To:
Re:
Date:
Dear X (FSA Administrator),
I am writing to appeal a denied claim for speech therapy services for X (client’s name) under my
Flexible Spending Arrangement (FSA) plan. These services are essential to successfully treat X’s
(clients’ name) stuttering disorder. X (client’s name) has been diagnosed with a X (severity) stuttering
disorder that is characterized by behavioral, affective, and cognitive components. The behavioral
components of the disorder include many instances of speech disfluency including speech repetitions,
blockages or tense pauses before words and phrases, and/or prolongations of sounds. These behaviors
are the result of disruptions in the timing of the systems of respiration, phonation, and articulation.
In your denial letter, you stated that the reason for the denial was X (list reason give for denial here).
Internal Revenue Service (IRS) publication 502 states that both Special Education and Therapy are
eligible services for FSA accounts. In fact, IRS publication 502 states:
You can include in medical expenses fees you pay on a doctor’s recommendation for a child’s tutoring by a teacher
who is specially trained and qualified to work with children who have learning disabilities caused by mental or
physical impairments, including nervous system disorders.
IRS publication 502 further states:
You can include in medical expenses amounts you pay for therapy received as medical treatment.
As it relates to IRS publication 502, there are several important points I would like to make to support
the need for speech therapy services for X (client’s name):
1. Stuttering is not a “psychogenic” or “emotional” disorder. Recent brain imaging studies have
indicated that during speech, people who stutter exhibit specific differences in the physiology and
functioning of the brain in the areas responsible for speech and language. References include:
Foundas AL; Bollich AM; Corey DM; Hurley M; Heilman KM. (2001) Anomolous anatomy of speech-language
areas in adults with persistent developmental stuttering. Neurology. 57:207-15
2. Stuttering affects multiple neural systems used for planning language and producing speech. Specific
areas include the speech-motor regions of the non-dominant cerebral hemisphere. References
include:
Fox P.T., Ingham RJ. et al. (2000) Brain correlates of stuttering and syllable production. A PET performancecorrelation and analysis. Brain. 123:1985-2004
3. Stuttering tends to run in families, indicating that there is a genetic component to the transmission of
the disorder. Thus, it is not purely environmental or learned. Children with family members who
stutter are at greater risk for continuing to stutter than children without a family history of stuttering.
References include:
Gordon N. (2002) Stuttering: incidence and causes. Developmental Medicine and Child Neurology. 44:278-81
4. The longer a child stutters, the more likely he is to develop negative reactions to stuttering that may
affect his ability to succeed in social and educational endeavors. Waiting to see if a child will
“outgrow” his stuttering before beginning treatment may result in more severe stuttering that is more
resistive to treatment. Therefore, early intervention is critical to reduce the likelihood that a child
will need more intensive and costly treatment at a later date.
Nicholas, A. & Millard, S.K. (1998). The case for early intervention with preschool dysfluent children.
International Journal of Language Communication Disorders, 33: 374-377.
5. Stuttering can result in the same deficits in general communication as other speech and language
disorders. Speech-language pathology services are not educational in nature, but instead are
recognized as healthcare services by the U.S. Department of Health and Human Services as well as
the Joint Commission on the Accreditation of Healthcare Organizations (JCAHO). In fact, stuttering
is a disorder that has been classified and given a diagnostic code in the International Classification
of Diseases, 9th Revision. The term “healthy” indicates that an individual is free from disease or
dysfunction. A person who stutters is not free from dysfunction due to the lack of normal speech
function. In these terms, treatment of stuttering may be classified as “medically necessary.” The
Health Insurance Association of America (HIAA) has issued a report recognizing the importance of
Speech-Language Pathology and Audiology services. In addition, you should know that speechlanguage pathologists are licensed in 40 states in order to protect the public health.
6. Not all speech therapists specialize in stuttering. It is critical to have an evaluation and subsequent
treatment carried out by a speech-language pathologist with extensive experience in stuttering.
Based on the recommendations of X (SLP’s name and credentials), speech therapy services are critical
in helping X (client’s name) reach his potential in social and educational areas. Depriving him of these
needed services may have a profound negative impact. Both children and adults with communication
disorders are far more likely to exhibit deviant behavior as their frustration continues to grow.
At this time, my sincere hope is that we can work this out through the appeal process and reach an
agreement that speech therapy services should be covered for X (client’s name) under our FSA plan. I
understand that federal legislators do not want to be bothered with formal complaints, so I look forward
to working with you to solve this matter.
Finally, I would welcome the opportunity for you to meet X (client’s name) so that you can get a better
sense of X (his/her) communication deficit.
Sincerely,