'Wiser' CMS executes new order

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Friday, January 10, 2020

WASHINGTON – Industry stakeholders are cautiously optimistic that CMS’s new standard written order will streamline documentation and reduce denials for HME.

Noridian, a DME MAC, posted an update to its website last week saying that the SWO would be the only type of order needed for DMEPOS claims starting with dates of service Jan. 1, 2020.

“I think we’re seeing a wiser CMS stepping into the 21st century,” said Andrea Stark, a reimbursement consultant for MiraVista. “The industry supports looking to the medical record to determine medical necessity and not using administrative processes to logjam cash flow. That is what the order is and has become—a nitpicky way to deny payments.”

The SWO, which was included in the final ESRD rule published in November, replaces four other types of orders: the preliminary/dispensing order; the detailed written order; the five element order/written order prior to delivery; and the seven element order and detailed product description.

Stakeholders are now waiting for “the dust to settle,” Stark says. When CMS previously removed the start date requirement, for example, the agency and the MACs continued to require a “preparation date” in addition to the “order date” when the order was prepared by someone other than the physician.

“We’ll see if the sub-regulatory guidance and the Program Integrity Manual truly embrace this simplified order without reservation, modification, or caveats,” she said.

Stakeholders have also inquired with Noridian on certain “gray areas.” For example, certain HME selected by CMS will appear on a “required list” and will still be subject to face-to-face and written order prior to delivery requirements, but that list, at press time, hasn’t been published.

“Which items need a SWO vs. a face to face and WOPD,” said Kelly Grahovac, general manager of The van Halem Group. “I’d caution that, for right now, it’s business as usual, with suppliers following the instructions in the LCDs, where appropriate. I would suggest making sure orders contain all of the required elements of the SWO and, hopefully, we will get more details from CMS soon.”

There may be a few kinks to iron out, but that doesn’t take away from the fact that this is a “huge win” for the industry, says Kim Brummett, vice president of regulatory affairs for AAHomecare.

“This makes it a lot easier for providers and prescribers to comply,” she said. “A huge audit issue has been eliminated by having just one or fewer elements. We’ve been after them for this for a long time.”