The United States Society for Augmentative and Alternative Communication (USSAAC) writes to state its opposition to the current effort to develop an AAC specialty certification.
USSAAC is a nationwide membership organization and serves as the United States national chapter of the International Society for AAC (ISAAC). USSAAC members include individuals with complex communication needs who use AAC; family members; speech- language pathologists; clinicians, educators and researchers from other professions; speech generating device (SGD) manufacturers; and advocates. Central to USSAAC’s mission is advocacy to expand and protect access to AAC treatment, including SGD funding by public and private health benefits sources.
USSAAC has followed the discussion on the ASHA SIG 12 list serv including the October 29 “joint statement” of ASHA, the Council for Clinical Certification and the so-called “American Board of AAC.” That discussion makes clear the need for the ASHA Board of Directors to intervene directly to add a measure of public accountability to this process. USSAAC believes the AAC specialty certification initiative must be stopped for four reasons: (1) there has been no plain statement of the need for or of the benefits that will accrue from AAC specialty certification; (2) there has been complete and summary dismissal of potential harm that may follow adoption of AAC specialty certification and no consideration of whether the potential harm can be avoided or addressed; (3) there has been no consideration of other alternatives that may provide equal or greater benefits and fewer if any risks of harm to the AAC community as a whole; and (4) the process is being conducted largely and wholly unnecessarily in secret.
USSAAC believes the ASHA Board of Directors must conduct a complete, independent, and public review of both the procedure and substance of this initiative. As applied to AAC as an area of SLP practice, the “semi-autonomous” procedure ASHA established for consideration of specialty certification is not working.
No Statement of Need
For the past 4 decades, AAC service delivery has been the responsibility of SLPs, qualified by their ethical mandate to practice only within the scope of their knowledge, skill, and experience. It generally has been recognized that a critical need exists to expand the number of SLPs able and willing to provide AAC assessment and treatment because there are too few clinical resources currently available to meet the demand for such services. USSAAC is aware of no study, whether informal, peer-reviewed, or published, or public discussion or debate that has stated there is any need for AAC specialty certification or that its effect will address this critical need for increased clinical resources. Instead, the record includes several instances in which AAC specialty recognition or certification was explored and subsequently tabled. We know of no change in circumstance that warrants yet another investigation today.
In addition to there being no study that identifies a need for AAC specialty certification, there has been no disclosure of even a simple statement of reasons for its development. Who will benefit or how anyone will benefit has not been disclosed.
Generalist SLPs Provide Appropriate AAC Services
USSAAC opposes the AAC certification development effort because according to the only statements of need that have been disclosed, this effort is motivated by the conclusion that there is a systemic issue with the quality of AAC service delivery by generalist SLPs. Absent credible proof, we reject this conclusion.
We also reject the assumption that AAC specialty certification is or will be a solution to this alleged quality of service problem. We believe the solution is to improve and expand both pre- and in-service education and training, both of which can be accomplished without AAC specialty certification.
No Consideration of Risks of Harm
USSAAC objects to the further development of AAC specialty certification because there has been a complete and summary dismissal of all possible risks of harm associated with this effort.
The key risk is that AAC specialty certification will be adopted as a requirement for SLPs conducting AAC assessment, submitting reports to support SGD funding requests, and providing AAC treatment. If AAC specialty certification is adopted as a pre-requisite for delivery of these services, clients, SLPs, SGD manufacturers – all USSAAC members — will be harmed.
Rather than explore these risks, we have been told that “there is no evidence to suggest [these risks] ever have happened or [are] going to happen.” Hubris is not a substitute for investigation or analysis.
USSAAC’s concerns based on these risks are tied to the almost 40 years of SGD funding advocacy that has been required to establish and maintain the present extent of funding source acceptance of AAC services and SGDs. There have been and still are many health benefits sources that will try to restrict SGD access if a means exists to do so. AAC specialty certification is just such a means. By itself, restricting AAC service delivery to AAC specialists may not appear to be a source of harm. But when it is unknown how many SLPs will elect to pursue and will qualify for AAC specialty certification and where they will be located, the risks become obvious: if required by funding sources, AAC specialty certification will result in the immediate reduction of AAC services capacity. Whatever its extent, this effect will further worsen the long-standing and continuing shortage of SLPs available to deliver AAC services.
Because all risks have been completely and summarily dismissed, there has been no acknowledgement of the possible reduction in AAC service delivery capacity; no explanation that this reduction will have only a short-term effect; and no explanation of whether or how this loss will be offset by future increases in the number of SLPs available to deliver AAC services. There also has been no statement to the SLPs who will not yet qualify for specialty certification due to lack of experience. They have not been told how they can overcome the barriers to gaining necessary experience if they are excluded from reimbursement for AAC services delivery. Rather than provide a ladder for the expansion of quality AAC services delivery, AAC specialty certification may cause the loss of clinical resources and be a roadblock to SLPs achieving specialty certification in the future.
Medicaid and insurance are the health benefits sources for far more than half of all Americans, and an even larger percentage of all children. To claim that there is “no evidence” the risks associated with AAC specialty certification “[are] going to happen” is more a reflection of what is accepted as “evidence” than what harm AAC specialty certification may cause.
In addition, public schools that have enrolled as Medicaid providers for SLP services will lose the revenue they received from SLPs delivering AAC services who may not qualify for certification. If this occurs, it will be even harder for students to receive appropriate and necessary AAC services.
No Statement of Benefits or Consideration of Alternatives
USSAAC opposes the further development of AAC specialty certification because there has been no disclosure of benefits expected from AAC specialty certification. Also missing is any acknowledgement that alternatives to AAC specialty certification were considered and that this course is the only or best solution. As noted, AAC specialty certification has been described as needed because generalist SLPs lack the skills to provide AAC service of sufficient quality. If the goal is to provide higher quality AAC services to those who need them, there has been no disclosure that an alternative of increasing the focus on AAC core competencies in graduate programs, expanded AAC related continuing education opportunities, or expansion of mentoring and other forms of peer-to-peer assistance were considered.
USSAAC opposes further development of the AAC specialty certification proposal because there has been no statement of need; no identification of the alternatives that may address the “need;” complete and summary dismissal of risks of harm; and unnecessary secrecy concerning the effort. USSAAC, on behalf of its members believes this proposal should not proceed until a complete and public review is undertaken of its need, its process, and its work product to date. ALL stakeholders need to be consulted, including people with complex communication needs and their families. We offer ASHA our full cooperation with this review, to work jointly to ensure that the interests of all members of the AAC community are appropriately considered and efforts to improve AAC service delivery are undertaken. Please contact me if you have questions or wish further information about any of the topics addressed in this letter. We await your reply. Thank you.
Wendy Quach, President, USSAAC On behalf of the USSAAC Board of Directors