How to Submit an Effective Comment on the Proposed Federal Accreditation Regulations

The U.S. Department of Education is providing an opportunity for the public to comment on proposed changes to the federal requirements for recognized accrediting agencies through the Accreditation, Innovation, and Modernization (AIM) rulemaking.

Programs, faculty, institutional leaders, students, and other interested individuals accredited through the Council on Academic Accreditation in Audiology and Speech-Language Pathology (CAA) may submit comments directly to the Department. Comments can help the Department understand how proposed requirements could operate in practice, particularly for specialized programmatic accreditors and the academic programs they accredit.

Comments are due September 21, 2026.

Before You Begin

You do not need to address every provision of the proposed rule. Consider focusing on the provisions most relevant to your program, institution, role, or experience.

Before drafting your comment:

Review the Department’s proposed rule.
Review CAA’s overview of the proposed changes and their potential implications.
Review CAA’s resource identifying provisions and topics programs may wish to consider.
Determine whether you are commenting as an individual or on behalf of a program, department, college, university, or other organization.

If you plan to comment on behalf of your program or institution, follow any applicable institutional policies or approval procedures.

Step 1: Decide Who Is Submitting the Comment

Comments may be submitted by organizations or individuals. Depending on your institution and the issues you want to address, perspectives could come from:

an academic program
a department, college, or university
a program director or department chair
faculty members or clinical educators
students or student organizations
institutional accreditation or compliance staff
other individuals with relevant experience

More than one person or unit at an institution may submit a comment if each has a relevant perspective to share.

Step 2: Identify the Issues Most Relevant to You

A comment does not need to discuss the entire proposed rule. Consider identifying one, two, or three provisions where you can provide specific information about how the proposed requirement could affect your program or institution.

CAA has identified several areas that may be particularly relevant to programmatic accreditation in audiology and speech-language pathology, including:

conflict-of-interest requirements
requirements related to economic outcomes and data reporting
separation of accrediting agencies and related organizations
academic freedom and viewpoint-diversity requirements
proposed implementation timeline

Step 3: Explain Your Perspective

Begin by briefly explaining who you are and why you have experience relevant to the issue. Depending on your role, useful information could include:

your position or responsibilities
your relationship to an audiology or speech-language pathology graduate program
your experience with accreditation, program administration, clinical education, data reporting, or standards development
characteristics of your program or institution that are relevant to the issue you are discussing

Provide only the background needed to help the Department understand the perspective behind your comment.

Step 4: Describe the Potential Impact

Comments are most informative when they explain how a proposed requirement would work in practice. Rather than stating only that you support or oppose a provision, describe what the requirement could mean for your program, institution, students, or accreditation activities.

For example, consider explaining:

what new responsibilities the provision could create
whether your program currently collects the information that would be required
what staff, systems, institutional coordination, or financial resources could be needed
how a requirement could affect accreditation or institutional processes
whether a proposed requirement would create challenges that may not be apparent from the regulatory text
how the proposal could affect students or program operations

Use concrete examples when you can. Information based on your own experience can help the Department understand the practical effects of a proposed requirement.

Step 5: Identify the Provision You Are Addressing

When possible, connect your comments to the relevant provision of the proposed rule. You may identify the regulatory section—for example, § 602.14, § 602.15, or § 602.17—and briefly explain which requirement you are discussing. Referencing a specific provision makes it easier for the Department to understand and evaluate your comment.

You do not need to provide a detailed legal or regulatory analysis.

Step 6: Recommend an Approach

If you identify a concern or implementation challenge, explain what you believe the Department should consider doing differently. Depending on the issue, you might recommend that the Department:

clarify a requirement
narrow its scope
distinguish between institutional and programmatic accreditation
allow alternative ways to meet a requirement
modify an implementation deadline
establish a phased transition

Your recommendation should reflect the issue and experience described in your own comment.

Step 7: Review Your Comment

Before submitting, make sure your comment:

clearly identifies who is submitting it
focuses on the issues most relevant to your experience
explains practical effects rather than relying only on general statements of support or opposition
uses specific examples or information when available
identifies relevant regulatory provisions when possible
makes clear what you want the Department to consider
is written in your own words

Protect Private and Confidential Information

Comments and uploaded documents become publicly available. Before submitting:

Remove personal information you do not want posted publicly.
Do not include confidential or proprietary institutional information.
Do not include identifiable information about students, patients, or clients.
Confirm that you are authorized to identify an institution or organization as the commenter if you are submitting on its behalf.

Step 8: Submit Through the Official Federal Docket

Comments must be submitted through the official rulemaking docket.

To submit your comments, go to: Federal Register – Accreditation, Innovation, and Modernization: The Secretary's Recognition of Accrediting Agencies: Institutional Eligibility Under the Higher Education Act of 1965, as Amended, Student Assistance General Provisions

You may also search Regulations.gov for:
Docket ID: ED-2025-OPE-1042

Before submitting, confirm that the docket title refers to the Department of Education’s Accreditation, Innovation, and Modernization proposed rule.

Follow the instructions provided on Regulations.gov. Depending on the docket, you may be able to enter your comment directly or upload a document.

Do not use a general website feedback form to submit your regulatory comment. Your comment must be submitted through the official rulemaking docket to become part of the administrative record.

Step 9: Submit by the Deadline

Comments must be received by: September 21, 2026.

After submitting, retain any confirmation or tracking information provided by Regulations.gov.

Tips for an Effective Comment

Focus on what you know. You do not need to address every provision. Concentrate on issues where you have relevant experience or information.
Be specific. Explain what a requirement could mean for your program or institution and why.
Use examples. Program-level experiences can help illustrate consequences that may not be apparent from the regulatory language.
Connect your comment to the rule. Cite the applicable regulatory provision when possible.
Explain your reasoning. Describe why a particular requirement could help, create challenges, or need clarification.
Offer a recommendation. Tell the Department what change or approach you believe it should consider.
Use your own words. Comments that reflect an individual program’s, institution’s, or commenter’s experience provide the Department with distinct information to consider.

Additional Resources

Questions

For questions about CAA’s information regarding the proposed rule, contact accreditation@asha.org.