CGS Provider Outreach confirmed date stamps will no longer cause failures in audits of 5EOs for items subject to ACA.
CMS updated the policy article titled Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426). Until May 24, 2017 the now superseded policy article contained the following paragraph in relation to “Standard WOPD” requirements:
“A WOPD must meet the requirements described above for a DWO. The WOPD must be both signed and dated by the prescribing physician before the item is dispensed. The supplier must have received the WOPD before dispensing the item. A date stamp or equivalent must be used by the supplier to document receipt date.”
CMS removed this language from the current policy article. MiraVista presumes CMS made the change because the statute never directly imposed the requirement. Per section 410.38 of the Code of Federal Regulations, the following items are required of a 5EO:
Suppliers are required to secure a 5EO prior to delivery. To satisfy the “date of the order” being on or before the date of delivery, the DME MACs will now base timeliness on the date of the order. Suppliers must still secure a Detailed Written Order before billing the claim for reimbursement. To prevent reimbursement delays, MiraVista recommends suppliers only dispense product after securing the detailed written order.
Internal date stamping has been a burdensome and problematic administrative protocol. The shift to leverage elements that are naturally on the order (instead of artificially imposed for administrative purposes) will make it easier to pass audits and validate timely orders. Continue if you wish, but you have our blessing to do away with this unnecessary step!
CMS updated the policy article titled Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426). Until May 24, 2017 the now superseded policy article contained the following paragraph in relation to “Standard WOPD” requirements:
“A WOPD must meet the requirements described above for a DWO. The WOPD must be both signed and dated by the prescribing physician before the item is dispensed. The supplier must have received the WOPD before dispensing the item. A date stamp or equivalent must be used by the supplier to document receipt date.”
CMS removed this language from the current policy article. MiraVista presumes CMS made the change because the statute never directly imposed the requirement. Per section 410.38 of the Code of Federal Regulations, the following items are required of a 5EO:
- Beneficiary name.
- Item of DME ordered.
- Physician signature.
- Physician NPI.
- Date of the order.
Suppliers are required to secure a 5EO prior to delivery. To satisfy the “date of the order” being on or before the date of delivery, the DME MACs will now base timeliness on the date of the order. Suppliers must still secure a Detailed Written Order before billing the claim for reimbursement. To prevent reimbursement delays, MiraVista recommends suppliers only dispense product after securing the detailed written order.
Internal date stamping has been a burdensome and problematic administrative protocol. The shift to leverage elements that are naturally on the order (instead of artificially imposed for administrative purposes) will make it easier to pass audits and validate timely orders. Continue if you wish, but you have our blessing to do away with this unnecessary step!
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