This latest clarification, however, defines new directives that permit modification and cure to the DWO in a new limited circumstance. The clarification, posted to the NHIC website here http://www.medicarenhic.com/viewdoc.aspx?id=2760 reads:
I. If errors in the WOPD are found prior to delivery, the supplier has two options:
A. The WOPD may be properly amended following the guidance in the Program Integrity Manual (Internet-Only Manual, Publ. 100-08), Chapter 3, Section 18.104.22.168; or,
B. A new WOPD may be created and sent to the physician for signature and date.
II. If errors in the WOPD are found after delivery of the item, the supplier has two options:
A. If the error is discovered prior to claim submission, the original supplier may recover the delivered item(s), obtain a compliant, complete WOPD and then may re-deliver the item(s) to the beneficiary; or,
B. If the error is discovered after submitting a claim, the original supplier can recover their items and a new supplier must complete the transaction after complying with all requirements.”
This newest development opens the door for suppliers struggling with errors in the DWO found after delivery. The clarification allows suppliers the opportunity to collect a new compliant DWO after delivery but before billing and still remain compliant with FTF requirements. In this instance, the supplier would be required to pick-up the equipment issued under the non-compliant order, obtain the new DWO with all necessary components to comply with the FTF rule and then redeliver the equipment, and allow the new claim to bill for reimbursement.
This is a major shift from prior education that opens reimbursement opportunities in the event of proactively identified DWO errors.
CMS has not yet issued information on when the second phase of the FTF rule will be rolled out regarding collection of the FTF notes prior to delivery that will also require NPs, PAs and CNSs to secure a physician co-signature on their notes. Stay tuned to the MiraVista blog for updates on this and other important topics impacting reimbursement.