Speakup Blog

This SpeakUp! blog addresses questions posed to Lewis Golinker, Esquire, USSAAC's former Advocacy Director, about the development of adequate and necessary information to support speech-generating device (SGD) funding requests. This is a condensed version of Lew's response (from November, 2025, and edited by Amy Goldman) to the concerns voiced by a USSAAC member and speech-language pathologist (SLP). USSAAC is grateful for Lew's service to USSAAC and his career spent advocating for access to, and payment for, AAC devices and services.

NOTE:  The specific question presented was focused on Medicare. This response is applicable to Medicare and all other health benefits funding sources for SGDs.

1. Is an SLP's signature required for an SLP evaluation report in support of a Medicare SGD funding request?

Yes, but... Medicare's Local Coverage Determination (October 2015) discusses the documentation required to support a Medicare SGD funding request. It has multiple references to "signatures", but none is directed to the SLP report or addenda or revisions to the report. Signature references appear to be directed to the physician and the beneficiary (who must sign for the device upon delivery).

However, the LCD is explicit in stating an SLP evaluation must support the benefit request and the data from that evaluation must be stated in writing. In addition, the SLP performing the beneficiary evaluation must attest to financial independence from the supplier. Although not stated expressly, as a practical matter, this attestation requirement is a SLP signature requirement for the SLP evaluation report and recommendation. Also as a practical matter, if an SLP provides a signature, the date of the signature also should be provided.

2. Are signatures required on additional documents that may be prepared to support an SGD funding request? 

In my opinion, yes. It is common that documents in addition to the SLP report will be submitted to support an SGD funding request to Medicare or other funding sources. These additional documents may complement or supplement the SLP report, or revise or add to that report. They may be generated by the SLP or others.

Medicare guidance does not state that a signature and date is required for these additional documents. Nonetheless, it is my opinion that all additional documents, whether from the SLP or another source, should be signed and dated, regardless of the funding source to which the document is directed.

3. Why is an SLP signature and date so important? 

In a few words: credibility and integrity. For close to 50 years, SLPs have worked to persuade funding sources that their reports and recommendations are procedurally and substantively credible. Sufficiently so for the funding sources to rely on or defer to the SLPs' professional judgments and conclusions.

In addition, SLPs have worked to persuade funding sources of their integrity: that their reports and recommendations are based solely on their professional judgment of what is most appropriate to address clients' daily communication needs.

These dual goals have largely been achieved, leading to approval of almost all funding requests at the first level of review. Consequently, clients secure device access much sooner and much less effort is required to gain that access than if appeals would be required.

But the foundation for routine approval of SGD funding requests is thin and easily cracked. And once that foundation is cracked, it will be very difficult or impossible to repair. To protect that foundation, in my opinion, SLPs should view their evaluation data (facts measured and observed), their conclusions and their recommendations as valuable personal, professional property. They should want to protect that property from unauthorized use. Unauthorized use presents three types of risks: to specific clients' request for SGD funding; to the specific SLP's professional reputation; and to the foundation of trust of SLPs generally.

By signing and dating all documents supporting funding requests, SLPs, on a continuing basis, are pledging on their professional reputation that the information and/or opinion stated in each document satisfies all of Medicare's (and other funding sources') procedural and substantive requirements and deserves to be relied on. This includes: that the evaluation was performed by the SLP; that the evaluation was performed consistent with the funding source's requirements and consistent with the SLP's professional practice standards; and that the equipment recommendation represents solely the SLPs' professional judgment of what is most appropriate for the client. And on the basis of the SLP report and recommendation and additional documentation submitted, Medicare and other funding sources should rely on the SLP's recommendation and grant prior authorization for the requested equipment or approve the Medicare claim for payment for the equipment.

The SLP's signature on each document submitted to Medicare or other funding sources is an easy to perform task that should be viewed as required even if it is not formally demanded by Medicare guidance documents. In my opinion, signing and dating all documents supporting SGD funding requests is a security feature not different from checking to see that doors are locked upon leaving home.

4. In the absence of direct Medicare guidance regarding SLP signature on an addendum or a revision report, is an SLP signature indicated?

In my opinion, yes. An addendum or revision to an initial SLP report should not warrant different treatment than the original report and recommendation. SLPs should sign and date every report and recommendation including addenda and revisions. By signing and dating all of them, SLPs are communicating to Medicare that they have upheld their responsibility under Medicare's SGD coverage guidance.

5. What happens if there is a situation where the supplier (e.g. through its local sales representatives or "funding department") fills in missing information they believe is needed to secure physician signature and advance a funding claim, without the SLP's knowledge or consent?

This question requires 2 answers. First, for decades, SGD suppliers have encouraged SLPs to use supplier-developed templates to help SLPs organize their thoughts; ensure their evaluations and reporting are complete; and have provided feedback to SLPs to address missing, unclear or contradictory information in their reports. Use of these templates is voluntary – a matter reserved to SLPs' discretion.

To complete these templates SLPs are required to fill in blanks or otherwise add client-specific data and SLP conclusions and professional judgments about client needs. When templates are just a resource for SLPs, they are not a problem.

But the second answer is that if supplier staff completes one of these templates or creates any other document that suggests it was authored by the SLP and then submits the document to a funding source without an SLP's knowledge, review and assent, signature and date, in my opinion, this is evidence of fraud. Supplier staff are not authorized to 'stand in' for the SLP without the SLP's knowledge and consent. If there is a need for data, opinion or conclusion that fills-in missing information, clarifies unclear statements or provides context to resolve contradictory evidence in the file, the supplier's staff's duty is to identify these issues for the SLP. But that is the limit of the supplier's authority. It is for SLPs to address these points (or not), exercising their independent professional judgment.

6. Do you have a recommendation for language that should be added to the SLP evaluation report? Why is such a paragraph important?

I recommend the addition of a paragraph at the conclusion of the evaluation report and above the SLP signature and date. The intent of this paragraph is to ensure current and future clients with SGD need have continued access to Medicare and other sources' funding for those devices. It advances that goal by making clear that everything in the client's file that has as its basis something the SLP did or concluded has been given close scrutiny for accuracy and completeness.

My signature below affirms that this document is an accurate report of the evaluation I performed for this client, of the facts I gathered or that were reported to me from other sources, and is a true and correct statement of my professional conclusion and recommendation, and of my financial independence from the device supplier.  Any addendum, revision or supplement to this report, and any other document to be submitted that is related to this funding request also will be signed and dated by me.
 

Sources

Medicare Local Coverage Determination (LCD) for SGDs #L33739 October 2015 posted at www.cms.gov/medicare-coverage-database/view/lcd.aspx?LCDId=33739&ContrID=140

Medicare Local Coverage Article for SGDs# A52469 article October 2015 posted at www.cms.gov/medicare-coverage-database/view/article.aspx?articleId=52469&ver=28

Resources

For the history of Medicare funding for SGDs, go to https://aacfundinghelp.com/