Medicare DWO Requirements: DWO & SWO What You Need to Know

Detailed Written Orders (DWO) were necessary when you billed a claim to Medicare, but as of January 1, 2020, DWOs were replaced with Standard Written Orders (SWO)—making it essential to note that Medicare DWO requirements have been replaced with Medicare SWO requirements. 

This article will help you understand SWOs, what information you’ll need to include in one, and what to do when DMEPOS items require Written Order Prior to Delivery (WOPD) and Face-to-Face Encounter documentation. 

Difference Between Medicare DWO and SWO 

As a result of the Final Rule CMS-1713, the Centers for Medicaid and Medicare Services (CMS) made the decision to change DWOs to SWOs in 2020. Since the Final Rule CMS-1713, all mentions of DWO have been removed from the CMS website. So, if you’re looking for information on Medicare DWO requirements, you’ll need to review their Medicare SWO requirements. 

Additional Changes in 2021

When the initial change from DWO to SWO occurred, there were a few differences between them. Then in 2021, Medicare no longer required frequency. However, it still needs to be included in the documentation either on the SWO or in the patient’s medical record. Read more about the 2021 changes.

Items to Include in the Medicare SWO Requirements

Medicare’s SWO requirements include the following (source): 

  • Beneficiary’s name or the Medicare Beneficiary Identifier (MBI)
  • Order date
  • Item description can include:
    • A general description (i.e., wheelchair)
    • HCPCS code (i.e., K0108)
    • HCPCS code narrative (i.e., wheelchair component or accessory)
    • Brand name/model number
  • For equipment and supplies, list each item separately:
    • Concurrently ordered options
    • Accessories 
    • Additional features (separately billed or require an upgrade) 
  • Item quantity dispensed
  • Treating practitioner name or National Provider Identifier (NPI)
  • Treating practitioner’s signature

Note that you might want to check your state law or regulation since some states may have additional conditions for an order/prescription element. 

WOPD and Face-to-Face Encounters Equipment 

When placing orders for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS), it may require you to comply with additional conditions to receive payment. That’s when WOPD or Face-to-Face Encounters might be necessary. When a DMEPOS item needs more than an SWO, you’ll have to complete specific requirements before delivering the order to the patient. 

Review all the equipment that requires WOPD or Face-to-Face Encounters.

WOPD Requirements 

When an item requires WOPD, you’ll need a complete order before it’s delivered. 

Face-to-Face Requirements 

The following criteria need to be met for all Face-to-Face Encounters.

  • A practitioner will visit the patient within six months preceding the order.
  • During the visit, the practitioner must gather subjective and objective information regarding diagnosing, treating, or managing a clinical condition.
  • Document the encounter in the medical record (i.e., physical examination, diagnostic tests, progress notes, treatment plans, etc.), and it must be subjective and objective. If the visit occurs through telehealth, you must meet the requirements and pay for the telehealth services. 
  • Ensure the written order, prescription, and additional documentation are on file and easily available to CMS and its agents upon request.

Maintain Medicare Billing Compliance with Medbill 

At Medbill, our team regularly monitors industry changes and policies, which allows us to ensure our clients maintain their DME billing compliance. 

Contact us to learn how we can help with your billing needs!