Clarification on Standard Written Orders

Published in Government Relations on April 16, 2024

Ronda Buhrmester Recently, 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.

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