The U.S. Department of Education’s (also "the Department") proposed Accreditation, Innovation, and Modernization (AIM) regulations include several provisions that could affect the Council on Academic Accreditation in Audiology and Speech-Language Pathology (CAA), CAA-accredited programs, and their institutions.
CAA-accredited programs and other stakeholders may wish to provide the Department with information about how these proposed requirements could operate in practice.
This resource identifies provisions that may be particularly relevant to programmatic accreditation in audiology and speech-language pathology and provides questions to consider when developing a comment.
You do not need to address every issue. Consider commenting on the provisions where you or your institution have relevant experience, examples, or information to share. Review the Department's summary of changes and rationale to address your concerns fully.
See also:
New Conflict of Interest Requirements
What the Proposal Would Do
The proposed regulations would establish additional conflict of interest requirements affecting individuals affiliated with institutions or programs accredited by an agency. These provisions could affect the ability of faculty members, administrators, clinical educators, and other individuals affiliated with accredited programs to participate in accreditation standard-setting or policy decisions.
CAA already maintains conflict of interest requirements [PDF] governing participation in accreditation activities and decisions involving an individual’s own institution.
Topics Your Program May Wish to Address
When developing your comment, consider addressing:
- The expertise needed for accreditation. Who is best qualified to develop and evaluate standards for graduate education in audiology and speech-language pathology, and how important is current academic or clinical experience?
- Where that expertise is found. Consider whether it would be practical to identify qualified experts who have no affiliation with any CAA-accredited program.
- The role of faculty and other professionals. How could restrictions on participation by faculty, clinicians, administrators, and other subject-matter experts affect the development and review of accreditation standards?
- Managing conflicts of interest. How are conflicts involving an individual’s own institution currently addressed, and what safeguards are appropriate for those situations?
- Accreditation decisions vs. standard setting. Should a distinction be made between participating in an accreditation decision involving an individual’s own institution and participating more broadly in developing standards or accreditation policy?
Potentially relevant provisions: §602.3 What definitions apply to this part and §602.15 Administrative and fiscal responsibilities
New Requirements Related to Economic Outcomes
What the Proposal Would Do
The proposed regulations would require accrediting agencies to evaluate measures related to post-completion employment, continued education, and economic returns relative to the cost of attendance. Some of the information contemplated by these requirements may be maintained at the institutional level rather than by an individual academic program or programmatic accreditor. If finalized, these provisions could require CAA-accredited programs to collect, analyze, coordinate, or report additional information.
Topics Your Program May Wish to Address
When developing your comment, consider addressing:
- Data currently available to your program. What student, graduate, financial, employment, or earnings data does your program currently collect or report, and what information is maintained elsewhere within your institution?
- Access to and verification of additional data. Would your program have direct access to the information required under the proposal? Consider which institutional offices would need to provide or verify the data.
- New reporting responsibilities. What additional staff time, technology, institutional coordination, or other resources would be needed to collect, analyze, verify, and report the required information?
- Factors affecting economic outcomes. How might geography, employment setting, public-service employment, clinical specialty, or other factors influence graduate earnings or employment outcomes independent of program quality?
- Usefulness in evaluating program quality. How well would the proposed economic measures reflect the quality and effectiveness of graduate education in audiology or speech-language pathology, and are there other outcome measures that would provide more meaningful information?
Potentially relevant provisions: §602.16 Accreditation and pre-accreditation standards, §602.17 Application of standards in reaching accreditation decisions, and § 602.20 Enforcement of standards
Separation of Accrediting Agencies and Related Organizations
What the Proposal Would Do
The proposed regulations would eliminate the existing joint-use exception and establish new restrictions on sharing personnel, facilities, technology, office space, financial resources, and other operations between an accrediting agency and a related trade or membership organization. CAA currently operates as an accrediting entity while receiving certain administrative and operational support through its relationship with ASHA, as outlined in its Memorandum of Agreement and its Semi-Autonomous Entities Agreement.
If finalized as proposed, the new requirements could require substantial changes to CAA’s staffing, financial operations, technology, governance, physical facilities, and other administrative functions.
Topics Your Program May Wish to Address
When developing your comment, consider addressing:
- Costs to academic programs. How could higher accreditation fees or other costs resulting from separate staffing, technology, financial systems, facilities, and administrative functions affect your program’s budget, institutional resources, or students?
- Efficient use of accreditation resources. How has CAA’s ability to leverage shared infrastructure and administrative support benefited accredited programs? What is the potential impact if more resources must be directed toward duplicating administrative functions rather than accreditation activities?
- Continuity during organizational transition. How could significant changes to CAA’s operations and infrastructure affect your program, particularly during a transition to new systems, staffing, or processes?
- Independence and shared administrative support. Can an accreditor use shared infrastructure and administrative services while maintaining independent accreditation standards and decision-making? What safeguards are important for maintaining that independence?
- Alternative approaches. Are there approaches other than complete operational separation that could preserve independent accreditation decision-making while maintaining efficiencies and limiting additional costs for accredited programs
Potentially relevant provisions: §602.14 Purpose and organization and §602.15 Administrative and fiscal responsibilities
Academic Freedom and Viewpoint-Diversity Requirements
What the Proposal Would Do
The proposed regulations would require accrediting agencies to evaluate institutional policies and practices related to academic freedom, First Amendment protections at public institutions, research and scholarly integrity, and intellectual or viewpoint diversity. These requirements address institution-wide policies and practices that have historically been reviewed primarily through institutional accreditation.
CAA, as a programmatic accreditor, evaluates individual graduate programs in audiology and speech-language pathology rather than the institution as a whole.
Topics Your Program May Wish to Address
When developing your comment, consider addressing:
- Institutional vs. programmatic accreditation. Which accreditor is best positioned to evaluate institution-wide policies related to academic freedom, First Amendment protections, research integrity, and viewpoint diversity?
- Program authority and access. Does your program have the authority or access to information needed to evaluate these institution-wide policies and practices?
- Potential duplication. Could requiring programmatic accreditors to conduct these reviews duplicate responsibilities already addressed through institutional accreditation or other university processes?
- Practical implementation. What challenges could arise from evaluating institution-wide requirements through the accreditation of an individual audiology or speech-language pathology program, including differences between public and private institutions?
Potentially relevant provisions: §602.17 Application of standards in reaching accreditation decisions and §602.18 Ensuring consistency in decision-making
Proposed Implementation Timeline
What the Proposal Would Do
If finalized on the timetable currently proposed, many of the new requirements could take effect within a relatively short period after publication of the final rule. Requirements involving physical separation could have a somewhat longer implementation period.
CAA could be required to make substantial operational changes while continuing its regular accreditation activities, including program reviews, accreditation decisions, standards administration, and maintenance of federal recognition.
CAA-accredited programs could also need time to develop processes for any new reporting or compliance requirements.
Topics Your Program May Wish to Address
When developing your comment, consider addressing:
- Continuity of accreditation. How could a compressed implementation timeline affect CAA’s ability to maintain accreditation activities while making significant operational and regulatory changes?
- Impact on program planning. How could changes or uncertainty during the transition affect accreditation reviews, budgeting, enrollment, recruitment, or other program and institutional planning?
- Time needed to implement new requirements. What staffing, technology, reporting, budgeting, or institutional approval processes would your program need to put in place, and how much time would those changes reasonably require?
- Phased implementation. Would a longer or phased transition help CAA and accredited programs implement the new requirements while maintaining continuity in accreditation?
Potentially relevant provisions: §602.14 Purpose and organization and §602.15 Administrative and fiscal responsibilities
Continuity of Accreditation and Federal Recognition
CAA has been continuously recognized by the Department since 1967. Federal recognition has important implications for CAA-accredited programs and their students and graduates, including in areas such as federal student aid, certain state licensure pathways, and some provider qualification requirements.
If your program has experience relevant to these areas, you may wish to explain the practical importance of continuity in accreditation and federal recognition.
Topics Your Program May Wish to Address
When developing your comment, consider addressing:
- Importance of accreditation continuity. How does CAA accreditation affect your program, institution, students, and graduates?
- Impact on students and graduates. How could uncertainty or a disruption in CAA’s federal recognition affect current or prospective students, particularly those approaching graduation or pursuing professional requirements?
- Program and institutional impacts. How could uncertainty about accreditation status affect recruitment, enrollment, advising, financial aid, or other institutional processes?
- Transition protections. What safeguards or transition provisions would help protect accredited programs and students while CAA implements new federal requirements?
Potentially relevant provisions: §602.14 Purpose and organization and §602.16 Accreditation and pre-accreditation standards
Developing Your Comment
Your comment can focus on one issue or several. The strongest contribution your program can make is information the Department would not otherwise have about how a proposed requirement would work in an actual academic program or institution.
As you draft, consider this basic approach:
- Identify the provision. Explain which proposed requirement you are addressing.
- Explain your experience. Describe your program, responsibilities, or other relevant context.
- Describe the practical effect. Explain what the proposed requirement could mean in your setting.
- Provide specific information. Include examples, data, processes, timelines, or other details that help illustrate the impact when available.
- Suggest an approach. Explain what clarification, modification, alternative, or implementation approach you believe the Department should consider.
Comments should reflect the commenter’s own experience and perspective. CAA is not providing a template comment letter because individualized comments can provide the Department with more useful information about how the proposal could affect different programs and institutions.
See also: How to Submit an Effective Comment on the Proposed Federal Accreditation Regulations
Additional Resources
Questions
For questions about CAA’s information regarding the proposed rule, contact accreditation@asha.org.