Updates to Orders in the Standard Documentation Requirements

Published in Government Relations on January 02, 2020

From the Desk of Ronda Buhrmester:

Remember the final rule for ESRD/DMEPOS reference number CMS-1713-F that included changes to order requirements? While there was speculation as to what the ruling meant, we now have the final answer. The Standard Documentation Requirements (SDR) has been updated with the updates being effective January 1, 2020.

There are now two types of orders and 1 new acronym, standard written order (SWO) and Written Order Prior to Delivery (WOPD). Below is the information that can be found in the SDR:

STANDARD WRITTEN ORDER (SWO)
A SWO must be communicated to the supplier prior to claim submission. For certain items of DMEPOS, a written order is required prior to delivery (WOPD) of the item(s) to the beneficiary (see below).

A SWO must contain all of the following elements:

  • Beneficiary's name or Medicare Beneficiary Identifier (MBI). The beneficiary’s name is needed to verify the MBI.
  • Order Date, which means the date the referral was communicated to the supplier.
  • General description of the item
    • The description can be either a general description (e.g., wheelchair or hospital bed), a HCPCS code, a HCPCS code narrative, or a brand name/model number. The description needs to be detailed. If it’s genereic, the details must be in the medical record.
    • For equipment - In addition to the description of the base item, the SWO may include all concurrently ordered options, accessories or additional features that are separately billed or require an upgraded code. List each separately.
    • For supplies – In addition to the description of the base item, the DMEPOS order/prescription may include all concurrently ordered supplies that are separately billed. List each separately.
  • Quantity to be dispensed, if applicable. This applies to supply-type items, not DME.
  • Treating Practitioner Name or NPI. Legible identifiers still apply, so get the printed name.
  • Treating practitioner's signature

The SWO can be completed by the supplier. The treating practitioner needs to just review it and add their signature.

WRITTEN ORDERS PRIOR TO DELIVERY (WOPD)
A WOPD is a completed SWO that is communicated to the DMEPOS supplier before delivery of the item(s).

Pursuant to Final Rule 1713 (84 Fed. Reg Vol 217), CMS may select DMEPOS items appearing on the Master List of DMEPOS Items potentially subject to a Face-to-Face Encounter and WOPD requirement and include them on a Required List.

The Required List will be comprised of:
  • Statutorily required DMEPOS items such as Power Mobility Devices (PMDs); and
  • Additional DMEPOS items selected by CMS appearing on the Required List.

Items appearing on the Required List are subject to the face-to-face encounter and WOPD requirements. The required list will be released around March.

CMS and the DME MACs will post on their websites the Required List of the selected HCPCS codes, once published through the Federal Register Notice, and the Required List will be periodically updated.

Note that the face-to-face encounter and WOPD requirements are statutorily required for PMDs, and in accordance with this statutory obligation, both will continue to be required and will be included in any future publications of the Required List.

The date of the WOPD shall be on or before the date of delivery.

A WOPD must be completed within six (6) months after the required face-to-face encounter. PMDs no longer have the 45-day rule.

For PMDs, following the face-to-face encounter, the treating practitioner must complete the WOPD of the item pursuant to 1834(a)(1)(E)(iv).

I would like to explain the general description in more detail, specifically related to CPAP masks, because this has been an area that is both challenging and scrutinized in audits. According to what we have learned, the order can state “mask or CPAP mask.” However, the type of mask must be supported in the medical record (nasal mask or full-face mask). Suppliers struggle getting correct information documented within the medical record by the physician currently, so it will be tough to get the type of mask documented within the medical record. The best practice is to continue to indicate the type of mask on the order.

Click here to read the current Standard Documentation Requirements. Also, please note that the best practice is to continue gathering the necessary elements on the written orders (do not change orders).

Stay tuned for more information as we learn more.

Please reach out with questions or comments to Ronda Buhrmester at [email protected]


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  1. billing & reimbursement
  2. vgm government

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