A 2003 ruling by an insurance commissioner in Michigan that the diagnosis of childhood apraxia of speech (CAS) can be viewed as both developmental and neurological has facilitated reimbursement for speech-language pathology services and may have broader implications. The ruling, made on a review, stated that developmental and neurological issues are not mutually exclusive, but both may exist in relation to a diagnosis.
In December 2002, a father in Michigan filed a request on behalf of his young son that the Commissioner of Financial and Insurance Services review the denial of benefits for speech services by Blue Cross Blue Shield of Michigan (BCBSM).
The child had initially been diagnosed with suspected CAS and delayed expressive language skills. After a period of treatment, the speech-language pathologist subsequently confirmed the CAS diagnosis. The child demonstrated improvement through treatment and both the SLP and the child's physician stated that with further treatment the child would continue to improve.
While BCBSM admitted that speech treatment was a covered benefit under the insurance contract, they argued that the contract specifically excluded coverage for speech and language conditions that were "developmental." BCBSM claimed that the child's condition was developmental and was therefore not a covered service. BCBSM further claimed that the child was being treated for stuttering and for articulation errors, both of which they argued were developmental.
An Independent Review Organization (IRO) appointed by the insurance commissioner stated that speech disorders in children are often both developmental and organic and one does not automatically exclude the other. The IRO found that although the child's speech issues were longstanding, developmental, and possibly congenital, the impairment was also neurological, thus organic. The review body also stated that the child's apraxia of speech and stuttering may have neuropathological correlates. Finally, the IRO noted that the child's speech treatment had benefited him and that the services were effective in the remediation of disorders that were both organic and developmental in nature. The commissioner then ruled that the child's condition was not strictly developmental in nature and therefore the speech therapy was a covered service.
Analysis and Implications
The ruling may be helpful in relation to insurance reimbursement for speech services for some children. While the decision was not rendered in a court of law and thus may not be controlling, it could be relevant and could potentially influence a judiciary decision. Additionally, the case could be referenced in other appeals of denials of speech treatment coverage. According to the Michigan ruling, BCBSM had 60 days from the date of the Insurance Commissions Order to seek judicial review. The date of the order was Jan. 31, 2003. As of June 1, 2003, per telephone inquiries to the Insurance Bureau, Department of Consumer & Industry Services in Michigan, no appeal had been filed and thus it is presumed that the ruling stands.
The term "developmental apraxia of speech" is misleading in that developmental implies to insurers that children will outgrow a speech impairment. However, according to David Hammer, coordinator of speech-language services at Children's Hospital of Pittsburgh, "the word 'developmental,' when used with apraxia, signifies a childhood disorder to differentiate it from adult acquired apraxia."
Visit the Apraxia-KIDS Web site to read the ruling from the Michigan Insurance Commission.