Purpose

This policy establishes guidelines for the responsible use of artificial intelligence (AI) tools by speech-language pathologists and related services staff within the district. It ensures compliance with the Family Educational Rights and Privacy Act (FERPA), the Individuals with Disabilities Education Act (IDEA), and district data governance standards while allowing staff to benefit from AI-assisted workflows.

Scope

This policy applies to all district-employed and contracted speech-language pathologists, speech-language pathology assistants (SLPAs), special education administrators, and related services personnel who use AI tools in connection with their professional duties, including but not limited to evaluation, intervention planning, IEP documentation, progress reporting, and parent communication.

Definitions

• AI Tool: Any software application that uses artificial intelligence, machine learning, or large language models to generate, summarize, or analyze text, data, or other content. Examples include ChatGPT, Copilot, Gemini, and similar platforms.
• Personally Identifiable Information (PII): Any data that could identify a student, including name, date of birth, student ID number, disability classification, or any combination of details that could reasonably identify a student.
• De-identification: The process of removing or obscuring all PII so that a student cannot be identified from the remaining information.
• Education Record: Any record directly related to a student that is maintained by the district, as defined under FERPA.
• Public AI Tool: An AI platform that does not have a formal data processing agreement with the district and may use submitted data for model training.

Policy Statements

1. AI tools may be used to support professional productivity, but they shall not replace clinical judgment, professional reasoning, or individualized decision-making required under IDEA.
2. No student PII shall be entered into any public AI tool under any circumstances.
3. All AI-generated content used in official education records must be reviewed, verified, and approved by a licensed SLP before dissemination.
4. AI-assisted IEP goal drafts, evaluation summaries, and progress reports must be clinically accurate and individually tailored to each student before inclusion in any official document.
5. The district shall maintain a list of approved AI tools that have been vetted for FERPA compliance. Only tools on this list may be used with any student-related data, even if de-identified.

Approved Uses

• Drafting IEP goal language using de-identified student profiles (e.g., “a 7-year-old student with a phonological disorder” rather than using the student’s name or identifiers).
• Generating templates for progress notes, evaluation reports, or parent communication letters.
• Researching evidence-based intervention strategies and therapy activity ideas.
• Summarizing professional development materials or clinical research articles.
• Creating therapy materials such as word lists, sentence stimuli, or visual supports that do not contain student information.

Prohibited Uses

• Entering any student name, ID number, date of birth, parent name, school name, or other PII into a public AI tool.
• Using AI to generate IEP goals, evaluation findings, or eligibility determinations without substantive clinician review and modification.
• Submitting audio or video recordings of students to any AI platform for transcription or analysis without an approved data processing agreement.
• Relying on AI-generated diagnostic impressions or eligibility recommendations as the sole basis for clinical decisions.
• Using AI to auto-generate progress data or fabricate clinical observations.

Data Protection Requirements

1. All use of AI tools with student-related information must comply with FERPA (34 CFR Part 99) and applicable state student privacy laws.
2. Before any AI tool may process student data, even in de-identified form, the district technology office must confirm that the tool has a compliant data processing agreement on file.
3. Staff must de-identify all student information before entering it into any AI tool not on the district-approved list. De-identification must remove names, dates of birth, school names, ID numbers, and any combination of descriptors that could identify a student.
4. AI-generated outputs that will become part of a student’s education record must be stored in the district’s official student information system, not on personal devices or third-party platforms.

Disclosure Requirements

1. At each annual IEP meeting, the team shall inform parents/guardians if AI tools were used in the preparation of evaluation reports, IEP documents, or progress summaries.
2. Upon parent request, staff shall identify which portions of documentation were AI-assisted and describe the review process applied.
3. Disclosure language shall be included in the district’s procedural safeguards notice, updated annually.

Documentation Standards

1. When AI is used to draft any portion of an IEP, evaluation report, or progress note, the clinician shall note “AI-assisted draft; reviewed and finalized by [Clinician Name], [Credentials]” in the document’s internal notes or a designated field in the student information system.
2. Staff shall maintain a personal log of AI tools used, the purpose of each use, and confirmation that no PII was entered, available for review upon request by administration.
3. The final clinician of record remains responsible for the accuracy, completeness, and clinical soundness of all documentation regardless of AI assistance.

Compliance & Accountability

1. The Director of Special Education, in coordination with the District Technology Officer, is responsible for maintaining the approved AI tools list and enforcing this policy.
2. Violations involving unauthorized disclosure of student PII through AI tools will be treated as a FERPA violation and may result in disciplinary action up to and including termination.
3. Suspected breaches must be reported immediately to the building administrator and the District Technology Officer.
4. All staff subject to this policy shall complete annual training on FERPA-compliant AI use before using any AI tools in their professional duties.

Review Schedule

This policy shall be reviewed and updated annually by the Director of Special Education, the District Technology Officer, and a representative committee of practicing SLPs. Interim revisions may be issued as needed in response to changes in law, regulation, or available technology.

Acknowledgment

I, ______________________________ (printed name), acknowledge that I have read, understand, and agree to comply with this policy governing AI use in speech-language pathology services.

Signature: ______________________________ Date: ______________

Position/Title: ______________________________ Building(s): ______________________________

Supervisor Signature: ______________________________ Date: ______________