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Updates To Orders In The Standard Documentation Requirements

From the Desk of Ronda Buhrmester:

Remember the final rule for ESRD/DMEPOS reference number CMS-1713-F that included changes to order requirements? While there was speculation as to what the ruling meant, we now have the final answer. The Standard Documentation Requirements (SDR) has been updated with the updates being effective January 1, 2020.

There are now two types of orders and 1 new acronym, standard written order (SWO) and Written Order Prior to Delivery (WOPD). Below is the information that can be found in the SDR:

A SWO must be communicated to the supplier prior to claim submission. For certain items of DMEPOS, a written order is required prior to delivery (WOPD) of the item(s) to the beneficiary (see below).

A SWO must contain all of the following 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 NPI
  • Treating practitioner's signature

A WOPD is a completed SWO that is communicated to the DMEPOS supplier before delivery of the item(s).

Pursuant to Final Rule 1713 (84 Fed. Reg Vol 217), CMS may select DMEPOS items appearing on the Master List of DMEPOS Items potentially subject to a Face-to-Face Encounter and WOPD requirement and include them on a Required List.

The Required List will be comprised of:
  • Statutorily required DMEPOS items such as Power Mobility Devices (PMDs); and
  • Additional DMEPOS items selected by CMS appearing on the Required List.

Items appearing on the Required List are subject to the face-to-face encounter and WOPD requirements. 

CMS and the DME MACs will post on their websites the Required List of the selected HCPCS codes, once published through the Federal Register Notice, and the Required List will be periodically updated.

Note that the face-to-face encounter and WOPD requirements are statutorily required for PMDs, and in accordance with this statutory obligation, both will continue to be required, and will be included in any future publications of the Required List.

The date of the WOPD shall be on or before the date of delivery.

A WOPD must be completed within six (6) months after the required face-to-face encounter.

For PMDs, following the face-to-face encounter, the treating practitioner must complete the WOPD of the item pursuant to 1834(a)(1)(E)(iv).

The new requirement allows for the either the patient’s name or MBI and either the practitioners signature or NPI.

Click here to read the current Standard Documentation Requirements

Stay tuned for more information as we learn more.

Please reach out with questions or comments to Ronda Buhrmester at [email protected]





  • Sharon Briggman | Jan 3rd 2020 @ 2:02 PM

    I would LOVE to attend!! How can one attend if they're a non-member? Thank you

  • Tim Van | Jan 6th 2020 @ 3:52 PM

    Scratching my head...oxygen, diabetic shoes, APMs, wound care...Just need SWO? I get the wopd... but ? Is this required if we collect info other ways and other documents, are rejections to follow? Head still hurts.

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