On January, 1 2020, CMS made it effective that only one type of order is needed for DMEPOS claims, in an effort to help reduce supplier and provider burden. As such, the preliminary/dispensing order, Detailed Written Order (DWO), Five Element Order (5EO)/Written Order Prior to Delivery (WOPD), Seven Element Order (7EO), and Detailed Product Description (DPD) are no longer needed for DMEPOS and have been replaced by a Standard Written Order (SWO).
With limited details provided in the DME MACs' publication, suppliers were left scratching their heads and timid to make any changes that would eliminate familiar, often times burdensome, documentation.
Nearly two weeks have passed since the SWO was introduced, and there are still several unanswered questions. The van Halem Group has been working with industry stakeholders and the DME MACs to understand the new requirements and make sense of it all. Here is what we know so far...
There is one order that has six required elements:
- Beneficiary name or MBI
- Order date
- This is the date you communicate with the practitioner ordering the equipment/supply
- General description of the item
- The base item does not have to be on the same order as the options, accessories or additional features
- Each supply that will be separately billed will need to be listed
- CPAP mask without being specific is now allowed however you would not want to list all types of mask as that would be considered a blanket order.
- Quantity, if applicable
- If > than 1, must be indicated
- Treating practitioner name or NPI
- Treating practitioner signature
Is a Dispensing Order still required?
Although the dispensing order requirement has been removed, you still have to have communication with the ordering practitioner of what is being ordered.
For recurring supplies, you are able to dispense the quantity listed on the order ongoing.
How often should a new order be obtained?
The order is considered valid for Medicare indefinitely, however, you must check with your state licensure requirements as to when a new order is required. If something changes on the order, a new order must be obtained, as previously required.
New order requirements for Medicare have not changed. You will need a new order for all claims for purchase or initial rentals, change in order, when indicated in the medical policy, replacement, change in supplier if the new supplier isn’t able to obtain a valid order and documentation from the original supplier.
You must follow LCD order requirements as previously required.
Utilization and reimbursement
Reimbursement will be based on the specific utilization amount supported in the medical records.
If you are providing more than a one month supply, include a narrative in the NTE segment of the electronic claim indicating the number of months you are billing.
What about the items on the ACA list?
The ACA listed items that required a face to face and written order prior to delivery (WOPD) are not in effect other than power mobility devices (pmd), which must have a face to face examination and the SWO completed by the treating practitioner prior to delivery. The WOPD must be completed within 6 months of the face-to-face evaluation.
CMS will create a required list from their master list which will instruct us of the items that will require a WOPD and face-to-face evaluation similar to the ACA list. The required list should be published this spring. Until then, you must obtain the SWO prior to billing for all but the PMDs - which require the SWO prior to delivery.
The decision to change your processes now versus waiting until the required list is posted is one that may vary based upon the needs of your organization.
Can we really eliminate the DPD?
The detailed product description (DPD) is no longer required for PMD options/accessories. Once you obtain the SWO for the base wheelchair, you as the supplier are able to create another SWO that includes all the options/accessories previously listed on the DPD and send back to the treating practitioner to review and sign. This eliminates the practitioner from having to list all the options/accessories since they rely on the expertise of the supplier and licensed/certified medical professional. These orders must be obtained prior to delivery of the wheelchair.
What do we do now?
There is no need to obtain a new order if you have a valid order currently simply because of the new SWO.
Noridian has conducted webinars regarding the new order requirements and plans on publishing a Q&A summary of their educational sessions. They anticipate this being made available on their website in the coming weeks.
We will continue updating you as we learn more information.