Reduce Provider Burden: Implement New Standard Written Order (SWO)
Kathleen D. Schaum, MS March 2020 APWH eNews
Information regarding coding, coverage, and payment is provided as a service to the Academy of Physicians in Wound Healing (APWH) members. Every effort has been made to ensure accuracy. However, APWH and the author do not represent, guarantee, or warranty that coding, coverage, and payment information is error-free and/or that payment will be received.
Many APWH members spend a significant amount of time creating plans of care and documenting (in each patient’s medical record) the medical necessity for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) for their patients to use in the home setting. Then they have to send a dispensing order to the DMEPOS supplier. Then before the DMEPOS supplier can submit a claim to Medicare, they must complete and sign one or more types of orders, that vary depending on the type of equipment and supplies ordered. Some equipment and supplies used at home require a detailed written order (DWO), others require a five-element order (5EO/written order prior to delivery (WOPD), others require a seven-element order (7EO), and many orders require a detailed product description (DPD).Therefore, most physicians and qualified healthcare professionals (QHPs) find it difficult to remember which elements to include in their orders for the various products that they order for home use.
To reduce provider burden, on January 1, 2020, the durable medical equipment (DME) Medicare administrative contractors (MACs), Noridian Healthcare Solutions and CGS Administrators, updated their Local Coverage Article (LCA): Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426)[i]. This updated LCA, which is attached to all of the DME MAC Local Coverage Determinations (LCDs), implemented a standard written order (SWO) format that physicians and QHPs should follow when ordering equipment and supplies covered for use in the home.
The new SWO only requires 6 elements:
- Beneficiary’s name or Medicare Beneficiary Identifier (MBI)
- Order date
- 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
- 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 that require an upgraded code (List each separately).
- For supplies – In addition to the description of the base item, the SWO may include all concurrently ordered supplies that are separately billed (List each separately)
- Quantity to be dispensed, if applicable
- Treating practitioner name or National Provider Identifier (NPI)
- Treating practitioner’s signature
- Stamps are not allowed for signatures
- Signatures must comply with the CMS signature requirements[ii]
The SWO must be dated before the DMEPOS supplier submits a claim to Medicare, unless the equipment/supply is subject to the written order prior to delivery (WOPD) requirements. For physicians and QHPS who are also DMEPOS suppliers, the 6 required elements of the new SWO must be documented in their patients’ medical records, but a separate SWO is not required.
When a face-to-face encounter and a WOPD are required, the SWO may act as the WOPD, but the SWO must be completed and sent to the DMEPOS supplier before the supplier can deliver the item(s) to the Medicare Beneficiary. In the spring of 2020, the Centers for Medicare & Medicaid Services (CMS) and the DME MACs will post, on their websites, a Master List of the DMEPOS items that are subject to a face-to-face encounter and a WOPD.
In case you are wondering if the new SWO can take the place of order requirements mandated by federal and state laws, by National Coverage Determinations (NCDs) and LCDs, and by Local Coverage Articles (LCAs), the answer is “no”. Those unique order requirements must still be followed by physicians and QHPs when they document in the patient’s medical record and write orders for the DMEPOS supplier. However, the DME MACs are currently in the process of updating the LCDs and LCAs to incorporate the SWO, when it is appropriate.
Following are 5 steps that physicians and QHPs should take to incorporate the new SWO elements into their medical record documentation and ordering processes:
- Read the updated LCA
- Incorporate the SWO elements into medical record documentation and into electronic medical record templates
- Complete SWOs for DMEPOS suppliers to align with the SWO in the patient’s medical record
- Read pertinent NCDs, LCDs, and LCAs to learn which ones now align with the new SWO requirements and which ones still have unique order requirements that are above and beyond the SWO elements
- Monitor the DME MAC’s website for the publication of the Master List of equipment and supplies that will require a face-to-face encounter and a WOPD before the DMEPOS supplier can deliver the item(s) to the Medicare beneficiary.
[i] Local Coverage Article: Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426): https://www.cms.gov/medicare-coverage-database/details/article-details.aspx?articleId=55426&ver=72&Date=02%2f10%2f2020&DocID=A55426&bc=ggAAAAgAAAAA&
[ii] Program Integrity Manual, Chapter 3, Section 220.127.116.11: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c03pdf.pdf
Kathleen D. Schaum is the president of her own consulting business for
wound/ulcer management reimbursement strategy. She serves as a consultant
and educator for professionals, provider-based departments, manufacturers,
and professional societies. She lectures at many regional/national
symposiums and authors columns in 2 medical journals. She was recently
identified by Expertscape as a world expert for healthcare reimbursement and
is in the top 0.051% of 29,342 published authors worldwide from 2010 through