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Published in the August 2026 issue of the ISHA Voice

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

At last, the fourth (extended Part 3!) and final article summarizing the feedback gathered in the 2026 Illinois School-based SLP Workload Survey is here!  Many concerns were shared, all of which fall under one of the following topics:  

• regulatory issues
• administrative issues
• caseload, workload
• salary

Here is a link to all of the specific comments.

REGULATORY ISSUES:  First, we are all obligated to uphold our Codes of Ethics (i.e. ASHA, ISHA, IL Educator), which, in turn, all require us to uphold federal, state, and local regulations (i.e. laws, codes, statutes, etc.).  A Code is a set of related laws.  The Illinois Administrative Code Section 226.735 Workload for Special Educators is a law within the state’s Administrative Code for Special Education, and is linked on ISBE’s website (scroll to page 98).  Since you, as a school-based SLP and educator, are obligated to follow laws, etc., you do not need your administrator’s permission to do so. 

Workload analysis is required in the Code…not an “option” to be ignored.  Unfortunately, ISBE does not monitor districts’ compliance with this Code, though I believe we would all agree that they should.  However, an ISBE Special Education staff member has encouraged the submission of complaints (more about complaints later) about non-compliance, adding that if ISBE doesn’t know about the issues, they can’t support us for change/compliance.  If your district, large or small, has not implemented a workload plan that actually analyzes ALL four areas of the Code, then you do NOT have a workload plan that is in compliance with the Code.  As many of you have noted in this and previous surveys, counting the number of students and/or IEP minutes is NOT analyzing IEPs (noting what is required for direct and indirect services), and everything else required of you…it is NOT looking at ALL you are required to accomplish during your contractual time. 

No one really wants to submit a complaint; collaborating with each other and with administrators to develop a plan that accomplishes everything the Code requires is preferred, of course.  So, if you find that you do not have administrator support, you and your team may want to consider gathering data using a workload analysis method (e.g. ASHA’s WL calculator (there is a new one), or ISHA’s Guide for Eligibility and WL Analysis).  The data you and your team of SLPs collect should help your advocacy efforts, and it would also demonstrate that you are attempting to follow the Code, even though your district is not.  ISHA’s WL analysis has been specifically designed to follow the requirements of the Code.

One of the respondents to the survey expressed that ASHA’s WL Calculator and ISHA’s WL Analysis are very time-consuming.  Yes, documenting all that we do in schools IS time-consuming, but  necessary if we want to justify our need to better manage our overwhelming workloads.  More about the WL Calculator and ISHA’s WL Analysis in the next section.

ADMINISTRATIVE, CASELOAD, and WORKLOAD ISSUES: These are related issues and will be addressed together.  Special education administrators are responsible for managing special education programs, supervision of certified staff, making sure the district is in compliance with IDEA and state regulations, and to make sure IEPs provide appropriate student services in compliance with FAPE.

One critical compliance issue, of course, is to uphold the IL Administrative Code Section 226.735 Workload for Special Educators.  This section of the Special Education Code requires the analysis of 

• individualized instruction
• consultative services and other collaboration with staff
• attendance at meetings (IEPs, staff, etc.)
• paperwork and reporting

To that end, the IL Workload Analysis helps to document specific tasks required for each student, calculating the amount of time required for each task and student (Student Profile form), and then calculates the total time needed by the SLP (SLP Summary form) to fulfill all IEP tasks (direct and indirect), all compliance issues, and district-required activities (staff meetings, plan, lunch, supervision and mentoring of CFs/SLPAs, travel).  

The following chart is a comparison of the ASHA Calculator and ISHA’s WL Analysis. Both of these tools are free to use.  As SLPs, we will always have caseloads in schools; the point here is to recognize the characteristics and needs of students in the different programs districts offer (i.e. general education, instructional, self-contained, autism programs, etc.).  One SLP’s caseload can be significantly different from another SLP’s caseload, even within the same building.  However, workloads should be as balanced as possible.  Each SLP in this case will have the same daily hours, the same amounts of time for plan and lunch, but one whose workload is higher than the other is not fair to the students whose services may be compromised by an overwhelmed SLP.  Ultimately, it’s student outcomes that will be impacted, and it is for this reason that workload analysis has been mandated by ISBE.  It really doesn’t matter which workload analysis is used—ASHA’s, ISHA’s, or another—as long as the requirements of ILAC Section 226.735 are upheld.

According to email communications with ISBE several years ago, a district who does not follow the Code would be considered in non-compliance of the regulation (see #4 in the linked document).  One respondent suggested that ISBE be mandated to review workload plans every 3-5 years.  This is an excellent idea!  Maybe it should be tied into the current regulation that ISBE review and/or update its IEP paperwork every TWO years.  Or preferably yet would be the review of WL plans and IEP paperwork to be reviewed and/or updated every 3-5 years (even 5 years), with NO changes to IEP paperwork in between!  Honestly, the review of IEP paperwork every two years seems to be very cumbersome for ISBE staff.  If we all were given appropriate instruction for completing IEP paperwork, there wouldn’t be such need to make changes due to results of mediation finding issues with details missing from IEPs (something a committee on IEP paperwork redundancy has learned; we are still working with ISBE and legislators on this, but this is another topic!).

There was a comment on the survey about SLPs being “…relegated to evaluations, re-evaluations, IEP meetings, and miss out on forming connections with students…”.  If you review the IL Speech Language Pathology and Audiology Practice Act, Sections 8.5-8.8, and if you follow the requirements for supervision, you will learn that part of your responsibility includes having knowledge of and, at least, “first encounters” with the students on your caseload.  SLPAs are not allowed to have their own caseloads; essentially, they follow your scheduled sessions for your students.  As supervising SLPs, we must be ready to assume scheduled therapy sessions if, for whatever reason, the SLPA is not able to do so.  So, you should not accept a role that would eliminate your total interactions with students, unless, of course, you accept the role as a district’s S/L diagnostician (and then wouldn’t be supervising an SLPA).

Another respondent mentioned the issue of missed sessions due to the SLP having to attend IEP meetings.  This too is another topic, but suffice it to say, not all missed minutes must be made up.  These are decisions that should be determined by individual IEP teams on a case-by-case basis.  Consideration and review of impact on the student (denial of FAPE, regression, etc.) determines the need for compensatory services, which do not mandate that compensatory service time be equal to missed session minutes, and there is no mandate requiring compensatory services to be provided during the school day and/or the regular school year.  This can all be found in OSEP policy guidance letters (i.e. Letters to Clarke, Kane, and Pergament).

For comments specific to workload not already addressed, the following responses are offered:

• Completing WL analysis takes time…yes, it does.  ASHA’s calculator must be completed daily for however long necessary or desired; to complete ISHA’s analysis (which, remember, upholds the Code) the Student Profile form is completed annually (i.e. after eligibility/annual review), or whenever the IEP is changed, and the SLP Summary is also completed annually, by January in preparation for identifying staffing needs for the following year.  Both ASHA and ISHA applications calculate time needed for direct, indirect, all compliance issues, and duties/responsibilities of the district.  It includes plan and lunch times, travel time, supervision, and if you provide consultation and strategies via MTSS/RtI, it includes that time as well.  ASHA’s calculator is a daily time study; ISHA’s analysis looks at individual IEPs and SLP responsibilities at least annually.
• Various caseload assignments:  ISHA’s WL Analysis includes a Team Consensus form completed annually by the SLP team members.  This form is meant to ensure that SLPs use these average time amounts when completing their WL forms.  As we all know, some of us take longer than others to complete certain tasks; by averaging these time amounts and having all SLPs in the district use the average times to complete student profiles and SLP summary pages, the SLPs are demonstrating that they are doing their best to be fair to the district.  
• Need for clear definitions of direct and indirect services:  See Advocacy Part 2 article for discussion.
• Burdens experienced by an in-person SLP due to contracted/remote SLPs:  Contract and remote SLPs are responsible for responding to questions from the teachers and/or parents of the students on their caseloads.  In-person SLPs are only responsible for the students on their caseloads.  If in-person SLPs are going to be responsible for all evaluations, then their caseload assignments and workloads should be adjusted.  If burdened with questions from parents and/or teachers of students receiving services from others (remote or not), the in-person SLP should respond with encouragement to contact the SLP providing services.
• Schedules that vary week to week and districts/administrators constantly changing scheduled meetings: these are perhaps systemic or working conditions issues.  Can the special education team problem-solve with administration?  What about identifying a day of the week, or a week every month dedicated to meetings?
• Case manager for SLP only students:  this is documented and given time on ISHA’s Student Profile form.
• WL statement into a CBA: a general statement of upholding regulatory requirements would be sufficient, but to add specific information may be difficult to change if the regulation changes.  Since Section 226.735 is already a law, it is not necessary to add to a CBA.  The IL Educator Code of Ethics already requires all educators and administrators to uphold laws.
• Using CL student numbers, IEP direct minutes, units or ratings: will never completely or accurately define an SLP’s workload responsibilities.  The number of students doesn’t address each student’s need which varies significantly based on their adverse effects.  IEP minutes address only part of the workload.  Units or ratings are arbitrary and do not identify the amount of time each SLP needs to fulfill each task/activity required by students’ IEPs and district duties and responsibilities.
• Case manager responsibilities not included in a district’s WL:  Whether you are the case manager, the service provider, or both, the time it takes to complete your responsibilities for each of your students should be included in your workload calculations.  Both ASHA’s WL Calculator and ISHA’s WL Analysis do include these responsibilities in their calculations.
• Designated screening and evaluation times on your schedule:  You make your schedule, so where you can’t schedule students regularly, use those times for screening and evaluating.  ISHA’s WL Analysis provides space on the student form to include the time needed for re-evaluation.  Screenings and initial evaluations occur before a student is IEP’d and SLP teams can determine an average time needed, and either start a Student Profile form or include the time as “district duties…” on the summary form.
• Space for Therapy:  Perhaps many SLPs have found themselves in less-than-optimal spaces for providing therapy.  Rooms next to lunchrooms or band rooms, “rooms” with no walls under stairwells near exit doors used during recess, rooms with no windows and poor ventilation, very small rooms or large rooms having to be shared with another teacher.  None of these are appropriate spaces for the work we do; none are appropriate for students requiring specialized instruction.  Advocating for appropriate therapy space is a “working environment” issue, and unfortunately the resolution may be so dependent on the district’s socio-economic status, demographics, age of the building, etc.  But, if advocacy focuses on how your space affects your students, their progress, their accessibility, and if you can scope out your building for a potential, more appropriate space to suggest, then perhaps you and your administrators (principal?) can problem-solve together.
• Dictating group size:  Expecting therapy sessions to always have a set number of students (e.g. 3) could potentially cause a denial of FAPE and be in violation of IEP services.  As SLPs only we have the clinical judgment to appropriately determine group sizes based on student needs and behaviors.

Before beginning a full-out advocacy campaign within your district, you do need to review and reflect on your eligibility practices.  Are you following IDEA’s requirements to identify adverse effect(s) and educational impact (academic and functional performance)?  Your review of your eligibility practices should help you identify students on your caseload who really may not exhibit impact on their academic and/or functional performance, and therefore are not eligible for special education services; these students should be dismissed.  This does not necessarily mean they no longer exhibit a disorder; it just means they are not eligible for services within the school setting.  By dismissing students and/or by appropriately identifying students eligible for services, you will demonstrate to your administrators that you are doing your part to manage your caseload and workload.  

Along with reviewing and aligning eligibility practices with IDEA and state regulations, there are also specific requirements for the content of IEPs.  I can tell you that, after several conversations with my contact in ISBE’s Special Education department, and with ISBE staff members during IEP paperwork redundancy committee meetings during the past two+ years, improvements are needed for when and how we are trained to complete IEPs.  We should not be copying and pasting information into multiple sections of the IEP…but this is perhaps a topic for another time.  What should be noted is that details about all direct and indirect services, goals/benchmarks, supplementary aids, modifications, accommodations, should ALL answer the questions:  who, what, where, when, why, and how.  

• Who will provide the service?  
• What type of service?  
• Where will the service be provided?  
• When will the service be provided?  Why will the service be provided? 
• How will the service be provided?  

In IDEA language: provide service provider (i.e. SLP or teacher), type of service (i.e. speech and language), location (classroom and/or therapy room), amount and frequency (e.g. min/week or min/month), duration (e.g. for 6 weeks or the entire school year), and the language/mode of communication necessary.  The answer to the “why” question should be the statement describing the adverse effect(s) and impact on educational performance—the academic and functional performance—specific to the goal(s).  Go back to the eligibility documentation to make sure that subsequent IEPs are consistent with why the student was found in need of special education in the first place.  ISBE’s Special Education staff member, someone who is entrenched in responding to mediation requests, says that minutes and details for all services that a student needs should be documented in the IEP.  If there are no minutes documented for services…direct, indirect, compliance…then ISBE cannot support our requests for help with our workload concerns.  The more detail provided in IEPs, the better.

Advocacy strategies to utilize when addressing workload analysis with your district administrators should include, first and foremost, describing the impact of overwhelming workloads on your students.  

• What happens to your students when you can’t plan well?
• When your time is so restricted you must have larger groups than what is best practice?  
• Do your students progress as well as you expect?   

Begin your advocacy conversations with administrators by advocating first for things your students will benefit from; this not only helps them, but also their teachers, parents, the district itself, and ultimately you.  

BOTTOM LINE:  Each of us has a responsibility to uphold our ethical and legal responsibilities, even if we are not directly impacted.  For those of you who have manageable workloads, you are very fortunate; perhaps you could consider supporting your colleagues who aren’t as fortunate, those who  have overwhelming workloads, even if they are in other parts of your district or even the state.  Know that they would be very appreciative of your support!  If your district is not upholding the Code, submit a Complaint Form to ISBE.  Complete pages 4 and 5; where it asks for student-specific information, enter “N/A”.  Include a description of what is happening in your district with regards to workload non-compliance; you can attach additional documentation.  If you began conversations with your administrators, then by providing them with a copy of your “request for support to uphold the Code” form (a.k.a. Complaint Form) should not be a surprise to them.  Imagine the change we could evoke if we all submitted “requests for support to uphold the Code” to ISBE!

SALARY:  Some SLPs throughout the state have successfully negotiated for separate salary schedules, salary schedule placement, and stipends for dues, convention attendance, and/or having CCCs.  Salary issues are specific to individual district’s location, socio-economic status, and other demographics.  The best bet is to participate in your local union, especially during negotiation years.  ASHA has some great resources for working with unions.

Questions and/or concerns can be sent to ISHA’s School Affairs committee chairs and/or the ASHA SEALs for IL.