Supervision, Scope, and a Signature on the Billing Log
A school district in a state that licenses SLPAs assigns you to supervise Marcus, a licensed SLPA with four years of experience, across two elementary buildings. Your contract allots 40 minutes per week for supervision. Marcus provides direct therapy to 22 students on your caseload, each twice weekly for 30 minutes. In October the special education director asks Marcus to complete an initial evaluation for a kindergartner referred for speech sound concerns-standardized testing, scoring, and a written report with a diagnosis and eligibility recommendation-because your evaluation schedule is booked until December. The same day, the director asks you to sign September's Medicaid billing log for six sessions you did not attend: 'Marcus was there, the service was delivered, and the district needs the reimbursement.'
1. The director has made two requests. Which do you decline, and how do you handle each one?
Read the worked answer
Decline both, but the analysis and the fix differ.
1. The initial evaluation. Administering, interpreting, diagnosing, and writing the eligibility report is the supervising SLP's work. ASHA's SLPA scope allows an SLPA to assist with screening and with delegated technical tasks, but the SLPA does not interpret findings, assign a diagnosis, or determine eligibility; state licensure rules are often narrower still. Marcus's four years of experience is irrelevant here-scope attaches to the credential, not to competence.
What to do instead: the initial-evaluation timeline under IDEA (60 days in most states) is a legal clock and does not stop because your calendar is full. Options, in order: reschedule your own non-mandated activities; obtain a contract SLP or use the district's assessment pool; if genuinely impossible, the district must document the barrier and, where state rules permit, obtain parental written agreement to a specific extended timeline. Delegating to Marcus is not on the list.
2. The billing log. Signing for six sessions you did not attend is a false claim whether or not services were delivered. It breaches the ASHA Code of Ethics' prohibitions on misrepresentation and on fraud in billing, and it exposes the district to False Claims Act liability and you to licensure discipline-'the district needs the reimbursement' is not a defense.
Nuance that matters: many states do allow SLPA-delivered services to be billed under the supervising SLP's provider number. But that is contingent on the supervision your state requires having actually occurred and being documented. So: pull Marcus's session notes and your supervision log for those six dates. Sign only what you can personally attest to; if supervision did not occur, do not sign, and say so in writing.
2. Marcus asks whether he can administer and score the GFTA-3 and whether he can complete hearing screenings for the building. Separately, the district gives you 40 minutes a week for supervision. Is that enough? Show your reasoning and your plan.
Read the worked answer
(a) Hearing screening: yes. (b) GFTA-3: partly. (c) 40 minutes: no.
- Hearing screening is a technical, non-interpretive procedure within SLPA scope. Marcus may conduct it; you interpret the result and follow up on any failed screen.
- Administering and scoring a standardized test is treated as a delegated technical task in some states and prohibited in others-verify your state's rule before agreeing. What is not delegable anywhere: interpreting the score, integrating it with other data, diagnosing, and writing the report.
- The math. 22 students × 2 sessions/week × 30 minutes = 1,320 minutes = 22 hours of direct service per week. ASHA's supervision guidance calls for at least 20% of the SLPA's work time in supervision (state minimums vary): 0.20 × 1,320 = 264 minutes, about 4.4 hours per week, weighted toward direct observation early and when student needs are complex. You have 40 minutes-roughly 3%.
Plan: put the shortfall in writing to the director with the computation attached, and ask for one of: a caseload reduction for Marcus, additional supervision hours funded by reducing his direct service time, or a second SLP. Document that you raised it. If nothing changes, you are supervising at a level you cannot defend, and the students-not the schedule-absorb the risk.