Nobody at ACTFL has ever said anything about you having to communicate with your students while using certain words. Try doing that in English at the dinner table. It’s not so easy! In fact, I find it impossible and after trying it for 15 years when I was doing TPRS, I finally gave up five years ago and focused on what the research says that conversation can’t be planned out. The result is the Ultimate CI Book, which in my opinion is far better than any other way to use CI, if the person can wrap their head around the concept.