Standard Written Order (SWO)

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.

• Noridian Medicare Website (https://med.noridianmedicare.com)• CMS Website (https://www.cms.gov)

February 2020 Noridian DME Outreach and Education 2

https://med.noridianmedicare.com/

https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance%20-Programs/CERT/Downloads/AppendicesMedicareFee-for-Service2016ImproperPaymentsReport.pdf

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– 1 AAPC CEU is offered for this course– CEU and presentation PDF available in the Handouts

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Asking a Verbal Question


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How to Ask a Written Question

February 2020 7Noridian DME Outreach and Education

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Agenda• Comprehensive Error Rate Testing (CERT)• Order Requirements• Pre-Submitted Questions• Questions• Resources and Reminders


10February 2020 Noridian DME Outreach and Education

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)

https://www.cms.gov/files/document/2019-medicare-fee-service-supplemental-improper-payment-data.pdf

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


Standard Documentation Requirements Article


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


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


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


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


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


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


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.


https://www.cms.gov/files/document/esrd-qip-final-rule-2019-24063.pdf-0

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


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


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


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


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


PMD Order


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


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


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


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.


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.


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.


Question 4Q – What is the transition period for the conversion?

A – SWO is effective 1/1/2020. There is no official transition date.


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.


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.


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.


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.


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.


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.


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.


Question 12Q – Is date stamping the SWO a requirement?

A – It is not required but would be a good business practice.


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.


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.


Questions?


• To ask a verbal question:– Click on the hand icon

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Asking a Verbal Question


• From the access panel

• Type your question into the Questions field– Be concise

• Click “Send”

How to Ask a Written Question

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Noridian Website Experience Survey

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


MBI Lookup Tool• Allows providers/suppliers to look up MBI when

it cannot be obtained from patient• Input values

– First name – Last name– Date of Birth (DOB)– Social Security Number (SSN)

• Patient’s SSN may be different than Health Insurance Claim Number (HICN) they currently receive benefits under

• Users will need to complete “I am not a robot” verification for every five transactions


Submitting Appeals through Noridian Medicare Portal (NMP)


Enter HCPCS code then click check

Potential modifiers display for code entered


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


PDAC – Palmetto GBA• Contact Center - 877-735-1326• Hours of Availability: 9:30 am - 5 pm EST,

Monday - Friday• Fax: 803-264-0648• Email Contact Form

– https://www.dmepdac.com/palmetto/Feedback.nsf/Feedback?OpenForm&SendTo=04

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PDAC Contact Information cont.

• Mailing AddressPalmetto GBAPO Box 100320Columbia, SC 29202-3320

• Certified/Courier MailingsPalmetto GBAAttn: PDAC, AG-2502300 Springdale Drive, Building OneCamden, SC 29020-1728


Targeted Probe and Educate (TPE)• Goal is to improve claims payment error rate

– Reduce volume of appeals• Existing data analysis determines supplier to review

– Claims with greatest financial risk– High error rates that vary from peers

• Written notification sent to suppliers• 10 claim preview

– Zero errors• TPE closed• Supplier PTAN excluded 1 year for HCPCS Codes

– Any errors• Round 1 continues

• Review of 20-40 claims• One on one education to address errors• Up to three rounds of probe reviews


DME on Demand and Medicare Midterms

• Available 24/7• Self-paced tutorials• General and policy-

specific topics• Include completion

certificate• Recommended for

new hire and on-going staff training

• Medicare Midterms– Short quizzes– Test your retention of

the DME on Demand content

• Education & Outreach > DME on Demands



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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


http://www.medicaredmeappeals.com/

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


http://www.medicaredmeappeals.com/


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


Questions?

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Documents

Standard Written Order (SWO)