In a revised joint publication issued by the MACs last week, CMS clarified their position on what is required to deliver equipment under the Affordable Care Act (ACA) Face-To-Face (FTF) Rule. Since the beginning, the MACs have educated that a fully compliant detailed written order (DWO) with an NPI and date stamp was required to DELIVER any product subject to FTF. The final rule, published in November of 2012, clearly outlined a minimal 5 element order for HCPCS subject to the FTF rule, but the MACs (and CMS) implicitly directed suppliers that a full DWO was required. With this recent clarification, however, it is now CMS’s intent that the MACs require suppliers to secure a minimum, five element order (5EO) prior to dispensing items addressed in the FTF/ACA rule. The simplified, 5EO must include:
The 5EO must be date stamped to document the receipt date by the supplier prior to delivery. Still, prior to BILLING suppliers must continue to secure a fully detailed written order to be in compliance.
- the beneficiary’s name,
- the item of DME ordered,
- the NPI of the prescribing physician/practitioner,
- the signature of the prescribing physician/practitioner, and
- the date of the order.
The 5EO must be date stamped to document the receipt date by the supplier prior to delivery. Still, prior to BILLING suppliers must continue to secure a fully detailed written order to be in compliance.
So should you loosen the reigns and start accepting 5EOs? No. Just as suppliers have effectively done away with reliance on verbal orders due to exposure points, we do not recommend suppliers adopt a 5EO protocol. A 5EO forces multiple communications with your referral sources which in turn forces payment delays. The DWO prior to delivery remains the gold standard…enabling you to collect everything you need to both deliver and bill while the quid pro quo still exists. If you secure a compliant DWO, you will be able to immediately release your claim for reimbursement upon delivery.
We do recommend, however, that you leverage this new education through your appeal endeavors. Many of you have received audit denials for invalid DWOs that were missing elements required on a DWO but frequently missing from dispensing orders (like frequency of replacement, method of delivery, quantity, etc.). If your dispensing order contains the required five elements and was properly date stamped, then you can contact the MAC about reopening options. You will still need to document a compliant DWO post-delivery (and prior to billing) to fully take advantage of this newly opened documentation lane.
More education is being released from the MACs on this topic, but suffice it to say this 5EO requirement is a much lower standard for delivery than previously directed. Thankfully, this is one of the few and welcome directives that puts suppliers in a position to have more documentation than required.
We do recommend, however, that you leverage this new education through your appeal endeavors. Many of you have received audit denials for invalid DWOs that were missing elements required on a DWO but frequently missing from dispensing orders (like frequency of replacement, method of delivery, quantity, etc.). If your dispensing order contains the required five elements and was properly date stamped, then you can contact the MAC about reopening options. You will still need to document a compliant DWO post-delivery (and prior to billing) to fully take advantage of this newly opened documentation lane.
More education is being released from the MACs on this topic, but suffice it to say this 5EO requirement is a much lower standard for delivery than previously directed. Thankfully, this is one of the few and welcome directives that puts suppliers in a position to have more documentation than required.
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