An open letter to the CAA
I posted on April 25, 2025, about how the Council on Academic Accreditation, associated with the American Speech-Language-Hearing Association, seemed to be questioning its commitment to the areas this website addresses: culture, identity, languages, equity, inclusion, diversity, and related topics. On June 11, 2025, the CAA posted proposed revisions to Standards 3.4A (for audiology) and 3.4B (for speech-language pathology) and invited public comment.
I emailed the following comment to them on July 6, 2025.
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To the members of the Council on Academic Accreditation:
Thank you for seeking widespread peer comment about the proposed changes to Standards 3.4A and 3.4B. My expertise is in speech-language pathology, so my comments focus on 3.4B, but I believe that most of my concerns also apply to 3.4A.
The online feedback form asked two questions, beginning with "Do the proposed revisions capture the CAA's intent of the standard, which is to ensure that programs provide academic and clinical opportunities for students [to] learn to provide individualized person- and family-centered care to any client who comes into their clinical space?"
This question includes an inaccurate restatement of the 2017/2023 Standards. Standard 3.4B (as currently in place) does not exist to quietly mumble something vague about person-centered care. Standard 3.4B exists to name culture, language, identity, diversity, equity, inclusion, and the social determinants of health. That’s why it exists. The "intent" of the current Standard 3.4B was obviously to bring culture, language, identity, diversity, equity, inclusion, the social determinants of health, and all the related issues specifically and explicitly into the conversation and into the education of future speech-language pathologists. These issues, by name, must be part of our conversations, our practice, and our educational programs. How can we possibly even begin to talk about providing person-centered care, or begin to educate future speech-language pathologists about person- and family-centered care, if we are not explicitly at least trying to understand the many layers of complexities — which start with understanding everything we need to know to be able to understand ourselves and then to be able to ask people who they are, what languages they use, what matters to them, what they have experienced in their lives, and how all of that affects their communication abilities and needs? The parts of Standard 3.4B that the proposed revisions strike are the very details that make Standard 3.4B matter at all as an educational standard. The revised version is toothless, contentless, and meaningless -- or, worse, the revised version has utterly abandoned the core content and therefore the important meaning that the current standard expresses and requires.
We then move on to the second question: "Does the revised language appear to allow graduate education programs to provide academic and clinical opportunities to students to allow them to demonstrate an understanding of ethical practice while also adhering to applicable state laws?" (emphasis added).
Well, no, it does not, because the revised language contradicts our profession's ethical documents.
And also, aha, here is the heart of the matter, in the mention of "applicable state laws." The CAA is attempting to obey in advance. The standard is being rewritten because of some political issues that "may put programs and students at risk" or because "some institutions" are requiring changes to "course titles and content." As disruptive as our federal and some state governments have recently been, none of what has actually happened requires this wholesale change in our accreditation standards.
My primary comment here, therefore, is that this is our chance as a profession to stand for anything that matters. Do we or do we not believe ASHA's motto that effective communication is a fundamental right, and that our role is to ensure that all people have access to it? If we do, we must, as the current standards do, expect and require students and programs to understand all the details about what it means for all people to have access to communication.
Do we or do we not, as I thought our Scope of Practice required us to,
"Engage decision makers at the local, state, and national levels for improved administrative and governmental policies affecting access to services and funding for communication and swallowing issues.
"Advocate at the local, state, and national levels for funding for services, education, and research....
"Help to recruit and retain SLPs with diverse backgrounds and interests.
"Collaborate on advocacy objectives with other professionals/colleagues regarding mutual goals....
"Advocate for fair and equitable services for all individuals, especially the most vulnerable" (emphases added)?
Do we or do we not hold paramount the welfare of the people we serve (Principle I), which must include teaching students explicitly about the scholarship of understanding and supporting other people's perceptions of their "welfare"? Do we or do we not seek to uphold both the dignity and, importantly, the autonomy of our professions (Principle IV)? Are we or are we not interested in ensuring that programs provide, and future professionals learn, the details that they need to be able to "understand the influence of issues related to cultural and linguistic diversity"; "enter into the [clinical or research] relationship with awareness, knowledge, and skills about their own culture and cultural biases, strengths, and limitations"; and provide "competent services to all populations" -- which includes "recognition of the cultural and linguistic experiences, or life experiences, of both the professional and those they serve"?
And, still quoting from the 2017 cultural ethics statement: "Cultural and linguistic competence is as important to the successful provision of services as are scientific, technical, and clinical knowledge and skills.... Speech, language, and hearing research and services should be respectful of and responsive to the needs of culturally and linguistically diverse populations."
Standard 4.3B is the educational program standard that makes any of this possible. We will fundamentally not be the profession we seek to be, or even the profession we say we are, if we reduce Standard 4.3B to some vague comment about family-centered care. It's not that "family-centered" care is wrong; it's that the role of accreditation standards is to spell out, in no uncertain terms, what potentially vague or complex terms actually mean and what programs must do to demonstrate that they are meeting the standards. Not to jump too far down a slippery slope, but if we drop any mention of culture and diversity from the culture and diversity standard, then why not replace the entire set of standards with something like "The program must be a good program"? It's true, but it's useless.
If you have to make some concessions to the bigotry and stupidity at work in some universities and statehouses at the moment, we could try a line in the accreditation handbook that says "Programs operating at institutions or in states that prohibit any of the terminology or topics addressed by Standard 3.4B will not be penalized in accreditation reviews for their efforts to comply with university regulations or state law. These programs are also expected to demonstrate that students have been exposed to ASHA's ethical requirements and culture-related documents." If federal funds are the issue, then add a similar statement about operating within federal law.
But until or unless our federal government or any state government actually manages to explicitly outlaw culture, identity, diversity, or any language other than English, or until or unless we can point to a specific current federal requirement for educational programs that would be in direct conflict with the current Standard 3.4B, I see absolutely no reason to change it. And even if state or federal law manages to change in these ways, I would still prefer to see Standard 3.4B continue to express our profession's values, state that the CAA "prefers" for programs to provide all the detailed elements that the current Standard 3.4B lists, and note, again, that no program's accreditation status will be harmed if they are genuinely required to follow other rules.
Please note that I am writing as a former department head and a former program director. I am familiar with the complexities of designing and providing educational programs, demonstrating compliance with accreditation standards, and managing competing needs. I still say ASHA and the CAA should explicitly express and explicitly support what I thought our profession's values were, not cave in to what I hope will be short-term political pressures.
Thank you for considering my thoughts as part of your review.
Yours very truly,
Anne Bothe Marcotte, Ph.D.
ASHA 01092638
ASHA Fellow (2015)
Professor Emerita, University of Georgia
Part-Time Instructional Aide, Athens Technical College
Anne Marcotte | July 7, 2025