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By Carrie Nienberg, RN, Director of Clinical Operations

Currently, Policy Article A52498, revised on 01/01/20, indicates a face-to-face encounter must occur within six months prior to the order date on the Standard Written Order (SWO). If the beneficiary had a licensed/certified medical professional (LCMP) evaluation as part of the face-to-face encounter to support the need for the equipment, the 6-month period begins when the treating practitioner signs and dates the LCMP encounter.

In the Final Rule CMS-1713-F SWO FAQ published 03/12/20, the medical directors indicate that the 6-month timeframe begins when the face-to-face encounter with the treating practitioner occurs . The final rule defines the face-to-face encounter to be between the beneficiary and either an MD, DO, PA, NP or CNS. It made no allowance to reset the timeframe to after the LCMP evaluation occurs.

To be clear, the 6-month timeframe is within the 6 months prior to the SWO being written when the practitioner had a face-to-face encounter. If an LCMP evaluation is performed and used to support medical necessity, it must be within this same 6-month timeframe and the order cannot be written until the LCMP report is signed, dated and indicates agreement/disagreement.

The PMD policy article will be updated soon to reflect this updated guidance.

If you have questions about the new SWO requirements we're here to help. Contact Us today!