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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 noncompliance with accreditation standards. These changes are consistent with 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 noncompliant 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 The 3-year time period includes probationary time, as probation is typically the first step before accreditation is withdrawn and the maximum time allowed under CAA’s probation policy is 2 years with extenuating circumstances.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 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 firstname.lastname@example.org.
What is the process for advising CAA of a decision to close a program?
When closure of an accredited or candidate program has been decided, programs must notify the CAA in writing as soon as possible but no later than 30 days after the final decision to close. This includes any component of the program, such as a distance education track or satellite/branch campus. This notification should be a standalone letter sent to the CAA formally acknowledging this change and should not be embedded in any report to the CAA.
The notification must include the following:
- specific circumstances and details of the pending closure, including closure date, and copies of the official decision or notification to close the program or any of its components
- a transition plan and timeline to ensure completion of the program by all current students that will ensure sufficient leadership, faculty, and other resources to provide the curriculum, practicum experiences, support services, and advising needed to fulfill the program’s mission, meet its obligations to students, and maintain all appropriate student records consistent with institutional policy
- evidence that all current and prospective students have been informed of the program closure, with a plan for assisting them in completing the program of study
After reviewing the program’s transition plan, the CAA will acknowledge the program’s closure and modify the program’s accreditation cycle to reflect the anticipated closure date. Programs will be expected to continue to file reports to the CAA to ensure adherence to the program’s transition plan and continued compliance with the CAA’s Standards for Accreditation.
For complete information on program closure, see the Accreditation Handbook (Chapter XI Expectations of Programs) or contact a member of the Accreditation team (email@example.com).
What are CAA’s expectations of programs that use the Praxis tests as a summative assessment?
The Educational Testing Service (ETS) developed the Praxis tests to assess an individual’s knowledge, skills, and readiness to enter independent practice in their respective profession. According to ETS,
[the] Praxis® Series™ test scores have not been validated for use in granting or denying graduation status, and, therefore, may not be considered legally defensible when used in this manner.
The Praxis has not been validated for use as a program summative assessment.
Under CAA Standard 5.6, programs must report to the CAA the percentage of test takers who pass the Praxis Audiology or Praxis Speech-Language Pathology and demonstrate that they meet or exceed the CAA’s established threshold, which is 80%. This is a separate standard, distinctly set apart from CAA Standard 5.2, which speaks to the use of formative and summative assessment WHILE your students are in your program. Under CAA Standard 5.2, programs must conduct ongoing and systematic formative and summative assessments of their students’ performance. Specifically:
- The program must develop an assessment plan used throughout the program for each student. The plan must include the purpose of the assessments and must use a variety of assessment techniques, including both formative and summative methods.
- Assessments must be administered by multiple academic and clinical faculty members.
Yet, the CAA realizes that some programs are choosing to utilize the Praxis test as one form of summative assessment in their program; some are stipulating that sitting for or passing the examination is a graduation requirement. The CAA has cited programs for using the Praxis as their only form of summative assessment. The council would ask programs to address the following questions:
- How has the program ensured that appropriate validation of the Praxis test has been completed for the test to be used as a program summative assessment?
- How does the program ensure that this summative assessment is administered by a range of program faculty and supervisors to evaluate students’ progress—and is applied consistently—when the Praxis is administered by ETS?
In both cases, we believe that programs would find it difficult to respond. To this end, we advise programs to develop an assessment plan that they use throughout the program of study for each student. The CAA requires programs to develop a plan that must include (a) the purpose of the chosen assessments and (b) the use of a variety of assessment techniques, including both formative and summative methods. As noted earlier, program assessments must be administered by multiple academic and clinical faculty members of the program.
We hope that this guidance assists programs in addressing and meeting these specific standards. As always, please direct your questions and comments to firstname.lastname@example.org.
Please welcome Jennifer Phelan as the new Manager, Accreditation Program Effectiveness. She’s been at ASHA for the past 5 years as a Manager in Continuing Education Account Services. Prior to her arrival at ASHA, Jen worked as an Assistant Practice Manager and Billing Manager at Orthopedic Solutions. She has a knowledge base and a skill set that make her a great fit for this position, especially her experience in process improvement, project management, team building, report and document preparation, database management, data analytics, and records management. Jen will start full-time in Accreditation on August 31, 2020.
Jen will serve as the primary contact for any issues regarding technical support, accreditation technologies, Sharepoint access and CAA program invoicing.
Please join us in giving her a warm welcome. We think she’ll be a great addition to the Accreditation Team!
What are the CAA’s expectations for documenting compliance with a standard?
When CAA members assess a program’s compliance with accreditation standards, they closely follow the Requirements for Review listed under each standard. If policies or procedures are required, the program should expect to provide a copy to the CAA. However, having a new policy or procedure on its own may not be sufficient. The CAA would expect to see evidence of implementation, dissemination, communication, and other appropriate documentation.
Here are a few examples to demonstrate how the CAA sets expectations for documenting compliance.
The CAA cites a program for having an outdated strategic plan (Standard 1.5). The program has indicated that the new provost is spearheading a university-wide review of strategic goals and that updates at the department and program level are pending. Although the program shares a draft of the program’s strategic plan, this is not sufficient to be in compliance with this standard. The Requirements for Review for Standard 1.5 provide guidance about making sure the program’s long-term goals are on par with those of the institution, are measurable, are evaluated periodically, and are disseminated to appropriate stakeholders.
A program was cited under Standard 3.1 for curricular deficiencies. The program advises the CAA that a new course to address limitations in its curriculum has been proposed. Proposing a course to address the identified issue is not sufficient to document compliance. The CAA is likely to ask further questions and for more documentation to ensure the proposed course becomes integrated into the curriculum as expected:
- Is the new course approved and faculty assigned?
- When will the new course be integrated into the curriculum?
- What is the program’s plan to address the deficiency until the course is officially offered?
- How are students being notified of the new course and whether it is an elective or required?
- How has the program updated its tracking forms and mechanisms to reflect the new course, related knowledge, and skill areas?
- And so forth…
In both scenarios, the program has responded with appropriate plans to address CAA’s citation with a simple, straightforward solution. However, if the solution is not implemented, this may not be sufficient to meet CAA’s expectations as outlined in the Standards for Accreditation [PDF]. It also is important to keep in mind, highlighted in the second example, how one change can have a ripple effect onto other standards.
How does the CAA use nondiscrimination statements to verify compliance with standards?
Through Standard 1.8, the CAA expects programs to address policies and procedures that they use to ensure equitable treatment for all students, faculty, staff, and persons served in the program’s clinics. Although several protected classes are listed in the standard, the program and institution do NOT need to use the exact wording as stipulated in CAA’s standard for its nondiscrimination statement. The CAA determined that not every protected class has to be included in the statement—as long as the program can demonstrate that it does not discriminate against any of the listed categories, as applicable.
The focus of the standard is not simply that a statement is in place but that (1) all constituents are treated equitably and (2) the institution and program are complying with all applicable laws, regulations, and executive orders. The program must carry out these intents (see Items 1 and 2 above) in related procedures and protocols. The program must be able to document how it communicates expectations, policies, and procedures or how it provides education for all concerned.
What is the difference between accreditation and certification?
Simply put, accreditation is about programs, and certification is about individuals.
The focus of accreditation, which is operated by the Council on Academic Accreditation in Audiology and Speech-Language Pathology (CAA), is to ensure the educational quality of academic programs. Through its Standards for Accreditation, its policies, and its procedures, the CAA evaluates and monitors graduate degree programs in the United States that prepare entry-level practitioners in the professions of audiology and in speech-language pathology. The CAA publishes the list of graduate education programs that meet CAA’s Standards for Accreditation, including accredited and candidate (pre-accredited) degree programs to help inform and protect students and the public.
The focus of certification, operated by the Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC), is to promote excellence in the practice of the professions of audiology and speech-language pathology. It accomplishes this through developing and implementing standards, awarding the Certificate of Clinical Competence (CCC) to individuals who meet those standards, and protecting and informing the public by recognizing individuals who meet the certification standards. The CCC designation demonstrates clinical skills and knowledge for independent practice as a speech-language pathologist (CCC-SLP) or as an audiologist (CCC-A) in all primary employment settings, including schools, hospitals, clinics, and private practice. The certification program is developed for practitioners throughout the United States.
At times, people get confused between (a) what the CAA expects in its standards and (b) what is expected of CAA program graduates who choose to seek certification (i.e., CCC-A, CCC-SLP). Although the CAA and CFCC use some of the same foundational documents to develop curricular expectations as well as knowledge and skills (e.g., Practice and Curriculum Analysis), the activities of these two councils are independent of one another.
The following chart provides an example of some standards requirements that are specific to either the CAA or specific to the CFCC. Academic program faculty and graduates who choose to apply for certification have a responsibility to understand the CAA and CFCC standards as well as additional state credentialing requirements. For further assistance, see the links below.
|Examples of Standards Content||CAA Accreditation1||CFCC Certification2|
|Includes curriculum (academic and clinical) requirements|
|Includes knowledge and skills expectations|
|Requires applicants to complete a statistics course|
|Requires applicants to complete prerequisite courses|
|Requires clinical educators/supervisors/preceptors to have CCC|
|Requires academic and clinical educators to have appropriate degree and qualifications|
|Requires direct supervision of at least 25% of the speech-language pathology student's total contact with each client/patient|
|Requires the program to track student progress in a format determined by the program|
Since 1994, graduation from a CAA-accredited or candidate program in the United States has been required of applicants for the CCC-A or CCC-SLP.
 Date of last major standards revision (accreditation): August 2017.
 Dates of last major standards revisions (certification): 2012 (audiology), 2014 (speech-language pathology), 2020 Pending (audiology, speech-language pathology).
How will CAA use the Guidance on Developing Quality Interprofessional Education for the Health Professions related to programs’ activities for IPE?
The Health Professions Accreditors Collaborative (HPAC) and the National Center for Interprofessional Practice and Education released Guidance on Developing Quality Interprofessional Education for the Health Professions [PDF] in February 2019. The guidance was developed through a multiyear, multiphase consensus process aimed at supporting the development and implementation of quality interprofessional education (IPE). The CAA is pleased to have been a part of the development of this resource for institutional leaders, programs and faculty, and accreditation agencies and volunteers.
The guidance document is intended to foster increased communication and collaboration between educators in various professions and to provide guidance on achieving quality IPE. The document
- offers consensus terminology and definitions for IPE and related concepts;
- encourages institutional leaders to develop a systematic approach to foster IPE in their own institutions and, where appropriate, collaborate with academic institutions, health systems, and community partners;
- suggests a framework for leaders and faculty to develop a plan for quality IPE; and
- provides opportunities for HPAC member accreditation boards/commissions to use the guidance to assess their IPE standards and to train site teams regarding the essential elements of high-quality IPE. 
The CAA views this document as a resource to support programs in their preparation of graduate students in audiology and in speech-language pathology as professionals, regardless of clinical externship or practice settings. It is not intended to replace or subsume CAA’s accreditation standards related to IPE, nor will site visitors be directed to consider programs’ IPE plans solely on the basis of recommendations from this document.
The CAA expects programs to be engaged in IPE ultimately to realize the success of their graduates in interprofessional collaborative practice (IPP). For a program, the advantage of using a multidisciplinary, collaborative guidance document as a basis for its own implementation and practice of IPE is that it can facilitate an organized and systematic approach that is consistent with the goals, objectives, and procedures used by other health professions in the training of their students. Such consistency of terminology, focus, process, and assessment across the health professions will help facilitate students’ use of IPP beyond their training and is, itself, a working example of IPP.
- Ask the CAA: Should our program include IPE/IPP in our academic and clinical curriculum?
- CAA Standards for Accreditation [PDF]—Standards 3.1 A, 3.4A, 3.1B
The Health Professions Accreditors Collaborative (HPAC) and the National Center for Interprofessional Practice and Education have released Guidance on Developing Quality Interprofessional Education for the Health Professions. The guidance was developed through a multiyear, multiphase consensus process aimed at supporting the development and implementation of quality interprofessional education (IPE). The goals of the guidance are to facilitate the preparation of health professional students for interprofessional collaborative practice through accreditor collaboration and to provide consensus guidance to enable institutions to develop, implement, and evaluate systematic IPE approaches and IPE plans.
The CAA is a member of HPAC, and contributed to the development of the guidance document and resources.