encompass a 
variety of factors within a single school, it may have 
different meanings from one school to the next. 
Depending on the “institutional mission, educational 
goals, the kind of students a medical school wants to 
educate, and the kind of physicians it wants to 
graduate,” the diversity interests of one medical 
school may be markedly different from those of 
another. Id. While their practices will likely share 
common elements, each school must determine how 
best to apply diversity principles in pursuing its in­
stitutional goals. “The key to success for any medical 
school seeking to enroll and graduate a broadly 
diverse class is the connection the school makes 
between the diversity it seeks and the educational, 
mission-driven goals to which it aspires.” Arthur L. 
Coleman et al., Roadmap to Diversity and 
Educational Excellence: Key Legal and Educational 
Policy Foundations for Medical Schools, at vii 
(AAMC 2d ed. 2014) (https://members.aamc.org/eweb 
/upload/14-050%20Roadmap%20to%20Diversity_2n 
d%20ed_FINAL.pdf) (incorporating guidance based 
on the Fisher I  decision) (emphasis in original).

For most medical schools, these goals include 
producing culturally-competent physicians who are 
well-adapted to serve patients from across the varied 
racial and ethnic makeup of the Nation. As this 
Court recognized in Grutter, “numerous studies show

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15

that student body diversity promotes learning 
outcomes, and ‘better prepares students for an 
increasingly diverse workforce and society, and 
better prepares them as professionals.”’ 539 U.S. at 
330 (citation omitted).

In the medical education environment, these 
benefits are particularly important because public 
health is at stake, not just business interests. A 
diverse student body helps to promote the empathy, 
emotional intelligence, and cultural competence 
required of physicians and other health care 
professionals. Medical students who are educated in 
a diverse student body report that they are better 
able to work with patients of diverse backgrounds. 
Gretchen Guiton et al., Student Body Diversity: 
Relationship to Medical Students’ Experiences and 
Attitudes, 82 Acad. Med. SI, SI (Oct. 2007 Supp.); see 
also Somnath Saha et al., Student Body Racial and 
Ethnic Composition and Diversity-Related Outcomes 
in US Medical Schools, 300 JAMA 1135, 1135 (2008) 
(finding that non-minority students attending more 
racially diverse medical schools exhibited greater 
preparedness to care for minority patients and 
stronger attitudes about equitable access to health 
care). The benefits are even greater when students 
engage in informal discussions about course 
materials with peers from diverse backgrounds, see 
Guiton, supra, at S4, and when medical schools 
actively promote student engagement and 
perspective-sharing across diverse backgrounds, see 
Saha et al., supra, at 1141. See also Emory Morrison 
& Douglas Grbic, Dimensions of Diversity and 
Perception of Having Learned From Individuals 
From Different Backgrounds: The Particular
Importance of Racial Diversity, 90 Acad. Med. 937



16

(2015) (graduating students associated racial/ethnic 
diversity within medical school class with greater 
ability to work with individuals from different 
backgrounds).

One contributor to health disparities is unconscious 
bias by physicians. Studies have shown that this 
bias exists and negatively impacts clinical decision 
making, which leads to negative treatment decisions 
and outcomes.3 There is also a connection between 
the unconscious bias of the physician and the 
patient’s negative response to that behavior. See 
Lisa A. Cooper et al., The Associations of Clinicians’ 
Implicit Attitudes about Race with Medical Visit 
Communication and Patient Ratings of Interpersonal 
Care, 102 Am. J. Pub. Health 979 (2012).

In its Standards for Accreditation of Medical 
Education Programs Leading to the M.D. Degree, the 
Liaison Committee on Medical Education (“LCME”) 
evaluates whether the medical school curriculum 
“provides opportunities for medical students to learn

3 See, e.g., Santry & Wren, supra; Alexander R. Green et al., 
Implicit Bias among Physicians and its Prediction of 
Thrombolysis Decisions for Black and White Patients, 22 J. Gen. 
Internal Med. 1231 (2007); Janice A. Sabin et al., Physicians’ 
Implicit and Explicit Attitudes About Race by MD Race, 
Ethnicity, and Gender, 20 J. Health Care for Poor & 
Underserved 896 (2009); Laura M. Bogart et al., Factors 
Influencing Physicians’ Judgments of Adherence and Treatment 
Decisions for Patients with HIV Disease, 21 Med. Decision 
Making 28 (2001); Michelle van Ryn et al., Physicians’ 
Perceptions of Patients’ Social and Behavioral Characteristics 
and Race Disparities in Treatment Recommendations for Men 
With Coronary Artery Disease, 96 Am. J. Pub. Health 351 
(2006); Michelle van Ryn & Jane Burke, The Effect of Patient 
Race and Socio-Economic Status on Physicians’ Perceptions of 
Patients, 50 Soc. Sci. & Med. 813 (2000).



17

to recognize and appropriately address gender and 
cultural biases in themselves, in others, and in the 
health care delivery process.” LCME, Functions and 
Structure of a Medical School: Standards for Accred­
itation of Medical Education Programs Leading to 
the M.D. Degree (“Standards for Accreditation ’), at 
11 (2015) (Standard 7.6) (www.lcme.org/publicat 
ions.htm). Only by producing a workforce of health 
care professionals who are well-adapted to working 
in a diverse environment, with patients from all 
backgrounds, can health professional schools hope to 
alleviate some of these disparities in patient care.

Increased exposure to diverse perspectives may 
also increase an individual’s ability to understand, 
accept, and ultimately value disparate viewpoints. 
Research among college students indicates that this 
ability can increase after engaging in even a single 
discussion with an individual expressing a minority 
viewpoint. See Anthony Lising Antonio et al., Effects 
of Racial Diversity on Complex Thinking in College 
Students, 15 Psychol. Sci. 507 (2004). And prolonged 
exposure to diverse viewpoints may have a 
cumulatively stronger impact on complex thinking 
skills. Id. at 509. For a physician or other health 
professional attempting to properly diagnose and 
design treatment plans for patients with different 
cultures, backgrounds, belief systems, and support 
networks, the ability to consider and integrate other 
perspectives is an essential skill.

In turn, the ability to work with individuals having 
diverse perspectives can improve outcomes. Studies 
have indicated that groups of people with diverse 
backgrounds and ways of viewing the world outper­
form groups of people who have similar backgrounds 
and perspectives, even when the latter group is

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18

composed of those deemed to be the best individual 
performers. See Scott E. Page, The Difference: How 
the Power of Diversity Creates Better Groups, Firms, 
Schools, and Societies (2007). In the health care 
arena, “[d]iverse teams working together and 
capitalizing on individuality and distinct 
perspectives outperform homogenous teams. This is 
particularly true when teams address complex 
problems, such as those that characterize biomedical 
and behavioral research, technology, and health.” 
Nat’l Insts. of Health (“NIH”), Draft Report of the 
Advisory Committee to the Director Working Group 
on Diversity in the Biomedical Research Workforce 
(“NIH Draft Report”), at 11 (2012) (acd.od.nih.gov/ 
Diver sity % 2 Oin% 2 Othe % 2 OBiome dical% 2 ORe se arch% 
20Workforce%20Report.pdf) (citing Lu Hong & Scott 
E. Page, Groups of Diverse Problem Solvers Can 
Outperform Groups of High-Ability Problem Solvers, 
101 Proc. Nat’l Acad. Sci. USA 16385 (2004); Valerie 
I. Sessa & Jodi J. Taylor, Executive Selection: Strat­
egies for Success (Ctr. for Creative Leadership 2000)).

To capture the proven benefits of team-based, 
patient-centered care using a team of professionals 
with diverse perspectives, medical schools 
increasingly require students to work in teams and 
train alongside students in other fields. This inter­
professional education can help future health care 
providers learn to work in a collaborative environ­
ment that considers all aspects of health, lifestyle, 
and background to provide the best patient care. 
Similarly, medical school students whose classmates 
represent diverse perspectives will be more prepared 
and capable of working collaboratively alongside 
others with diverse perspectives. “A workforce that 
brings the full power of diversity to pursue



19

biomedical and behavioral research problems that 
address the needs of underrepresented racial and 
ethnic minorities is an important component of 
reducing these health inequities.” NIH Draft Report, 
supra, at 11 (citing David M. Stoff et al., 
Introduction: The Case for Diversity in Research on 
Mental Health and HIV/AIDS, 99 Am. J. Pub. 
Health S8 (Supp. 1 2009)). As indicated by a former 
Surgeon General, “a diverse team of researchers will 
be more likely to ask and pursue the most 
appropriate questions in the most appropriate 
manner—whether in basic and clinical research, or 
in health services!] and behavioral research.” Id. 
(citing David Satcher, Embracing Culture, 
Enhancing Diversity, and Strengthening Research, 
99 Am. J. Pub. Health S4 (Supp. 1 2009)).

To select candidates embodying these diverse 
viewpoints, medical schools consider factors that can 
include rural or urban backgrounds, bachelor’s 
degrees in the sciences or liberal arts, unusual life 
experiences or journeys, and disparate racial and 
economic backgrounds, among others. A richly 
diverse class can contribute to a dynamic, multi­
dimensional educational environment where 
classroom and study-group discussions add insight 
and texture to course materials.

These benefits have been recognized in nursing as 
well. Researchers with the Health Resources and 
Services Administration of the U.S. Department of 
Health and Human Services have explicitly 
identified “nursing workforce diversity as a key 
strategy for increasing access to quality health care 
and health-care resources.” Shanita D. Williams et 
al., Using Social Determinants of Health to Link 
Health Workforce Diversity, Care Quality and Access,



20

and Health Disparities to Achieve Health Equity in 
Nursing, 129 Pub. Health Rep. 32, 33 (2014 Supp. 2).

These benefits of diversity in health professional 
education have been recognized by Congress, see 
Disadvantaged Minority Health Improvement Act of 
1990, Pub. L. No. 101-527, § l(b)(12), 104 Stat. 2311, 
2312 (1990) (finding that “diversity in the faculty 
and student body of health professions schools 
enhances the quality of education for all students 
attending the schools”); by students, see, e.g., Dean
K. Whitla et al., Educational Benefits of Diversity in 
Medical School: A Survey of Students, 78 Acad. Med. 
460, 466 (2003) (medical school students over­
whelmingly reported that contacts with diverse peers 
greatly enhanced their educational experiences); and 
by faculty, see, e.g., Robert A. Witzburg & Henry M. 
Sondheimer, Holistic Review— Shaping the Medical 
Profession One Applicant at a Time, 368 New Eng. J. 
Med. 1565, 1567 (Apr. 25, 2013) (according to 
medical school faculty, students selected through 
holistic review are “more collegial, more supportive 
of one another, more engaged in the curriculum, and 
more open to new ideas and to perspectives different 
from their own”). “[I]t is not too much to say that the 
‘nation’s future depends upon leaders trained 
through wide exposure’ to the ideas and mores of 
students as diverse as this Nation of many peoples.” 
Bakke, 438 U.S. at 313 (Powell, J.) (citation omitted).

Efforts to promote the inclusion of racial and ethnic 
minorities are vital to the educational goals of 
medical and other health professional schools. Amici 
have concluded that a diverse educational 
environment is essential to addressing the health 
care needs of an increasingly diverse population. 
This educational judgment warrants deference. See



21

Fishery. Univ. of Tex., 133 S. Ct. 2411, 2419 (2013) 
(‘‘Grutter calls for deference to the University’s 
conclusion, ‘based on its experience and expertise,’ 
that a diverse student body would serve its 
educational goals.”) (citation omitted); Grutter, 539 
U.S. at 328 (“The Law School’s educational judgment 
that such diversity is essential to its educational 
mission is one to which we defer.”).

The bodies responsible for accrediting medical 
schools likewise recognize the important role that 
student diversity plays in the effective delivery of 
health care. In its Standards for Accreditation, the 
LOME evaluates whether

[a] medical school has effective policies and 
practices in place, and engages in ongoing, 
systematic, and focused recruitment and 
retention activities, to achieve mission- 
appropriate diversity outcomes among its 
students, faculty, senior administrative staff, and 
other relevant members of its academic 
community. These activities include the use of 
programs and/or partnerships aimed at achieving 
diversity among qualified applicants for medical 
school admission and the evaluation of program 
and partnership outcomes.

Standards for Accreditation, supra, at 4 (Standard 
3.3).

Other accrediting organizations for health profes­
sional programs have adopted similar standards. 
The Commission on Osteopathic College Accredita­
tion advises: “A diverse student body provides the 
richness necessary for osteopathic medical education. 
A [school] should make every effort to recruit 
students from a diverse background to foster that



22

richness while meeting its mission and objectives.” 
Comm’n on Osteopathic Coll. Accreditation, Accredi­
tation of Colleges of Osteopathic Medicine: COM  
Accreditation Standards and Procedures, at 18 
(2015) (www.osteopathic.org/inside-aoa/accreditation/ 
predoctoral%20accreditation/Documents/COM- 
accreditation-standards-current.pdf) (Guideline to 
Rule 5.3.2).

The Commission on Dental Accreditation has simi­
larly recognized that “the demographics of our soci­
ety are changing,” and that “ [diversity in education 
is essential to academic excellence.” Comm’n on 
Dental Accreditation, Accreditation Standards for 
Dental Education Programs, at 12, 16 (2015) (www. 
ada.org/~/media/CODA/Files/predoc.ashx). Echoing 
the importance of cultural competence in the medical 
profession, the most recent standards emphasize the 
role of classroom diversity in achieving this goal:

A significant amount of learning occurs through 
informal interactions among individuals who are 
of different races, ethnicities, religions, and 
backgrounds; come from cities, rural areas and 
from various geographic regions; and have a wide 
variety of interests, talents, and perspectives. 
These interactions allow students to directly and 
indirectly learn from their differences, and to 
stimulate one another to reexamine even their 
most deeply held assumptions about themselves 
and their world. Cultural competence cannot be 
effectively acquired in a relatively homogenous 
environment. Programs must create an environ­
ment that ensures an in-depth exchange of ideas 
and beliefs across gender, racial, ethnic, cultural 
and socioeconomic lines.

Id. at 16.

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23

These standards, like those adopted by other 
accrediting bodies, are not (as some have incorrectly 
argued)4 directives to schools to implement any par­
ticular form of diversity policies. The standards do 
not define diversity. Instead, the LCME and other 
accrediting organizations defer to each individual 
school with respect to what types and levels of 
diversity are best suited to achieve the mission and 
goals of that particular institution. None of these 
organizations has promoted a specific form of 
diversity, and yet all emphasize the vital role that it 
plays in educating and training health care 
professionals. Prohibiting medical educators from 
valuing and achieving diversity would harm both 
students and the broader society that they are being 
trained to serve.

II. MEDICAL SCHOOLS HAVE LONG 
RELIED ON HOLISTIC REVIEW FOR 
ADMISSIONS DECISIONS.

Because consideration of grades and test scores 
alone is insufficient in selecting a student body that 
will achieve a school’s distinct educational goals and 
mission, most medical schools have adopted a holistic 
review process similar to that upheld by this Court 
in Grutter. Holistic review is a flexible, highly- 
individualized consideration of the multiple ways in 
which medical school applicants can demonstrate 
merit by matching an institution’s mission. “Under a 
holistic review framework, candidates are evaluated 
by criteria that are institution-specific, broad-based, 
and mission-driven and that are applied equitably 
across the entire candidate pool.” Addams et al.,

4 See Heriot Amicus Br. at 14—15; Cal. Ass’n of Scholars 
Amicus Br. at 14—15.



24

supra, at ix. Since well before Grutter, most medical 
schools have used at least some form of highly- 
individualized review in the admissions process that 
considers the many dimensions of merit, and 
potential contributions to the learning environment, 
of each candidate.

A. Medical Schools Have A History Of 
Highly-Individualized Admissions 
Practices.

The qualities that contribute to a successful health 
care professional are impossible to measure with 
grades and test scores alone. “Medical educators 
agree that success in medical school requires more 
than academic competence; it also requires integrity, 
altruism, self-management, interpersonal and team­
work skills, among other characteristics.” Dana 
Dunleavy et al., Medical School Admissions: More 
than Grades and Test Scores, 11 Analysis in Brief 
No. 6, at 1 (AAMC Sept. 2011) (footnotes omitted). 
To assess these qualities, medical schools have a long 
history of highly-individualized admissions 
processes, including personal pre-admission 
interviews for every accepted applicant.

Although these processes vary with the educational 
mission and goals of each school, all medical schools 
consider a range of non-academic factors. Id. 
Medical schools have never exclusively relied on 
numerical criteria to select their student bodies. See 
Filo Maldonado, Rethinking the Admissions Process: 
Evaluation Techniques That Promote Inclusiveness 
in Admissions Decisions, in The Right Thing to Do, 
The Smart Thing to Do: Enhancing Diversity in the 
Health Professions 305-07 (Inst, of Med. 2001). 
While undergraduate GPA and MCAT scores are 
usually high on the list of considerations in



25

determining which applicants to interview, medical 
schools rank personal interviews and, to a lesser 
extent, letters of recommendation as the most 
important considerations in final acceptance 
decisions. Dunleavy et al., supra, at 2. In fact, 
between 2012 and 2014, 8.8% of applicants with the 
highest combined GPAs and MCAT scores were 
rejected by all of the medical schools to which they 
applied. See AAMC, MCAT and GPA Grid for 
Applicants and Acceptees to U.S. Medical Schools, 
2012-2014 (aggregated) (2014) (www.aamc.org/down 
load/321508/data/factstable24.pdf) (table 24).

Holistic review precludes any single criterion from 
becoming the uniform deciding factor for interview­
ing and selecting candidates for admission. Serious 
consideration is afforded to the ways in which each 
applicant might uniquely contribute to a diverse edu­
cational environment and advance the school’s spe­
cific mission. A recent survey of health professional 
schools tied holistic review to the following insti­
tution-specific missions: serving underserved rural 
communities, serving underserved urban commun­
ities, research, primary care, and global health. See 
Urban Univs. for HEALTH, Holistic Admissions in 
the Health Professions 20 (Sept. 2014) (http:// 
urbanuniversitiesforhealth.org/media/documents/ 
Hohstic_Admissions_in_the__Health_Professions.pdf). 
Each candidate is able to communicate his or her 
potential as more than a set of numbers, and, 
through holistic review, medical schools are able to 
consider these factors in light of the institutional 
goals for the classroom, clinical practice, and 
biomedical research. See Addams et al., supra, at x. 
This holistic consideration of applicants is precisely

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26

For some schools, the range of factors considered 
during holistic review may include race, ethnicity, 
and gender. However, these factors are only 
considered to the extent necessary to achieve clearly 
articulated mission-driven benefits. Id. at 6. To the 
extent that race is considered, it is never considered 
in isolation. Health professional schools assess the 
following non-academic criteria through holistic 
review: status as a first-generation college student, 
experience with disadvantaged populations, 
socioeconomic status, origin in a community that is 
medically underserved, origin in a geographic area 
specifically targeted by the school, race/ethnicity (if 
permitted by state law), and foreign language ability. 
See Holistic Admissions in the Health Professions, 
supra, at 19. Race is considered flexibly as just one 
of the many characteristics and pertinent elements 
of each individual’s background. Characteristics that 
make an individual particularly well-suited for the 
medical profession, such as resilience or the ability to 
overcome challenges, may in some cases be 
intertwined with an individual’s race or ethnicity. 
When candidates have overcome great race-related 
challenges, obscuring or denying the realities of 
these challenges will hinder a full appreciation of the 
applicant’s potential contributions.

For most schools, there is no substitute for the 
consideration of an individual’s racial identity and 
ethnic background as part of the holistic review 
process intended to ensure that health professionals 
are educated in a diverse environment. As the Court 
indicated in Grutter, “percentage plans,” such as the 
one used by respondent for undergraduate admis­

the reason that individual interviews are so vital to
the medical school admissions process.



27

sions, do not translate to the professional school 
environment. See Grutter, 539 U.S. at 340 (“The 
United States does not * * * explain how such plans 
could work for graduate and professional schools. 
Moreover, even assuming such plans are race- 
neutral, they may preclude the university from 
conducting the individualized assessments necessary 
to assemble a student body that is not just racially 
diverse, but diverse along all the qualities valued by 
the university.”). Most medical schools draw from a 
nationwide (and often worldwide) applicant pool that 
makes it impossible to make simple comparisons 
based on grade point averages. And, as noted, such 
comparisons do not begin to capture the range of 
qualities that schools have always considered.

Moreover, medical schools have expressly relied on 
this Court’s pronouncements in crafting their holistic 
review procedures. After the Court’s decision in 
Grutter, the AAMC convened an Advisory Committee 
on Holistic Review, a constituent working group, to 
address how to increase diversity among health 
professional students in alignment with the frame­
work upheld by the Court. The Advisory Committee 
began developing tools and resources, such as the 
Roadmap guidance documents discussed above, that 
medical schools could adopt or adapt to create and 
sustain student diversity through the use of holistic 
review in the admissions process. Using these tools, 
the AAMC has conducted cross-country workshops 
with more than 60 medical schools, osteopathic 
schools, and nursing schools. The AAMC’s 
commitment to assisting schools in crafting 
institution-specific diversity policies in the context of 
a legally-sound holistic review process is ongoing, 
with the recent addition of a third Roadmap



28

guidance document on self-evaluation of admissions 
practices and policies.

Medical schools do not use the Court’s approved 
holistic review framework as a substitute for merit- 
based consideration of medical school applicants. 
Rather, it is a process through which medical schools 
are better able to appreciate the individual merits of 
each candidate to be a successful student and, 
ultimately, physician. One medical school reports 
that students admitted through holistic review are at 
least as well prepared academically as students 
admitted prior to the implementation of holistic 
review (the average GPA and average MCAT score 
were 3.66 and 33.62 for the entering class of 2012, as 
compared with 3.57 and 31.68 for the entering class 
of 2008). Witzburg & Sondheimer, supra, at 1567. 
This finding tracks those reported in a recent survey 
of public schools of medicine, dentistry, nursing, 
pharmacy, and public health using holistic review in 
admissions: 90% of the schools reported that the 
average GPA of incoming classes either remained 
unchanged or increased; 89% reported that average 
standardized test scores either remained unchanged 
or increased; 96% reported that graduation rates 
were either unchanged or increased; and 91% 
reported that the average number of attempts for 
students to pass required licensing exams either 
remained unchanged or improved. See Holistic 
Admissions in the Health Professions, supra, at 14.



29

B. Although Other Initiatives Have Shown 
Some Success, It Remains Necessary For 
Medical Schools To Consider Applicants’ 
Full Backgrounds In Order To Achieve 
The Schools’ Educational Goals.

Consistent with the requirements of narrow 
tailoring, direct consideration of race is to be 
continued only as necessary. Medical schools are 
implementing a host of initiatives outside of the 
admissions context to help achieve a diverse and cul- 
turally-competent student body and physician 
workforce. Those initiatives have had success in 
increasing the diversity of the medical school 
applicant pool. But this success has not been 
universal and such initiatives are not the complete 
answer. In order to discharge their obligations to 
produce well-trained health professionals who are 
prepared to serve all of society, many medical schools 
continue to find it necessary to consider an 
applicant’s entire background, including race or 
ethnicity as one factor among many.

“Pipeline” programs, which seek to encourage and 
prepare underrepresented minorities to pursue a 
medical education, have had promising results. For 
example, the Robert Wood Johnson Foundation has 
funded the Summer Medical and Dental Education 
Program (“SMDEP”) and its predecessor programs to 
increase diversity in the health professions for over 
25 years. This program is currently implemented at 
12 medical and 9 dental schools across the United 
States, serving 960 minority and socio-economically 
disadvantaged college students each year. To date, it 
has served over 23,000 aspiring health professionals. 
A 2015 study found that SMDEP increases the 
likelihood that students from diverse backgrounds



30

will apply and matriculate to both medical and 
dental school. See Clemencia Cosentino et al., 
Impact Evaluation of the RWJF Summer Medical 
and Dental Education Program (SMDEP), at x 
(Mathematica Jan. 28, 2015) (www.mathematica- 
mpr.com/our-publications-and-findings/publications/ 
impact-evaluation-of-the-rwjf-summer-medieal-and- 
dental-education-program-smdep).

Additional studies from smaller programs also 
demonstrate success in encouraging younger 
students to pursue the health professions. See, e.g., 
Behnoosh Afghani et al., A Novel Enrichment 
Program Using Cascading Mentorship to Increase 
Diversity in the Health Care Professions, 88 Acad. 
Med. 1232 (2013). And a recent study found that 
physicians who graduated from postbaccalaureate 
programs which help promising college graduates 
from disadvantaged and underrepresented back­
grounds get into and succeed in medical school were 
“significantly more likely to be providing care in 
settings that enable access to health care services for 
underserved and vulnerable populations” than a 
comparison physician group. Leon McDougle et al., 
A National Long-term Outcomes Evaluation of U.S. 
Premedical Postbaccalaureate Programs Designed to 
Promote Health care Access and Workforce Diversity, 
26 J. Health Care for Poor & Underserved 631, 639- 
40 (2015).

Medical schools have also invested in recruitment 
and outreach strategies that are designed to increase 
the number of underrepresented minority applicants 
and matriculants. For example, the USSTRIDE 
program at Florida State University, which provides 
academic and social support services and mentoring 
to college students, found that Black and Latino

http://www.mathematica-mpr.com/our-publications-and-findings/publications/
http://www.mathematica-mpr.com/our-publications-and-findings/publications/


31

participants had higher medical school acceptance 
rates than a comparison group. See Kendall M. 
Campbell et al., USSTRIDE Program is Associated 
with Competitive Black and Latino Student 
Applicants to Medical School, Med. Educ. Online 
(May 2014). And the University of Chicago Pritzker 
School of Medicine has found that having a focus in 
the medical school curriculum on health disparities 
among underrepresented minorities correlated with 
a significant increase in accepted underrepresented 
minorities deciding to matriculate. See Monica B. 
Vela et al., Improving Underrepresented Minority 
Medical Student Recruitment with Health Disparities 
Curriculum, 25 J. Gen. Intern. Med. S82, S83-85 
(Supp. 2 2010).

At the same time, systemic changes are also being 
made in the medical education system to address 
concerns about cultural competence in health care. 
For example, the AAMC and the Association of 
Schools and Programs of Public Health (“ASPPH”) 
have published joint recommendations for training 
medical and public health students to become more 
culturally competent practitioners. See AAMC & 
ASPPH, Cultural Competence Education for Students 
in Medicine and Public Health (July 2012) (members. 
aamc.org/eweb/upload/Cultural%20Competence%20E 
ducation_revisedl.pdf). AAMC has also worked to 
develop a new MCAT exam, which was introduced in 
2015 and is designed in part to measure how well an 
applicant understands the cultural, social, and socio­
economic differences that can influence health.

While many of these programs and efforts are 
helpful, on their own they are insufficient. Due to a 
multitude of factors outside of medical schools’ influ­
ence or control, including economic forces, the past



32

decade has only seen a slight increase in the percent­
ages of underrepresented minorities nationwide that 
apply to medical school. See AAMC, Race/Ethnicity 
of Applicants to U.S. Medical Schools, 2013-2014 and 
2014-2015 (2014) (www.aamc.org/download/321484/ 
data/factstablel3.pdf) (table 13). A recent study 
highlighted that among high school students 
expressing an interest in becoming a physician, those 
who change their minds are disproportionately from 
the groups least represented in medicine. See Emory 
Morrison & David A. Cort, An Analysis of the 
Medical School Pipeline: A High School Aspirant to 
Applicant and Enrollment View, 14 Analysis in Brief 
No. 3, at 2 (AAMC Mar. 2014).

Indeed, while many initiatives and programs 
supported by foundations, medical schools, and 
government have contributed to increasing diversity 
in the physician pipeline, the number of applicants 
from one major demographic group—black males— 
has not increased above the number from 1978, when 
Bakke was decided. That year, 1,410 black males 
applied to medical school, and in 2014, just 1,337 
applied. A similar trend is observed for first-time 
matriculants. In 1978, there were 542 black male 
matriculants to M.D.-granting institutions; in 2014, 
there were 515. See AAMC, Altering the Course: 
Black Males in Medicine, at 4 (2015) (www.aamc.org/ 
download/439660/data/20150803_alteringthecourse. 
pdf). This downward trend among black males 
occurred while the overall number of applicants and 
matriculants to medical schools increased, during 
that same period, from 36,626 and 16,054, 
respectively, to 49,480 and 20,343. See AAMC, 2015 
Data Book, at 17-18 (2015).

http://www.aamc.org/download/321484/
http://www.aamc.org/


33

It does not appear that the under-representation of 
minority medical students can be rectified by 
assessing applicants based on proxy criteria such as 
economic disadvantage. For example, simply 
focusing on statistical information that correlates 
with disadvantage—such as low socio-economic 
status—will in all likelihood reduce rather than 
increase the number of underrepresented minority- 
applicants accepted for admission. See Ann 
Steinecke et al., Race-Neutral Admission 
Approaches: Challenges and Opportunities for
Medical Schools, 82 Acad. Med. 117, 123 (2007); 
William G. Bowen & Derek Bok, The Shape of the 
River 270-71 (1998). And any prohibition on the 
consideration of race in student admissions will 
result in a student body with significantly fewer 
underrepresented minority students. See Liliana M. 
Garces & David Mickey-Pabello, Racial Diversity in 
the Medical Profession: The Impact of Affirmative 
Action Bans on Underrepresented Student of Color 
Matriculation in Medical Schools, 86 J. of Higher Ed. 
264, 287 (2015) (finding that affirmative action bans 
in six states resulted in a 17% decline in first-time 
matriculation of medical school students who are 
underrepresented students of color).

Medical educators continue to find that a deliberate 
focus on fostering diversity in medical education is 
essential if medical schools are to fulfill their 
responsibility to effectively serve all of society. It is 
hoped that such actions will no longer be necessary 
in the future, but that future has not yet arrived.



34

III. PRECLUDING OR LIMITING HOLISTIC 
REVIEW WOULD DISRUPT ADMISSIONS 
PRACTICES CRAFTED IN RELIANCE 
UPON THE COURT’S PRECEDENTS.

For more than thirty-five years, the Nation’s 
medical schools have utilized the kind of holistic 
admissions process approved by the Court’s holdings 
in Bakke and Grutter. In the schools’ expert judg­
ments, such practices are necessary to train physi­
cians and other leaders in the health professions who 
can effectively serve an increasingly diverse society. 
Health professional educators have faithfully abided 
by the Court’s guidance, including in Fisher I. See, 
e.g., Coleman et al., supra (2014 revisions to AAMC 
Roadmap guidance document). Amici urge the Court 
not to disrupt that reliance by withdrawing its 
imprimatur from those longstanding practices.

In no event should the Court accept the arguments 
of some of petitioners’ amici—but not petitioner 
herself—that Grutter should be overruled. The 
Court’s commitment to stare decisis “promotes the 
evenhanded, predictable, and consistent develop­
ment of legal principles, fosters reliance on judicial 
decisions, and contributes to the actual and 
perceived integrity of the judicial process.” Payne v. 
Tennessee, 501 U.S. 808, 827 (1991). “Indeed, the 
very concept of the rule of law underlying our own 
Constitution requires such continuity over time that 
a respect for precedent is, by definition, 
indispensable.” Planned Parenthood of SE Pa. v. 
Casey, 505 U.S. 833, 854 (1992) (citing Lewis F. 
Powell, Jr., Stare Decisis and Judicial Restraint, 
1991 J. Sup. Ct. Hist. 13, 16 (1991)).

Stare decisis should be respected here. Far from 
“defying practical workability,” id. at 854, the holistic



35

admissions process approved in Grutter and Bakke 
continues to be the predominant mode of decision 
making employed by universities and graduate 
schools across the Nation. Those schools, moreover, 
have expressly relied on this Court’s precedents in 
doing so. As the Court remarked in Grutter, “ [pjublic 
and private universities across the Nation have 
modeled their own admissions programs on Justice 
Powell’s views.” 539 U.S. at 323. That reliance has 
only grown in the more than twelve years since the 
full Court endorsed Justice Powell’s reasoning. See 
supra at 27-28. And there are no new facts that 
“have robbed [Grader’s] rule of significant 
application or justification.” Casey, 505 U.S. at 855. 
Quite the opposite, the need for educators to value 
diversity in education has only increased as our 
Nation has become more diverse.

For her part, petitioner insists on a narrow concept 
of diversity. She contends that respondent’s “Top 
10%” law achieves sufficient levels of diversity— 
measured solely by demographic statistics—such 
that the holistic review approved in Grutter could 
never be justified for any of respondent’s admissions 
decisions. To the extent petitioner is arguing that 
holistic review should be jettisoned in favor of a 
process that focuses exclusively on class rank, 
grades, and test scores, that argument should be 
rejected. Indeed, as noted above, reliance on a 
mechanical process like a Top 10% plan is not 
workable for medical schools, and medical educators 
have always relied on far more than grades and test 
scores to achieve their goal of training the next 
generation of physicians and other health care 
professionals. See supra at 24-27.



36

Unlike most undergraduate institutions, medical 
and other health professional schools have always 
considered and highly value personal interviews in 
order to learn what the applicant’s background 
would contribute to a culturally competent 
workforce. Removing the ability of medical schools 
to consider applicants’ race and ethnicity as one of 
many personal attributes would undermine their 
ability to assess the entirety of each individual’s 
background, thus frustrating the goal of best serving 
the public’s health. At a time when our Nation is 
becoming more diverse, and health disparities 
remain so stark, constraining a medical school’s 
ability to consider a student’s entire background 
would negatively impact not only the classroom, but 
also patients, who would be deprived of a pipeline of 
physicians better equipped through personal exper­
ience and a diverse learning environment to 
understand and serve patients from all walks of life.

It is difficult, if not impossible, to insulate 
consideration of an applicant’s race or ethnicity from 
consideration of the rest of that individual’s 
background. Where an admissions process includes 
reliance on personal statements, for example, 
ignoring race and ethnicity “might not even be 
possible,” since “to read the file in a ‘colorblind’ way, 
the admissions officer would likely have to ignore 
highly relevant information, without which the 
applicant’s personal statement might literally not 
make sense.” Devon W. Carbado & Cheryl I. Harris, 
The New Racial Preferences, 96 Cal. L. Rev. 1139, 
1146-47, 1149 (2008). Similarly, requiring
applicants to exclude any references to their race or 
ethnicity “create [s] an incentive for applicants to 
suppress their racial identity and to adopt the



37

position that race does not matter in their lives,” 
which “is likely to be particularly costly to applicants 
for whom race is a central part of their social 
experience and sense of identity,” Id. at 1148.

Holistic review in medical school admissions is not 
a static concept. Rather, continuously “ [evaluating 
the effectiveness of admission policies, processes, and 
criteria in producing outcomes that reflect a medical 
school’s mission is a core element of holistic review.” 
Addams et al., supra, at 21. In furtherance of that 
principle, medical schools constantly re-evaluate 
their admissions processes to align them with the 
fundamental objectives of producing physicians of 
the highest caliber who can meet the health needs of 
the entire population. Given the persistence of 
health disparities among minority communities and 
the unconscious bias that contributes to that 
problem, amici strongly believe that it remains 
necessary in 2015 for institutions to continue to take 
action to ensure diversity in the admissions process. 
Our judgment about necessity reflects careful 
consideration of the responsibility our educational 
institutions have in preparing a healthcare 
workforce to meet the health needs of a diverse 
population, and is anything but “routine.” Pet. Br. at 
48. Amici believe that it would be a grave mistake 
for this Court to upset decades of precedent by 
precluding or significantly reducing the ability of 
expert medical educators to ensure that the next 
generation of physicians and other health 
professionals is educated and trained in an 
environment that will prepare them to address the 
Nation’s critical health needs.



38

CONCLUSION
For the foregoing reasons, and those in respondents’ 

brief, the judgment below should be affirmed.
Respectfully submitted,

Frank R. Trinity Jonathan S. Franklin*
HEATHER J. ALARCON Counsel of Record 
Association of Robert Burgoyne

American Medical John W. Akin
Colleges Norton Rose Fulbright US LLP

655 K Street, N.W. 799 9th Street, N.W., Suite 1000 
Washington, D.C. 20001 Washington, D.C. 20001
(202) 828-0540 (202) 662-0466

jonathan.franklin@
nortonrosefulbright.com

Counsel for Amici Curiae



ADDENDUM



l a

AMICI CURIAE
Association of American Medical Colleges—

represents all 145 accredited U.S. medical schools, 
nearly 400 teaching hospitals and health systems, 
and 90 academic and scientific societies.

American Academy of Family Physicians—
represents 120,900 family physicians and medical 
students from all 50 states, the District of Columbia, 
Guam, Puerto Rico, the Virgin Islands, and the 
Uniformed Services of the United States.

American Academy of Pediatrics—represents
64,000 primary care pediatricians, pediatric medical 
sub specialists, and surgical specialists who are 
committed to the attainment of optimal physical, 
mental, and social health and well-being for all 
infants, children, adolescents, and young adults.

American Academy of Physician Assistants—
represents approximately 104,000 certified physician 
assistants in the United States and provides 
advocacy and educational benefits on behalf of the 
profession and the patients served by physician 
assistants.

American Association of Colleges of
Nursing—represents 768 institutions offering 
baccalaureate and graduate programs in nursing.

American Association of Colleges of
Osteopathic Medicine—represents the 31
accredited colleges of osteopathic medicine in the 
United States, which deliver instruction at 44 
teaching locations in 29 states.

American Association of Colleges of
Pharmacy—represents pharmacy education in the 
United States, advancing pharmacy education,



2a

American College of Obstetricians and 
Gynecologists—represents more than 57,000 
physicians who specialize in the health care of 
women.

American College of Physicians—represents
143,000 internal medicine physicians (internists), 
related subspecialists, and medical students.

American Dental Association—represents the 
interests of its 157,000 members, advocates for the 
public’s oral health, and promotes the dental health 
profession in all 50 states, the District of Columbia, 
and Puerto Rico.

American Dental Education Association—
represents all 66 U.S. dental schools and 10 
Canadian dental schools.

American Medical Association—the largest 
professional association of physicians, residents, and 
medical students in the United States.

American Medical Student Association—
represents the concerns of more than 40,000 
physicians-in-training in the United States.

American Nurses Association—represents the 
interests of 3.4 million registered nurses, has more 
than 179,000 members through both state 
associations and individual membership, and has 35 
national organizational affiliates that collectively 
represent approximately 420,000 registered nurses 
in specialty areas.

American Osteopathic Association—represents 
more than 122,000 osteopathic physicians (“DOs”) 
and osteopathic medical students, promotes public

research, scholarship, practice, and service to
improve societal health.



3a

health, encourages scientific research, serves as the 
primary certifying body for DOs and the accrediting 
agency for osteopathic medical schools, and has 
federal authority to accredit hospitals and other 
health care facilities.

American Psychiatric Association—represents 
more than 36,000 physicians specializing in 
psychiatry who are engaged in treatment, research, 
and the education of physicians.

American Public Health Association—
champions the health of all people and all 
communities, strengthens the profession of public 
health, shares the latest research and information, 
promotes best practices, and advocates for public 
health issues and policies grounded in research.

Associated Medical Schools of New York—
represents the 16 medical schools in New York State.

Association of Academic Health Centers—a
non-profit association dedicated to advancing the 
Nation’s health and well-being through the vigorous 
leadership of academic health centers.

Association of American Indian Physicians—
committed to pursue excellence in Native American 
health care by promoting education in medical 
disciplines and honoring traditional cultural 
principles, and by offering educational programs, 
services, and activities to motivate American 
Indian/Alaska Native students to pursue careers in 
health professions and/or biomedical research.

Association of American Veterinary Medical 
Colleges—represents all 30 accredited colleges and 
schools of veterinary medicine in the U.S.



4a

Association of Schools of Allied Health 
Professions—a national association comprised of 
115 not-for-profit universities focused on issues 
impacting allied health education.

Association of Schools and Programs of 
Public Health—represents more than 100 schools 
and programs accredited by the Council on 
Education for Public Health.

Association of University Programs in Health 
Administration—a global network of colleges, 
universities, faculty, individuals, and organizations 
dedicated to the improvement of health and 
healthcare delivery through excellence in healthcare 
management and policy education and scholarship.

National Association of Hispanic-Serving 
Health Professions Schools, Inc.—represents 43 
schools of medicine, public health, nursing, 
pharmacy, and dentistry that strive to strengthen 
the Nation’s capacity to increase the Hispanic health 
workforce and advance the health of Hispanics.

National Hispanic Health Foundation—a
501(c)(3) non-profit philanthropic arm of the 
National Hispanic Medical Association with the 
mission to provide education and research activities 
to improve the health of Hispanics.

National Hispanic Medical Association—
represents the interests and concerns of 50,000 
licensed physicians committed to the mission to 
improve the health of Hispanic populations with 
affiliated Hispanic medical societies, resident and 
medical student organizations, and other public and 
private partners.



5a

National Medical Association—represents and 
promotes the interests of physicians and patients of 
African descent.

National Medical Fellowships, Inc.—provides 
scholarships for underrepresented minorities in 
medicine and the health professions.

Physician Assistant Education Association—
represents over 200 physician assistant programs 
across the Nation.

Society of General Internal Medicine—
represents more than 3,600 of the world’s leading 
academic general internists, who are dedicated to 
improving access to care for vulnerable populations, 
eliminating health care disparities, and enhancing 
medical education.

Student National Medical Association—
represents more than 6,000 medical students, 
premedical students, residents, and physicians 
committed to supporting current and future 
underrepresented minority medical students, 
addressing the needs of underserved communities, 
and increasing the number of clinically excellent, 
culturally competent, and socially conscious 
physicians.

The ASPIRA Association, Inc.—promotes the 
education and leadership development of Puerto 
Rican and other Latino youth, and works with over
50,000 youth and their families each year.

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