CESRW Meeting June 18, 2026 - Public Comment 1

June 5, 2026

Mitch Steiger, Chair
Classified Employee Staffing Ratio Workgroup via e-mail
California Department of Education
1430 N Street
Sacramento, CA 95814

Dear Mr. Steiger:

We write on behalf of the California Speech Language Hearing Association (CSHA) to provide comments on the draft report of the Classified Employee Staffing Ratio Workgroup (July 2026). We appreciate the Workgroup’s efforts to address staffing equity across California’s classified workforce, and we respectfully write to raise a matter of significant concern: the inclusion of Speech-Language Pathologists (SLPs) in the Health and Student Services grouping of the classified workforce framework.

As defined in California Education Code section 41401(b), “classified employee” means an employee of a school district “employed in a position not requiring certification qualifications.” School-based SLPs do not meet this definition. Speech language pathologists hold master’s degrees in communication sciences and disorders and are required to hold a Speech-Language Pathology (SLP) Services Credential issued by the California Commission on Teacher Credentialing (for those working in schools) or a California License in Speech-Language Pathology from the Speech-Language Pathology and Audiology and Hearing Aid Dispensers Board (SLPAHAD). Many California Speech Language Pathologists also hold a Certificate of Clinical Competence in Speech-Language Pathology through the American Speech-Language-Hearing Association (ASHA), They are credentialed and licensed professionals — not classified staff — and we do not believe should be included in a classified employee staffing ratio framework.

Including SLPs in the classified workgroup’s recommendations risks mischaracterizing a highly specialized, credentialed profession. We are also concerned about confusing staffing ratios with the distinct legal and regulatory framework that already governs SLP caseloads in California schools (Cal. Educ. Code § 56363.3; 5 C.C.R § 3051.1; Cal. Educ. Code § 56441.7).

SLP Caseloads in California Are Longstanding concern

The challenges with caseloads facing California’s school-based SLPs are a priority for CSHA and the association has established a taskforce to address the concerns. In 2025, CSHA produced A Closer Look at Caseloads: Challenges in School-Based SpeechLanguage Pathology Services, a report by Dr. Sherrie Reed Bennett which included information based on a survey of California SLPs. The report provides valuable context for this issue:

• California employs 5,659 SLPs (FTE) in public schools — a ratio of 1 SLP for every 1,034 enrolled students and 1 for every 30 students whose primary disability is Speech Language Impairment.
• California law sets a caseload limit of 55 students for K–12 SLPs (5 C.C.R § 3051.1; Cal. Educ. Code § 56363.3) and 40 students for SLPs serving exclusively preschool-aged children (Cal. Educ. Code § 56441.7). These limits were established in the 1980s and have not been meaningfully updated since.
• In a CSHA statewide survey, school-based SLPs reported an average of 64 students, with some caseloads reported higher. SLPs serving exclusively preschool students averaged 48 cases, also above the 40-student cap.
• Nationwide, 24% of SLPs describe their workloads as unmanageable (American Speech Language Hearing Association (ASHA), 2024). In California specifically, 77% of school-based SLPs have considered leaving the field due to unmanageable caseloads.

CSHA has identified several issues driving the problem: inconsistent interpretation of caseload requirements, incomplete reporting of SLP caseload data, and a lack of clear accountability for monitoring and enforcement at the local and state level. The association continues to work on finding solutions to these challenges.

The complexity driving challenging workloads extends well beyond direct student contact. SLPs must conduct multilingual and disability-specific assessments, author and attend IEP meetings, maintain detailed Medi-Cal billing documentation, supervise Speech-Language Pathology Assistants (SLPAs), and provide consultation to teachers and families.

We would be happy to schedule a meeting with CSHA leadership and the SLP Caseload Taskforce Chair to discuss these issues.

Thank you for your consideration. If we can be of further assistance, please contact me at (916) 616-3116 or via e-mail at andrea@ballfrostgroup.com.

Sincerely,

Andrea Ball
Legislative Advocate
California Speech Language Hearing Association

Laura Wasco
Legislative Advocate
California Speech Language Hearing Association

Copy: Monique McWayne, California Department of Education

Return to CESRW Meeting Agenda June 18, 2026