Clarification on Standard Written Orders

Published in Government Relations on April 16, 2024

Ronda BuhrmesterRecently, the DME MACs released a Dear Physician Letter that clarified language on a standard written order (SWO) specifically related to CPAP masks. While the article was great news being welcomed by the industry, it also initiated additional conversation for other PAP supplies such as interfaces and tubing.

A SWO can have all the CPAP supplies listed separately (itemized). The descriptions of the items can be generic such as “CPAP mask”, this is applicable to either a full face mask or a nasal mask. The same SWO can have “tubing” listed to refer to either standard or heated tubing. The interfaces can also be a generic description.

The important pieces of information to be aware of when working with suppliers offering PAP supplies is making sure the SWO is not stating “CPAP supplies.” While the supplier can dispense with this type of order, the supplier cannot submit the claim for payment.  The SWO needs to be itemized. 

The other important piece of information is knowing that the interfaces would be listed separately because the quantities allowed each month are different. While both nasal replacement interfaces and full face replacement interfaces can be listed on the same SWO, the monthly allowed quantities are different. 

One last important piece of information is knowing the effective date of this change. The medical directors with the DME MACs have stated the guidance is for claims reviewed on or after February 1, 2024.

Even though this is a big win for our industry, we need to be mindful and not take advantage of the system. We can all agree the DME industry doesn’t need any more black eyes and we would not want this change reversed.

In summary, applicability is to all PAP supplies: The Dear Physician letter was intentionally written to address the issue of “mask swapping” only, an issue that industry stakeholders and the American Academy of Sleep Medicine asked the DME MACs to address in a recent “white paper.” PAP supplies, when separately billable, should be listed separately on the order. Two examples illustrate acceptable versus unacceptable orders for supplies:

  • Acceptable: “Tubing, Filter” – The DME MACs would allow this general description of the items, recognizing that the supplier’s knowledge of the base equipment dispensed, and patient medical need would dictate the type of tubing (e.g., standard vs heated) and filter (e.g., permanent vs disposable).
  • Unacceptable: “CPAP Supplies” – This would be considered inconsistent with CMS’ instructions to list separately billable items on the SWO.

Reach out to Ronda Buhrmester, Sr. Director of Payer Relations and Reimbursement for questions.


TAGS

  1. reimbursement
  2. respiratory

From Our Experts

CMS Rule Phases Out Fax Machines, Snail Mail to Save Taxpayers $781.98 Million a Year thumbnail CMS Rule Phases Out Fax Machines, Snail Mail to Save Taxpayers $781.98 Million a Year As reported by CMS: “The Centers for Medicare & Medicaid Services (CMS) is slashing wasteful spending and antiquated paperwork by swapping out faxing and mailing for streamlined electronic transactions. This action lets providers spend less time on administrative hassle and more time caring for patients. PAMES Raises Critical Concerns Over Sole-Source Supply Shift thumbnail PAMES Raises Critical Concerns Over Sole-Source Supply Shift PAMES and DME suppliers across Washington are taking an important stand on behalf of both providers and patients. The Tacoma Daily Index recently reported on the state's plan to move to a sole-source contract for incontinence and urological supplies. Under this decision, the Health Care Authority intends to transition all Medicaid recipients to receiving these products from a single vendor. SBA Advocacy: Your Input Matters thumbnail SBA Advocacy: Your Input Matters Make your voice heard about how the CBP has affected your business. New Bipartisan Senate Bill Aims to Improve Access to Diabetes Technology & Education for Medicare Beneficiaries thumbnail New Bipartisan Senate Bill Aims to Improve Access to Diabetes Technology & Education for Medicare Beneficiaries U.S. Senators Jeanne Shaheen (D-NH) and Susan Collins (R-ME), Cochairs of the Senate Diabetes Caucus, have introduced the Diabetes Interventions Addressing Barriers to Enrollment, Technology, and Education Services (DIABETES) Act, S.4037. VGM Reintroduces the Fraud, Waste & Abuse Reporting Resource Center thumbnail VGM Reintroduces the Fraud, Waste & Abuse Reporting Resource Center VGM Government Relations is proud to announce the reintroduction of its Fraud, Waste & Abuse (FWA) Reporting Resource Center—a newly refreshed online hub designed to protect the integrity of the DMEPOS industry and reinforce our unwavering commitment to ethical, compliant care. Celebrating Another DME Champion of Change: Thom Harvill of Above and Beyond Medical thumbnail Celebrating Another DME Champion of Change: Thom Harvill of Above and Beyond Medical We're proud to once again recognize a true Champion of Change in the DME industry: Thom Harvill of Above and Beyond Medical in Tennessee. Thom has dedicated many years to the DME community—consistently showing up, speaking out, and pushing the industry forward. He's the kind of advocate who never stops asking, “Who else can I reach out to about this?” Federal Actions This Week Signal The Administration Is Doubling Down On Its Goal To Eliminate Fraud Waste And Abuse thumbnail Federal Actions This Week Signal The Administration Is Doubling Down On Its Goal To Eliminate Fraud Waste And Abuse This week, the Trump administration, through the Centers for Medicare & Medicaid Services (CMS), announced a significant deferral of federal Medicaid matching funds to Minnesota alongside the release of a new Request for Information (RFI) tied to the administration's Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative. These actions along with the changes to DMEPOS accreditation and enrollment signal the administration's aggressive posture on Medicaid and Medicare... VGM Response To CMS Moratorium On New DMEPOS Provider thumbnail VGM Response To CMS Moratorium On New DMEPOS Provider The federal moratorium on new DME suppliers presents a defining moment for us as an industry—an opportunity to demonstrate that the VGM members serving patients are the gold standard. We have long shown that our members operate with integrity, excellence in compliance, and unmatched commitment to service, efficiency, and patient outcomes. Now, we must elevate that message.