The U.S. Department of Education is moving forward with significant changes to the federal requirements for recognized accrediting agencies. This rulemaking, known as Accreditation, Innovation, and Modernization (AIM) [PDF] grew out of a 2025 executive order directing the Department of Education to review and revise federal accreditation requirements. A negotiating committee representing accreditors, institutions, and other stakeholders met earlier this year and reached consensus on draft regulatory text addressing a range of issues, including accreditation; conflict of interest requirements; outcome metrics; and viewpoint diversity.
Several of the proposed changes could directly affect the Council on Academic Accreditation in Audiology and Speech-Language Pathology’s (CAA's) relationship with the American Speech-Language-Hearing Association (ASHA) and the requirements for accrediting agencies to operate separately and independently from related organizations under the Higher Education Act (HEA).
Anyone who serves as an officer, director, or employee of an accredited program could be barred from voting on the policies and standards that apply to that program. CAA already has strict conflict-of-interest policies [PDF] that include addressing participation in decisions involving an individual’s own institution. The proposed requirements could affect how subject matter experts affiliated with accredited programs participate in broader accreditation activities, including the development and approval of accreditation standards.
Using federal earnings data or state wage records, accreditors would be required to evaluate programs on post-completion employment outcomes, continued education, and "economic returns" relative to the total cost of attendance. These requirements would represent a new area of review for a programmatic accreditor such as CAA. CAA does not currently collect the institution-level financial, enrollment, and earnings information contemplated by the proposed requirements. Accredited programs could therefore be required to gather, analyze, and report additional data to CAA.
The proposal would eliminate the long-standing "joint-use" exception that currently allows an accreditor to share staff, office space, and services with a related professional association if it pays fair market value. In its place, the proposed rule would prohibit shared personnel, facilities, technology, and office space between an accreditor and any related trade or membership organization. Budgets would have to be developed without review from the related trade or membership organization, and dues would have to be collected and held separately.
For CAA, this would mean substantially changing its current operational relationship with ASHA, including separate staff, separate office space, and a separate financial system, as well as changes to governance that could affect collaborative efforts between CAA and ASHA. A one-year grace period after the rule's effective date is included in the draft specifically for the physical office-space requirement.
CAA has historically been able to leverage ASHA’s infrastructure and administrative support to keep accreditation activities efficient and help offset costs that would otherwise have been passed on to academic programs. Requiring CAA to fundamentally alter its infrastructure and administrative functions would eliminate these efficiencies and could result in higher accreditation costs for academic programs, reduced resources available to support accreditation activities, and greater uncertainty during the organizational transition.
For the first time, all accreditors would be required to evaluate whether institutions maintain policies protecting academic freedom, First Amendment rights (at public institutions), integrity of research and scholarly activity, and "intellectual diversity," including measuring student and faculty perceptions of the range of viewpoints offered on campus. These new faculty and demographic provisions aim to address institution-wide policies and practices based on criteria that are difficult to define and evaluate in a reliable and consistent manner using credible and defensible data. In addition, these policies have historically been reviewed primarily by institutional accreditors, rather than programmatic accreditors such as CAA that focus on individual graduate programs and do not have jurisdiction over institutional policies. Some requirements may apply differently to public and private institutions.
If the Department of Education finalizes the rule by November 1, 2026, most requirements would take effect July 1, 2027, with the physical-separation requirement following about a year later. The proposed timeline would give accrediting agencies a relatively short period to make changes to staffing, governance, financial operations, physical location, and other processes needed to comply with the new requirements.
CAA's federal recognition, which has been continuous since 1967, has important implications for CAA-accredited programs and their students and graduates. This may include eligibility for federal grant funding, certain state licensure pathways, and some Medicaid and Veterans Affairs provider qualification standards.
If finalized as proposed, the new requirements would require significant changes to CAA’s operations, governance, and relationship with ASHA in order for CAA to continue meeting federal recognition requirements. New reporting requirements would add to the volume and complexity of data that programs must report to CAA on an annual basis.
CAA will continue to evaluate how the proposed requirements could affect accredited graduate education programs in audiology and speech-language pathology, including program operations, reporting responsibilities, and the accreditation process.
The Department of Education has published the Notice of Proposed Rulemaking (NPRM) in the Federal Register, opening a formal public comment period on the proposed accreditation changes. Comments are due by September 21, 2026.
CAA has reviewed the proposed rule and developed resources to help CAA-accredited programs and other higher education stakeholders understand the provisions that could affect CAA and programmatic accreditation in audiology and speech-language pathology. These resources include a policy analysis, an overview of issues programs may want to comment on, and step-by-step guidance for submitting comments through the federal rulemaking docket.
CAA encourages accredited programs to review these materials, consider submitting comments, and share the resources with faculty, students, institutional leaders, and other stakeholders who may wish to participate in the public comment process.
Individuals and organizations that wish to comment on the proposed rule can use these CAA resources to prepare and submit individualized comments:
For questions about CAA’s information regarding the proposed rule, contact accreditation@asha.org.