Several colleagues have recently been hit with audit denials for an incomplete or absent Standard Written Order (SWO). Why can’t Medicare get this right?
A Standard Written Order in DME parlance is like a fancy prescription whereby the provider(prescriber) writes an order for the device being ordered, along with the patient’s information, the date it is needed and other information typically found in a laboratory order.
Specific information on a SWO is located in the Medicare Internet Only Manual (MIOM) as well the AFO LCD. However, there is a little-known fact that if the provider is also the prescriber, there is no need for a separate SWO. It would be as though you wrote an order to yourself to provide a service or DME device to your own patient.
Both the AFO LCD and the MIOM stipulate that in the limited instances where the provider writing the prescription is also the supplier a separate SWO is not required, so long as the elements of the SWO are in the chart.
Let’s look at three questions:
- What exactly is needed to fulfill this requirement?
The patient’s name and some demographics.
Your name and signature.
A general description of the items being provided (e.g. Pneumatic Cam Boot OTS, or HCPCS Code or a brand or model number)
Date of the order
Quantity (this would apply to shoes and surgical dressings);
2. Why are there so many failures for a lack of a SWO?
The reason given is that the overwhelming majority of DME claims are not provided by the prescriber but filled by another provider other than the ordering/referring physician. Hence the auditors are keying in on looking for a SWO. Unfortunately, you may need to politely educate the auditor or claim representatives by providing them with the language right from the MIOM or AFO LCD.
3. There are two suggestions for avoidance of failure to have a SWO in the future?
A. One may choose to include the language from the MIOM in your chart and in any return
correspondence to a Medicare contractor is encouraged.
B. Second and less popular is to create your own SWO, in particular for a custom
fabricated item, directly from the laboratory order. Simply write the words Standard
Written Order on the laboratory order and be sure that all the elements in #1 are inclusive.
Personally I (and most other physicians) abhor additional paperwork and the possibility of having conflicting information makes 3B not the best option.
Recently a colleague had a redetermination at the carrier level denied due to a lack of SWO for a custom fabricated AFO The advice provided was to respond to the reconsideration (QIC) carrier is to direct the auditor to the policy language from the MIOM and the AFO LCD obviating the need for a SWO and to emphasize that the elements of the SWO were in fact in the patient’s chart (which were circled).
