2021 Medicare Guidelines Update on SWO and Frequency

On January 1, 2021, the new Medicare guidelines went into effect. It now requires that a Standard Written Order (SWO) must be communicated to a supplier before billing any durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) items. Before this new update requiring an SWO went into effect, a Detailed Written Order (DWO) was needed. As a result of Final Rule CMS-1713, these new guidelines changed DWO to SWO.

This article will provide you with additional information on the SWO and why frequency is still required for supply items.

SWO Requirements

The SWO can be completed by someone other than the practitioner (unless otherwise noted). However, the treating practitioner still needs to review and sign the SWO.

An SWO must contain the:

  • Beneficiary’s name or Medicare Beneficiary Identifier (MBI)
  • Order date
  • General description of the item, including:
    • Description – It can be either a general description, an HCPCS code, an HCPCS code narrative, or a brand name/model number.
    • Equipment – May include all other ordered options, accessories, or additional features separately billed or require an upgraded code (List each separately).
    • Supplies – The DMEPOS order/prescription may include all ordered supplies that are separately billed (List each separately).
  • Dispensed quantity 
  • Treating practitioner name or National Provider Identifier (NPI)
  • Treating practitioner’s signature

Click here to read a full summary of the new SWO requirements.  

Written Orders Prior to Delivery (WOPD)

A completed SWO passed onto a DMEPOS supplier before item delivery is a Written Orders Prior to Delivery (WOPD). DMEPOS items might be subject to a WOPD and Face-to-Face Encounter if the DMEPOS item is on CMS’s Required List.

The Required List will include:

  • Any statute required DMEPOS items (i.e., Power Mobility Devices)
  • Additional DMEPOS items selected by CMS on their Required List

Review CMS and DME MAC’s websites for the Required List of the selected HCPCS codes. It will be published once the items are added to the Federal Register Notice (the Required List will be updated regularly).

Frequency is Still Required for an SWO

Frequency is still required for supply items on an SWO. Even though the new SWO guidelines removed frequency from the requirement list, Medicare will still look to the medical records to ensure there’s support for the frequency being billed.

Where should the frequency be included?

The frequency either needs to be clear and listed on the SWO or in the medical records. Unfortunately, it’s not a common practice for practitioners or physicians to include frequency in the medical records.

Why is frequency still needed if it’s not on the SWO requirement list?

Frequency is how Medicare and Third-Party Payors reimburse suppliers. Medicare and Third-Party Payors want to see if the quantity of monthly supplies is truly medically necessary. Since the quantity of items doesn’t always equal the frequency, they need to see it listed either on the SWO or medical records.

The Supplier Manual Chapter 3 Section 4 states, “For any DME item to be covered by Medicare, the patient’s medical record must contain sufficient documentation of the patient’s medical condition to substantiate the necessity for the type and quantity of items ordered and for the frequency of use.”

SWO and Frequency

Overall, the new Medicare guidelines now require an SWO (instead of a DWO) before any DMEPOS items are billed. Although the SWO requirements don’t include frequency as a required item, it still needs to be included. The frequency can be on the SWO or in the medical record.

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