Published in the July 2026 issue of the ISHA Voice.
By Karen Kockler, ASHA SEAL for IL and School Affairs Committee Member
A survey was distributed in March and April this year for all school-based speech language pathologists. There were 152 respondents who provided feedback on several issues, including perceptions related to the definitions of “plan time” and “direct and indirect” services. The previous article in this 3-part series addressed the responses related to defining plan time. This article will address the responses related to direct and indirect services. Next month, part 3 summarizes all other information and comments gathered from the survey!
The two questions were “How do you define “direct services?” and “How do you define “indirect services?” Each question offered the following response choices: 1) all activities performed with students; 2) all activities performed on behalf of students; and 3) Other (for respondents to provide their own understanding of each term).
The responses to the first question, “How do you define “direct services?” indicate that:
· 96.5% (148) of those responding define direct services as all activities performed with students;
· 2% (3) define direct services as all activities performed on behalf of students;
· 0.7% (1) define direct services as all activities directly impacting students and related to their specific goals.
Indirect services were defined as follows:
· 96.7% (147) of respondents define indirect services as all activities performed on behalf of students;
· 0.7% (1) of respondents define indirect services as all activities performed with students;
· 0.7% (1) of respondents define indirect services as activities required so students benefit from the therapy session (e.g. material preparations, AAC device programming, etc.);
· 0.7% (1) of respondents define indirect services as collaboration;
· 0.7% (1) of respondents define indirect services as consultation, device programming;
· 0.7% (1) of respondents define indirect services as consultations with staff regarding students.
Clearly, the majority of respondents define direct services as those provided with students (96.5%), and indirect services as those provided on behalf of students (96.7%). When considering these responses and the “other” comments that were added by respondents, clarifying the terms “direct” and “indirect” services for which SLPs are responsible may be beneficial for improving not only our advocacy efforts, but to also more accurately document in IEPs the services and time needed by students. We could also ask ourselves whether or not direct and indirect services are the only types of activities SLPs perform. In this author’s opinion, there are indeed others.
Consider these four categories:
· direct,
· indirect,
· compliance,
· district expectations.
Would identifying tasks for each of these types help to better describe all of what our roles and responsibilities encompass?
Direct services are, of course, those performed directly with IEP students…easiest to define. These include, but are not limited to, face-to-face therapy/intervention, prepping students for attending their IEP/annual review meetings, and completing re-evaluations with students.
Indirect services and Compliance activities, though related, are different. Indirect services are those performed on behalf of students as related to their individual IEPs. Activities such as scheduling students for therapy or re-evals, consulting with parents, teachers, outside agencies are done on behalf of students to support their learning.
Compliance activities would be those related to the legal responsibilities of special educators, including speech language pathologists and educational audiologists. These are the tasks required by IDEA, the Code of Federal Regulations, and state mandates (e.g. Administrative Code, School Code, etc.). There are three areas these tasks fall under: procedural and timelines, documentation and goal writing, and service delivery. Requirements for due dates, writing measurable goals, implementation of identified services, and making sure students receive accommodations and modifications as outlined in their IEPs (or plans of care) are some compliance activities.
Finally, there are district-required activities. All districts have additional expectations of staff members. Have you ever asked for a copy of your job description? Often job descriptions of a staff member’s role and responsibilities include a statement similar to “…and other duties as assigned/required.” Activities may include attendance at staff meetings, Professional Learning Communities (PLCs), participation at Open Houses, and/or arrival/dismissal/lunchroom supervision of students. And, what about participation on crisis prevention teams?
To provide more inclusive descriptions, here is a chart showing activities/tasks under all four categories. The column headings are color-coded. The “indirect services” and “compliance activities” are the same color for a reason: they represent all that we must accomplish on behalf of our IEP students! These are tasks rarely discussed, but highly expected. These are the tasks that workload analysis would help to identify and require time allotments in our schedules. These are the tasks that give reason to why ISBE enacted the IL Administrative Code Section 226.735 Workload for Special Educators. Administrators need to understand…and see…that our time is not just spent on direct services, represented to them in terms of numbers of students and/or IEP minutes on our caseloads. Imagine what might happen if we all used some of this language in our advocacy efforts. What if we used language from our Codes of Ethics (i.e. ASHA, ISHA, IL Educator, etc.), language from IDEA and the Code of Federal Regulations, and language that speaks to administrators (i.e. compliance; due dates; highly effective, evidence-based interventions)? It is my hope that these descriptions and definitions will help you recognize all that you do and the language that, if used, would help your advocacy efforts be successful.
Stay tuned for Part 3: All Other Statistical Information and Comments (a.k.a. Frustrations and Concerns).