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Statement on Financial Responsibility, Administrative Capability, Certification Procedures, and Ability to Benefit (ATB)

July 26, 2024

On July 3, 2024, the following statement from the Council on Academic Accreditation in Audiology and Speech-Language Pathology (CAA) was sent to program directors of CAA-accredited and Candidate programs:

On October 31, 2023, the US Department of Education (also "the Department") published amended regulation language regarding Financial Responsibility, Administrative Capability, Certification Procedures, and Ability to Benefit (ATB) that went into effect on July 1, 2024. This regulation is related to the implementation of Title IV of the Higher Education Act of 1965. CAA-accredited programs fall under these requirements. However, since CAA accreditation is not a factor in federal financial aid participation, the CAA does not require any changes in reporting.

This ruling from the US Department of Education requires institutions to provide students with geographically accessible clinical or externship opportunities related to and required for the completion of the credential or licensure in a recognized occupation, within 45 days of the completion of other required coursework. The CAA does not anticipate that programs will have difficulty complying with this rule or continuing to comply with the Standards for Accreditation for Graduate Programs in Audiology and Speech-Language Pathology [PDF] due to this regulation. Several standards throughout Standard 3.0A/B (e.g., 3.1, 3.2, 3.3, 3.7, 3.8) require programs to perform functions that demonstrate that the proper policies and procedures are in place to ensure that the clinical experiences are appropriate, timely, and commensurate with students’ knowledge and skills.

The US Department of Education has not provided specific metrics or expansion of any definition of "geographic accessibility." The Department stated, "In terms of assessing geographic accessibility, the Department would consider how accessible distances look very different in rural areas versus urban ones. The level of the credential will also likely affect this consideration. Someone completing a professional degree in a highly specialized field is almost certainly going to have [to] travel longer distances for a clinical and so something quite far away would still be viewed as accessible and in line with their expectations...Preserving the concept of geographic accessibility while recognizing the need for flexibility in how that is considered based upon the credential level, type, and the physical location of the institution is appropriate." More information regarding the specific discussion related to this requirement may be viewed on pages 49–51 of the Department's [PDF].

The new language from the US Department of Education also requires institutions to demonstrate that they meet programmatic accreditation and licensure requirements in the state where their students are or intend to practice. As the CAA’s Standards for Accreditation do not vary by state, the CAA does not regulate the licensing process for any state or jurisdiction, and it has no requirements around the reporting of licensure disclosures. CAA-accredited programs are encouraged to (a) use the ASHA State-by-State resource for information about state licensing requirements and (b) consult with the licensure board or regulatory agency regarding the exact requirements in each jurisdiction.

Direct questions regarding this statement to Maia Williams, ASHA director of accreditation policy and education, at mawilliams@asha.org.


About ASHA

The American Speech-Language-Hearing Association (ASHA) is the national professional, scientific, and credentialing association for members and affiliates who are audiologists, speech-language pathologists, speech, language, and hearing scientists, audiology and speech-language pathology assistants, and students.

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About the CAA

The Council on Academic Accreditation in Audiology and Speech-Language Pathology (CAA) accredits eligible clinical doctoral programs in audiology and master's degree programs in speech-language pathology. The CAA relies on a dedicated corps of volunteers serving as Council members and site visitors to accomplish the work of the accreditation program.

Contact the CAA

Questions and/or requests for information about accreditation or the CAA can be directed to:

The Council on Academic Accreditation in
Audiology and Speech-Language Pathology

American Speech-Language-Hearing Association
2200 Research Boulevard, #310
Rockville, MD 20850

800-498-2071

Email the CAA