WASHINGTON, D.C. (May 24, 2016)—All four DME MACs recently issued clarification on WOPD requirements as defined in the Affordable Care Act (ACA). AAHomecare has had several meetings with CMS regarding the ACA requirements and how the WOPD does not have to be the DWOPD (detailed written order prior to delivery). You can find the clarification here. This link is to the NHIC website—however, you can find the same information on all four DME MAC websites.
AAHomecare recently reached out to the POE departments at all four DME MACs for further clarification, which they provided as follows:
All items subject to WOPD as the result of the ACA 6407 change require a 5EO prior to dispensing and a DWO prior to billing. If there is no properly completed 5EO prior to dispensing (or DWO prior to billing), the claim will be denied. A supplier would not be able to utilize a DWO prior to billing to remedy their lack of the 5EO.
Note the change to allow a DWO to be obtained BEFORE billing.
In follow-up, AAHomecare requested clarification on the current claim denials and appeals that exist based on the WOPD not meeting the DWOPD requirement as had been previously communicated. All four DME MACs responded as follows:
Changes in policy guidance are effective for dates of service on or after the article¹s publication unless otherwise specified in the article. Claims are adjudicated based on the rules in effect on the dates of service for the claim.
This would mean that the appeals process needs to be used for any claim previously denied.
This development is good news for the HME community and provides some relief related to WOPD requirements.
Visit aahomecare.org for more information.
