When Medicare Requires a Standard Written Order for DME Billing

Durable medical equipment (DME) billing is often attached to complex reimbursement rules and changing payer policies. According to a report, Medicare spending on DME grew at five times the rate between 2019 and 2023. The process of billing medical equipment is significantly different from billing medical services. For instance, in DMEPOS, if you are working with Medicare, you must prepare a Standard Written Order (SWO) to support DMEPOS claims. This helps establish the fact that items being billed have been appropriately ordered by a practitioner. It also ensures that the billed items meet applicable Medicare coverage and documentation requirements. If these requirements are hard to manage in-house, professional DME billing services can help suppliers manage them.

You may wonder why these SWOs are important for DME suppliers and healthcare providers. It is because these orders help practitioners maintain accurate records, support claim processing, and reduce the risk of claim denials. According to the Centers for Medicare & Medicaid Services (CMS), there are six elements in a SWO for DMEPOS. These include the beneficiary’s name, order date, general description, quantity to be dispensed, practitioner’s name, and practitioner’s signature.

Time plays a crucial role in payment for DMEPOS items. The timing rule for SWO for DMEPOS claims determines whether the supplier must obtain a valid order from the treating practitioner. This order must meet the Medicare documentation requirements. In DME billing, the order is usually obtained before claim submission or before the items are delivered. However, CMS is expanding the list of DME that require additional documentation before delivery. Under this requirement, for certain DMEPOS items, the beneficiary must have a qualifying face-to-face encounter and a written order completed before the equipment is delivered. These requirements help Medicare verify that the equipment is medically necessary and properly prescribed.

From October 28, 2026, CMS is scheduled to add 22 HCPCS codes to the existing list, increasing the total from 83 to 105 items. The 22 additional codes cover several types of equipment, including wheelchairs, home ventilators, oxygen equipment, and orthoses. Being a DME supplier, it is essential that you know more about a standard written order in Medicare. This will ensure that you bill the items correctly and prevent order-related billing errors.

Related Reading: Surefire Secrets for Managing Prior Authorization for DME Billing

Decoding the Medicare Standard Written Order in DME Billing

A Medicare SWO is nothing more than a written prescription from a treating healthcare practitioner that documents the need for a beneficiary to receive DMEPOS. CMS introduced the Standard Written Order for DMEPOS effective January 1, 2020. According to the final rule CMS-1713-F, the different order formats have been replaced by one consistent set of required elements. It can also be said that Medicare established a common format for documenting a practitioner’s order for medical equipment and supplies.

What Changed under CMS-1713-F?

The rule has simplified documentation by introducing one standard order format instead of multiple ones. The other important changes are mentioned below:

• For standard DMEPOS items – The SWO needs to be communicated to the supplier before the submission of the Medicare claim.
• For items requiring a Written Order Prior to Delivery (WOPD) – The supplier must receive the completed order before the item is delivered.
• Order frequency – It is no longer a requirement of the standard order. However, quantity must be included when applicable.
• Practitioner’s signature – A separate practitioner’s signature date is no longer required as a standard SWO element.

DME MACs’ General Documentation Policy Article

The CMS Medicare Coverage Database article A55426 serves as the general documentation policy reference for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) claims submitted to Medicare.

Article A55426 covers the following:

• SWO – General requirements for written orders from treating practitioners.
• Medical records – Evidence supporting the beneficiary’s diagnosis, functional limitations, and need for the item.
• Medical necessity – Documentation needed to support that equipment or supplies are reasonable and necessary.
• Record retention – Suppliers must maintain documentation in their files for seven years from the date of service.

Get Your SWO Right: Six Key Elements

Options, Accessories and Supplies in SWO

The DME MACs recommend including the base item and all associated accessories on one SWO. Separate orders for accessories are acceptable. When these items are ordered concurrently and are separately billed or require an upgraded HCPCS code, they must be identified separately in the order as applicable.

1. Options and accessories – These are additional components or features associated with the base equipment. The functionality may be improved or adapted to the beneficiary’s requirements. For example, an order for a wheelchair may include separately billed accessories. These include armrests or other approved components.
2. Additional features or upgraded equipment – Some equipment has additional features that affect its HCPCS coding or reimbursement category. If a feature requires an upgraded code, it should be clearly identified in the order rather than relying only on a general description of the base item.
3. Supplies – These are items used in connection with DME, including certain replacement or recurring supplies. The requirements help ensure that the order supports the items billed to Medicare.

Who Is Authorized to Sign an SWO?

According to the Centers for Medicare & Medicaid Services (CMS), a person other than the treating practitioner may complete certain elements of a Standard Written Order (SWO). However, the treating practitioner must review and sign the order.

The treating practitioner responsible for the order must sign the SWO. Depending on Medicare requirements, a treating practitioner may include:

• Physician
• Physician assistant
• Nurse practitioner
• Clinical nurse specialist

The practitioner must be legally authorized to prescribe the particular DMEPOS item. Chiropractors are not permitted to prescribe DMEPOS under these Medicare rules.

Who Can Complete an SWO?

For most DMEPOS items, authorized office staff may prepare or fill in the required information on the order, subject to applicable rules. The SWO must include the following information:

• Beneficiary’s name
• Order date
• General description of the item
• Quantity to be dispensed
• Practitioner’s name and signature

For example, a medical assistant prepares an SWO for a hospital bed using information from the patient’s medical record. The order here is reviewed for accuracy by the treating physician. The supplier then retains the order and ensures all applicable documentation and timing are met properly.

When Must the Supplier Receive an SWO?

Knowing when a supplier must receive an SWO is vital and aids in accurate billing, prompt reimbursement and minimizing claim denials.

When Is a New SWO Required?

A new Standard Written Order (SWO) is required in specific situations under Medicare’s DMEPOS documentation policy, Article A55426. The purpose is to ensure that the equipment or supplies being billed are supported by a valid order from the treating practitioner.

There are five situations when a new order may be required:

1. For all purchases and initial rentals – A new order is required for claims involving the purchase or initial rental of DMEPOS items.
2. When the order changes – A new order is generally required when the prescribed item or order details change, such as the quantity. However, a new order may not be necessary if the existing general description remains valid for the changed item; check the applicable DME MAC guidance.
3. When a medical policy requires periodic orders – Some policies require a new order at specified intervals, even when the prescription has not changed.
4. When an item is replaced – A new order is required when replacing equipment, subject to applicable Medicare replacement rules.
5. When the supplier changes – A new order is required if the new supplier cannot obtain a copy of a valid existing order from the previous supplier.

Providers must document all information accurately to ensure proper reimbursement in DME billing. Any missing detail may lead to claim denials that significantly affect revenue growth.

How to Avoid These SWO Documentation Errors

A Standard Written Order (SWO) is a required document for Medicare Part B claims for DMEPOS. Every DME supplier must avoid the following errors to ensure billing accuracy:

Missing SWO – The supplier submits a claim without having the required written order on file. Medicare generally requires an SWO for DMEPOS purchases and rentals. Providers must confirm that a valid order is on file before submitting the claim.

Missing beneficiary information – The order is missing the patient’s name or Medicare Beneficiary Identifier (MBI), or the information provided does not correctly identify the beneficiary.

Incorrect order dates – The SWO is missing the date the order was issued, or the documented date does not meet applicable requirements.

Incomplete item description – The order does not adequately identify the equipment or supply. Separately billed accessories, options, or additional features ordered concurrently may also be omitted.

Checklist for Pre-Billing and Pre-Delivery

The reimbursement process of DME is complex and challenging for most in-house billing teams. Hiring external DME billing companies can help streamline revenue cycle management. These professional billers follow the checklist mentioned below to ensure accuracy:

Related Reading: DME Billing Checklist for Billers When a Patient Changes Insurance

How Does SunKnowledge Support Order Follow-Up in DMEPOS?

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