Enforcement of Standards 2021

What is the impact to programs from CAA’s updated procedures regarding enforcement of its standards?

The Council on Academic Accreditation in Audiology and Speech-Language Pathology (CAA) approved changes to its policy and procedures that set forth the expectations and timelines for a program to address any areas of non-compliance with accreditation standards. These changes are consistent with the U.S. Department of Education’s (USDE) regulations for recognized accrediting agencies, like the CAA, that went into effect on July 1, 2020—specifically §602.20 [34 CFR 602.20].

Under this USDE criterion, when a program is cited as being not in compliance with any standard, the CAA must provide that program with a written timeline to resolve the issues. Further, the CAA must take adverse action (e.g., withdraw accreditation) if the program does not bring itself into compliance within the specified period. The timeline must be reasonable, as determined by the CAA, based on the nature of the finding, the stated mission, and the program’s educational objectives. The CAA expects programs to address any areas cited as non-compliant and to document their resolution by the time of the next report. The CAA determined that 3 years will be the maximum amount of time allowed for a program, regardless of professional area, to be out of compliance with standards before taking an adverse action. The 3-year time period includes probationary time, as probation is typically the first step before accreditation is withdrawn and the maximum time allowed under CAA’s probation policy is 2 years with extenuating circumstances. This 3-year allowance is consistent with the formula provided in the revised USDE criterion.

When the updated procedures go into effect on January 1, 2021, the CAA will place a program on probation or withdraw its accreditation if the review of a second consecutive report reveals that issues continue for the same standard(s) and that the program remains not in full compliance with all standards. Although CAA has had policies and procedures in place for several years to ensure that programs comply with standards within a specific amount of time, the CAA allowed a program multiple years before acting to place it on probation or withdraw accreditation as a result of continued noncompliance.

See the examples below, which illustrate the updated procedures:

• The CAA cites Program A as being noncompliant with Standard 1.9 because the program does not include both the number and percentage of graduates for the last 3 years on its website, as specified in the standard for student outcome data. The CAA expects that the program will update its website within the year and document that the issue is resolved in its next report to the CAA. If the website is not updated by the time of that report, the CAA would place the program on probation, as it is the second consecutive report for which the program is cited for noncompliance with the same requirement. (In the past, the CAA would continue to monitor and cite the program on this issue when compliance was not evident until the third consecutive report revealed continued noncompliance before placing the program on probation.)
• The CAA cites Program B as being noncompliant with Standard 4.7 because the program is not consistently tracking all students’ progress toward their degree. The CAA expects that the program will resolve these issues and document that fact in its next annual report. The program submits its report, which states that although progress has been made, the program needs additional administrative or financial resources to fully implement a new system. Because the tracking issue was still not resolved by the time of that annual report, the CAA would then place the program on probation—with the reason being that the latest submission is the second consecutive report for which the CAA is citing the program for noncompliance with the same requirement.

If CAA places a program on probation, that probation period is for 1 year. The CAA expects that permitting a second year of probation only would be for programs experiencing extenuating circumstances. Further, the CAA has adopted procedures for considering good-cause extensions when a program is on probation. The CAA may use good-cause extensions to allow additional time for a program to come into compliance beyond the 3 years, provided that the program (a) demonstrates substantial progress in addressing areas of noncompliance and (b) provides the rationale and an achievable plan that reflects the program’s issues, readiness, and capacity or resources to remedy the issues by the end of any good-cause extension. These procedures are in accordance with the USDE recognition criteria for accrediting agencies.

Please note that the CAA may place a program on probation or withdraw accreditation from a program prior to the review of multiple consecutive reports with areas of noncompliance when there is clear evidence of circumstances that jeopardize the program’s capability to provide acceptable educational experiences for the students.

Beginning January 1, 2021, the CAA will implement the changes that it has approved for enforcing its standards. The CAA wanted to ensure that all programs were advised of the revisions to the CAA’s enforcement policy and procedures as they submit their next report for review. All decisions made by the CAA after that date will be subject to the revised procedures. More information is provided in Chapter XVII, Procedures for Achievement and Maintenance of an Accredited Status, of the Accreditation Handbook.

Please direct any questions and comments to accreditation@asha.org.