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This technique, while simple, is not always effective, especially when you are providing custom fabricated items. If you are providing and billing for custom items, techniques two and three may be a better fit. Technique two is to provide a narrative description of the item(s) you are providing, and technique three is to list out all the Healthcare Common Procedure Coding System codes and their descriptors. Whichever technique you employ, make sure that all the unique features or components you are billing for on individual claim lines have been accounted for and included on the DWO.
When completing the descriptive part of the DWO, be sure to account for any supplies that you may have to replace or provide to the patient on a regular basis. If you have any of these types of items on your DWO, you must include not only the quantity originally dispensed but also how often you plan to replace them for the patient. When describing your replacement plan for supply items be as specific as possible. The last component of a valid written order is the inclusion of the ordering physician’s signature and the date he or she signed the DWO. For Medicare purposes, a valid signature must be legible or able to be authenticated and can be both electronic or traditional pen and ink.
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O&P Almanac SEPTEMBER 2013
Signature Criteria What is legible or illegible may be a matter of opinion and is at the discretion of the auditor reviewing your claim, but there are things you can do to ensure that you meet the established signature criteria and avoid a denial. See the table on page 18 for a breakdown of what auditors are reviewing to determine if signature criteria has been met. If the signature criteria is not met and the signature is deemed illegible and that is the only reason for a possible denial, the auditor should not automatically deny your claim, but should instead provide you with a chance to authenticate the signature. The signature can be authenticated using a signature log, a pre-filled out document that lists the typed name of the signee associated with the illegible signature, or an attestation statement. Medicare has not released official rules on what constitutes a valid electronic signature, however it has released some guidelines. Medicare recommends that whatever format the electronic signature takes it also should be accompanied by a statement showing that the signature was provided electronically. Some examples of these accompanying statements include but are not limited to: electronically signed by, completed by, or validated by. Once the final DWO has been completed, signed, and dated, that order is considered valid for the lifetime of the item delivered. This means that any replenishment of supplies, repairs, adjustments, or replacement of minor parts is covered under the order and would not need a new order/prescription. The only time you would need a new set (dispensing and detailed) of prescriptions is if you are replacing the current orthoses/prostheses the patient owns or you are providing new orthoses/prostheses due to change in the patient’s condition. If you are replacing a major component of the prostheses/orthoses, a new set of orders also would be required.
Once the final DWO has been completed, signed, and dated, that order is considered valid for the lifetime of the item delivered. Final Considerations Is it required that you have both a dispensing order and a DWO on file? Medicare will not cover any O&P items or related services if only a dispensing order is on file at the time the claim is submitted for payment, indicating that a DWO also is required. However, if the dispensing order meets all the requirements of a DWO written order, then a separate DWO is not required and you may bill with just the initial order. If for any reason you realize you don’t have a DWO on file or have an invalid DWO on file at the time of claim submission, you may consider submitting the claim with the EY modifier. The EY modifier signifies that you don’t have an order on file for the items you are providing. The EY modifier will result in a claim denial based on medical necessity, and a medical necessity denial will allow you to appeal the claim and demonstrate medical necessity. For more information on initial orders and detailed written orders, be sure to read your supplier manuals, and Medicare’s Program Integrity Manual (chapter 5, section 2), or contact AOPA. For specific information on when an order is required, review the Medicare medical policies for the items or services you are providing. a Devon Bernard is AOPA’s manager of reimbursement services. Reach him at dbernard@AOPAnet.org.