standard written order (swo)
TRANSCRIPT
Presented byNoridian DME Outreach and Education
February 2020
Standard Written Order (SWO)
DisclaimerThis information release is the property of Noridian Healthcare Solutions, LLC. It may be freely distributed in its entirety, but may not be modified, sold for profit or used in commercial documents. The information is provided “as is” without any expressed or implied warranty. While all information in this document is believed to be correct at the time of writing, this document is for educational purposes only and does not purport to provide legal advice. All models, methodologies and guidelines are undergoing continuous improvement and modification by Noridian and the Centers for Medicare & Medicaid Services (CMS). The most current edition of the information contained in this release can be found on the Noridian website and the CMS website. The identification of an organization or product in this information does not imply any form of endorsement. CPT codes, descriptors, and other data only are copyright 2020 American Medical Association (or such other date of publication of CPT). All Rights Reserved. Applicable FARS/DFARS apply.
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Agenda• Comprehensive Error Rate Testing (CERT)• Order Requirements• Pre-Submitted Questions• Questions• Resources and Reminders
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https://www.cms.gov/files/document/2019-medicare-fee-service-supplemental-improper-payment-data.pdf
Service Type Improper Payment Rate Projected Improper Payment Amount
Overall 7.25% $28.91 B
Part A Providers (excluding Hospital Inpatient Prospective Payment System (IPPS))
8.07% $13.34 B
Part B Providers 8.64% $8.66 B
DMEPOS 30.7% $2.44 B
Hospital IPPS 3.57% $4.47 B
• 2019 Improper Payment Rates and Projected Improper Payment
Comprehensive Error Rate Testing (CERT)
Order Requirements
Standard Documentation Requirements
• Significant updates effective January 1, 2020• Article A55426• Applicable to all Durable Medical Equipment,
Prosthetics, Orthotics, and Supplies (DMEPOS) items
• Noridian Website > Policies > Active LCDs > Standard Documentation Requirements Policy Article – A55426
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Standard Documentation Requirements Article
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Dates of Service (DOS) on or AFTER January 1, 2020
• Standard Written Order (SWO)– Eliminates Detailed Written Order (DWO)– Eliminates Five Element Order (5EO)– Eliminates Seven Element Order (7EO)– Eliminates Detailed Product Description (DPD)
• SWO required prior to billing for all DMEPOS not subject to WOPD requirements– SWO date must be on or prior to billing date
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Standard Written Order (SWO) Elements
• SWO 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 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– Treating practitioner name or National Provider Identifier (NPI)– Treating practitioner’s signature
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Order Date• Date medical need for item was communicated
to supplier (call, fax, prescription)• Needs to be dated before billing claim to
Medicare• Words “order date” do not need to be on SWO
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SWO Quantity• Accessories/Supplies
• Quantity is required • Example – 120 per/month, 2 boxes, etc.
• Drugs• Quantity is required. Must indicate amount prescribed
• Example - 31 units/month and as needed, 465 mg/month
“PRN” or “OR as needed” are not acceptable
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When is a New Order Required?• For all claims for purchase or initial rentals• Change in order• When indicated in the medical policy• Replacement• Change in supplier
– If new supplier is unable to obtain valid order and documentation from original supplier
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Written Order Prior to Deliveryand Face-to-Face Evaluation
• CMS Final Rule 1713 created Master List of codespotentially subject to:• Written Order Prior to Delivery (WOPD) and Face-To-Face
Evaluation and/or Prior Authorization• Required List is a subset of codes from the Master List and
will always include PMDs since WOPD and Face-To-Face are mandated in statute (1834(a)(1)(E)(iv)).
• CMS will publish the Required List in Federal Register sometime in near future– Required List items will be subject to WOPD and Face-To-Face
evaluation– Required List will be posted on CMS and DME MAC websites
• Until Required List is published and final in the Federal Register, only PMDs are subject to WOPD and Face-To-Face evaluation
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Master List: Possible WOPD/F2F and/or Prior Authorization
HCPCS that appear in the Master List:• https://www.cms.gov/files/document/esrd-qip-final-rule-2019-24063.pdf-0
• Items within this list could potentially appear on the forthcoming Required List for WOPD and Face-to-Face evaluations and/or Prior Authorizations.
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Face-to-Face Requirements (2)
• Qualifying F2F will be required:– For every new order/prescription of item on “Required
List”• One qualifying F2F may be used for multiple
DMEPOS orders if:– F2F is within 6 months of the order, and
• F2F must support payment for item(s) ordered• Supporting documentation must be beneficiary specific• Supporting documentation must include subjective and
objective assessment
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Miscellaneous Information• Date of the SWO must be on or prior to date of claim
submission– Exception: Items requiring WOPD
• “PRN” orders remain insufficient to justify payment• Exception to SWO for prescribing practitioners who
are also suppliers– SWO not required– Medical record must contain all elements of SWO
• Signature and date stamps remain not allowed• Prescriptions still not considered part of medical
record
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Review• DOS prior to 1/1/2020
– DWO required prior to billing for all DMEPOS
– 5EO required prior to delivery for ACA items
– 7EO required prior to delivery for power mobility
– DPD required for power mobility
– F2F required within 45 days of order for power mobility
– F2F required within six months of order for ACA items
• DOS on/after 1/1/2020– SWO required prior to
billing for all DMEPOS– SWO required within 6
months of the F2F date and prior to delivery for PMD
– SWO required prior to delivery for items listed on “Required List” – when published
– F2F required within 6 months prior to SWO for items on “Required List” –when published
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Power Mobility Devices (PMD)• Face to Face requirements still apply
– Treating practitioner must complete F2F and WOPD• WOPD applies
– Must be completed by treating practitioner before item dispensed
– Signed within 6 months of face to face– Date stamps no longer required
• Good business practice to show receipt
• Former Detailed Product Description (DPD)– No longer needed – Can serve as SWO if all required elements included
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PMD Face-to-Face (F2F)
DOS Prior to 1/1/2020• F2F discussing PMD need• LCMP evaluation after office
visit – Concurrence date = F2F
date• LCMP evaluation prior to
office visit– Office visit = F2F date
• Office visit, LCMP evaluation, Office visit– Last office visit = F2F
DOS After 1/1/2020• F2F discussing PMD need
– Will always be F2F date– Six month window begins
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PMD Order
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PMD Orders (2)
• SWO may have general description– Power wheelchair– List all accessories that are separately billed
• Accessories may be on same SWO as Base• Accessories may be on separate SWO from
Base• For SWO with general accessory description
– Second SWO with detailed description of all separately billed
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PMD Detailed Product Description (DPD)
DOS Prior to 1/1/2020• Created and dated by supplier
on or after 7EO• Reviewed, dated and signed
by treating practitioner• Contains
– Specific HCPCS for base and all options and accessories to be separately billed
– Narrative description of items or manufacturer information
– Practitioner signature & date– Date stamp to document receipt
DOS After 1/1/2020• No longer required
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PMD Prior Authorization Impact• Documentation to submit
– Completed coversheet– Face to Face assessment– Standard Written Order (SWO)– LCMP Specialty Evaluation– Financial Attestation Statement– Evidence of RESNA ATP involvement and certification– Other relevant medical documentation
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Pre-submitted Questions?
Question 1Q - What if the prescription is printed from a DME it has Dr. Smith, name and NPI and then Dr. Wesson, lines through and signs the prescription?
A - As long as Dr Wesson amends the order following the record keeping principles and adds his/her name or NPI it would be acceptable.
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Question 2Q - Are HCPCS required on the SWOs?
A – 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.
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Question 3Q - If the prescription is for dispensing, does it require an NPI?
A – Technically, there is no dispensing order anymore. A communication from the physician to the supplier is all that is needed. The NPI is not required at initial communication. The SWO must contain the physicians name or NPI.
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Question 4Q – What is the transition period for the conversion?
A – SWO is effective 1/1/2020. There is no official transition date.
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Question 5Q – When will the LCD be updated?
A – The Standard Documentation Requirements Article A55426 has been updated which should be used in conjunction with the LCD. The DME Medical Directors are working to update policy specific LCDs as necessary.
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Question 6Q – How do we find the new master list that require the face to face evaluation within 6 months of ordering?
A – The required list hasn’t been released by CMS yet. Until then, the only face to face requirements are for Power Mobility Devices (PMDs). When released, the face to face will be required within 6 months prior to the SWO.
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Question 7Q - Does the SWO need to be completed entirely by the Prescriber (Similar to the Prior 7EO Requirement) with regard to PMD's?
A – Yes, the SWO needs to be completed entirely by the prescriber for PMD’s.
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Question 8Q – What difference does the SWO make for the suppliers?
A – Reduction in requirements of what needs to be documented on the order. One standard order instead of several different variations depending on DMEPOS.
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Question 9Q – Frequency has been removed. If SWO shows supply with quantity of 4, is it only good for 4 refills?
A –The order will be good for the quantity indicated, each month until a new order is received.
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Question 10Q – If an order was received in December and refills would occur in January or after, is a new order needed?
A – No, a new order is not needed as long as the prior order was valid.
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Question 11Q – Can we use multiple SWOs to support our claims (e.g., one for pumps supplies and another for drug)?
A – Yes, multiple orders can be used as the accessories/supplies are not required to be on the same order as the base equipment.
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Question 12Q – Is date stamping the SWO a requirement?
A – It is not required but would be a good business practice.
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Question 13Q – Should we get chart notes with SWO?
A – The practice of obtaining medical information during the intake process has not changed and should continue.
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Question 14Q – What items will need a Certificate of Medical Necessity (CMN)?
A – The CMN requirements were not changed. For those that use the CMN as the order, the CMN must be fully completed.
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Questions?
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• To ask a verbal question:– Click on the hand icon
to the left of the access panel
Asking a Verbal Question
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• From the access panel
• Type your question into the Questions field– Be concise
• Click “Send”
How to Ask a Written Question
Resources and Reminders
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MBI as of January 1, 2020• All claim submissions• Certificates of Medical Necessity (CMN)• DME Information Forms (DIF)• Advanced Determination of Medicare Coverage
(ADMC)• Prior Authorization requests• Correspondence
– Reopenings– Redeterminations– Written Inquiries
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• Patient’s SSN may be different than Health Insurance Claim Number (HICN) they currently receive benefits under
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Submitting Appeals through Noridian Medicare Portal (NMP)
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Enter HCPCS code then click check
Potential modifiers display for code entered
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New Modifier Lookup Tool
NMP CERT Lookup Tool• CERT review look up status available on the
Noridian Medicare Portal• Decision and full error details available• Know where your claim is in the CERT review
process• Instructions regarding this new feature are
located at:– Noridian Medicare Website > Browse by Topic >
Noridian Medicare Portal (NMP) > CID Status Lookup
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PDAC Contact Information cont.
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ReconsiderationMaximus Federal Services, Inc.
• QIC Contractor• Starting September 1, 2019• Mailing Address
MAXIMUS Federal QIC – DME Project 3750 Monroe Avenue, Suite 777 Pittsford, NY 14534
• Website– http://www.medicaredmeappeals.com
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QIC Formal Telephone Discussion Demonstration & Reopening Process
• Participate in formal recorded telephone discussion with QIC contractor
• Discuss facts of the case• Provide additional documentation• Receive feedback/education on CMS policies and
requirements• Open to all DME Jurisdictions, with the exception of
reviews of glucose supplies for JA and JB
For more information visit http://www.medicaredmeappeals.com
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QIC Formal Telephone Discussion Demonstration & Reopening Letter
Interactive Voice Response (IVR) Enhancements
• Suppliers will see an enhanced Interactive Voice Response (IVR) as of December 13, 2019
• Upgrades to the IVR include:– Expansion on same and similar services– Provider details on home health and hospice services– Inpatient discharge status details– Advance Determination of Medicare Coverage (ADMC) information– Claim Denial Details
• IVR User Guide has been updated and is located under: – Tools – IVR Conversion Tool
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Questions?
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