Why Are Caseloads So High and Workloads So Overwhelming?

Published in the November 2024 issue of the ISHA Voice.

By Karen Kockler, ASHA SEAL for Illinois and member of the School Affairs Committee

Even before the pandemic, SLPs experienced large caseloads and overwhelming workloads. Subsequent effects of Covid have caused more and more students to experience significant and complex deficits. One of the most altruistic, compassionate groups of people on the planet are healthcare professionals, including audiologists, speech language pathologists, and their assistants. It seems it's in our DNA to want, to almost demand of ourselves, to help as many individuals as possible. It is often difficult for us to deny services at some level of support to the students or clients we encounter. However, in this day and age of overwhelming caseloads, workloads, shortages of SLPs, and significant attrition, it is especially critical to know and understand what our roles and responsibilities encompass, and what IDEA and our own state educational laws require of us. How do we balance the different roles we play, fulfill all of our responsibilities, uphold laws and standards, and provide high-quality, evidence-based and effective services to our students all within our contractual day? How can we say “no” when asked or told to work with students not on our caseloads?

First, let’s consider what those roles and responsibilities are in the school setting. In its description of the range of responsibilities we have as school-based SLPs, ASHA includes prevention, assessment, intervention, program design, data collection and analysis, and compliance “for meeting federal and state mandates as well as local policies in performance of their duties.” (ASHA, 2000). We work across all grade levels, address a variety of needs, ensure educational relevance, target language and literacy, contribute our unique skills and expertise by showing relevance to the curriculum, all the while being culturally competent. I won’t elaborate any further on the specifics here; you can learn more by reviewing ASHA’s information linked above.

ISBE describes our roles and responsibilities in ILAC Section 28.230 Standards for Speech Language Pathologists. To uphold these standards, we must demonstrate professionalism and competence in our “knowledge and performance” of the following:

content knowledge [gained from our university training programs];
understanding of human development and learning;
sensitivity to diversity and culture;
skills related to planning and intervention;
creating a positive, safe learning environment;
understanding and implementing a continuum of service delivery;
effective and appropriate communication;
clinical expertise in assessment and evaluation [relevant to the educational setting];
positive and effective collaboration with parents/caregivers, teaching staff, administration, etc.;
continuous self-evaluation, reflection and professional growth;
professional conduct and uphold ethical standards;
understanding of and taking an active role in advocacy and facilitation of accessing appropriate supports for students.

What is typically glossed over, however, are the added district duties and expectations that fall outside of our specific areas of expertise. Those added duties and responsibilities are, indeed, part of our roles as team players in the learning environment and they do contribute to school culture. But, how do we navigate around those oftentimes “fiery hoops” we must jump through? Is there a way to navigate around them?

The ASHA description of our roles and responsibilities and ISBE’s standards provide us with the substance of our “job descriptions”. Additionally, some of us have been told that we have to provide RtI/MTSS interventions for students, and some of us may use RtI/MTSS interventions to provide support for students with articulation or expressive language disorders, or other mild-moderate issues. Whatever the case may be, we need to explore these practices by reviewing the language in IDEA related to eligibility for special education, state and local special education laws for eligibility, and implementation of best practices in determining the appropriateness of working with students through RtI/MTSS interventions. When teachers, or even parents/caregivers, come to us to ask, or in some cases, “report” that a student has, or might have, a speech “problem”, the compassion button is lit, and we find ourselves in rescue mode. So, let’s examine this more closely by considering the following:

In Section 300.8 “Child with a Disability”, IDEA states that students are eligible for special education services if/when an adverse effect is identified. IDEA states that school districts must provide a free appropriate public education (FAPE) to “any individual child with a disability requiring special education and related services, even if the child has not failed or been retained in a course or grade, and is advancing from grade to grade.”. So, what is the meaning of “adverse effect”? How do we determine if an observed “difference” is adversely affecting a student’s access to the educational environment?

“Adverse effect” means significant and consistent negative impact on academic achievement or functional performance. In a Letter to Catherine Clarke (3/2007), OSEP provides the following:
“Whether a speech and language impairment adversely affects a child's educational performance must be determined on a case-by-case basis, depending on the unique needs of a particular child and not based only on discrepancies in age or grade performance in academic subject areas.”
Typically, articulation disorders do not significantly impact academics or functional performance. An adverse effect on academic skills might be observed in those related to phonemic awareness, spelling, literacy development, comprehension, and oral and/or written expression, to name a few. Adverse effects on functional performance might be those related to hearing, speech production, clearly expressing one’s needs, nutritional intake (eating/swallowing), and/or social skills and pragmatic language. When there are significant adverse effects on academics or on functional performance that impede access to the educational/learning environment, then special education is a more appropriate solution. If there are no adverse effects impacting a student’s learning, but there is a physical or mental impairment, then the student may be eligible for interventions under a 504 Plan. If there are no adverse effects, and a student does not experience physical or mental impairments (per the definition of 504 eligibility), then a student should not be considered for direct RtI/MTSS services. An SLP could provide consultation and/or strategies to the teacher who would implement the strategies within the general education setting. The SLP’s role, in this case, is to review the data collected with the teacher and determine next steps.

So, how do we deny provision of direct intervention to students with compassion and professionalism? Asking yourself, the teacher(s), and parents/caregivers the following questions may help guide your decisions:

Is this student able to access the learning environment successfully?
Can the student be understood?
Do the speech errors impact spelling and/or written expression?

Answers to these and other questions will help you determine whether or not the identified issues adversely affect a student’s access to a free appropriate public education (FAPE). If the parents/caregivers do not agree with your decision that there are no significant adverse effects, explain that their child’s errors do not impact his/her access to education as the law (IDEA) requires. Provide the evidence that there is no impact on spelling, written expression, the ability to be understood, or access to good nutrition.

You may suggest (not refer) that there are opportunities to seek services through a private agency or clinic. However, be sure to follow your district’s guidance when making such suggestions. Districts/staff members should not “refer” to outside agencies. Referrals to outside agencies make districts financially responsible for the costs of seeking such services.

Remember that RtI and MTSS are general education initiatives. MTSS is the overarching “global” process of providing supports to students, at different levels, for greater academic success. RtI is the process for targeting more specific needs of individual students resulting in greater academic success. Acknowledging that our roles in schools may include prevention, we could justify our provision of services to general education students by way of consulting with teachers and/or providing appropriate strategies teachers and parents can implement. There is no law—federal or local—that mandates that SLPs provide direct RtI/MTSS interventions. If Collective Bargaining Agreements require SLPs to provide direct services, they go against the intents of IDEA and RtI/MTSS and should be either eliminated or revised to reflect the current federal, state, and local education laws and policies.

RtI/MTSS interventions should be designed to be provided on a short-term basis, for weeks (maybe up to 12 weeks) but certainly not for a year or more, as some SLPs have reported on social media. During those weeks, there should be regular monitoring of a student’s progress. For speech/language consults and/or strategies, the idea is to provide this indirect support, checking in with the teacher to see if the student is responsive and improving at intervals determined by the team (eg. every 4-6 weeks). If the student is progressing, the strategies provided within the general education setting can be continued until the student’s issues have resolved within the team’s designated timeframe. If the student is not progressing, the team determines whether or not more time is needed or that the strategies may not be effective and a change should be made. Reviewing the collected data and progress monitoring are keys to moving a student through and out of RtI/MTSS interventions. Keeping students on RtI/MTSS for more than 6-12 weeks without regular progress monitoring and discussion is not appropriate.

Additional guidance from ASHA’s Schools Services team:

OSEP Guidance Letter to Catherine Clarke, ASHA, 5/28/2008; references RtI/MTSS
ASHA’s Policy Statement on the Roles and Responsibilities of School-based SLPs.
ESSA dictates the utilization of MTSS/RtI, so technically the law does stipulate that policies should be in place to identify, monitor, and/or provide preventative measures for students. RtI/MTSS is provided to students within the general education setting, as they do not have IEPs.
MTSS/RtI doesn’t serve as a replacement for special education. Most places set a temporary timeframe regarding the implementation (eg. 12 weeks max for Tier 2 direct interventions). In Washington DC public schools, for example, If MTSS/RtI interventions exceeded 12 weeks, then their policy required them to be referred for special education. In addition, services through RtI/MTSS cannot be used in place of provision of services via an IEP.
In many places RtI/MTSS students do not count towards caseload because these students don’t have IEPs and that they should not be receiving MTSS/RtI interventions for a prolonged period of time (hence they should be rotating off).
Provision of direct speech language interventions are special education services—whether primary, secondary, or related. IEPs are legally binding documents. If you find you are having difficulty providing all service minutes consistently and with efficacy to your IEP students, perhaps it’s time to reconsider if and how you provide RtI/MTSS services.

ADDITIONAL REFERENCES AND RESOURCES

American Speech-Language-Hearing Association. (2000). Guidelines for the roles and responsibilities of the school-based speech-language pathologist [Guidelines]. Available from www.asha.org/policy/

Child with a disability https://sites.ed.gov/idea/regs/b/a/300.8

Determination of Eligibility https://sites.ed.gov/idea/regs/b/d/300.306

Illinois State Board of Education, Special Education Eligibility and Entitlement within a Response to Intervention Framework: Frequently Asked Questions

Illinois State Board of Education, Illinois Special Education Eligibility and Entitlement Procedures and Criteria within a Response to Intervention Framework: A Guidance Document

LRE

Under Section 612(a)(5) of the IDEA, to the maximum extent appropriate, children with disabilities, including children in public or private institutions or other care facilities, must be educated with children who are not disabled.

(5) Least restrictive environment

(A) In general, to the maximum extent appropriate, children with disabilities, including children in public or private institutions or other care facilities, are educated with children who are not disabled, and special classes, separate schooling, or other removal of children with disabilities from the regular educational environment occurs only when the nature or severity of the disability of a child is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily.

Section 504 of the Rehabilitation Act of 1973 explained in detail:

https://www.ecfr.gov/current/title-34/subtitle-B/chapter-I/part-104#p-104.3(j)(1)

Key definition of eligibility for a 504 Plan: "...has a physical or mental impairment which substantially limits one or more major life activities..."

Special Education https://sites.ed.gov/idea/regs/b/a/300.39