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David McGill Blogger

Our Error

Posted by David McGill | April 18, 2013

On January 22, 2013, we authored a post stating that effective July 1, doctors would have to sign Detailed Written Orders before delivery of a prosthetic or orthotic device. We were wrong.

Buried on page 262 (of 483) of the comments to the Final Rule is the following statement by Medicare:

As noted previously, section 1834(h)(3) of the Act incorporates by cross reference prosthetic devices, orthotics, and prosthetics to the items encompassed by section 1834(a)(11)(B) of the Act. At this time, we are not implementing the proposed changes to § 410.36(b) to require documentation of a face-to-face encounter for prosthetic devices, orthotics, and prosthetics that, according to § 410.36(b), require a written order before delivery in this final rule. We intend to use future rulemaking to determine which prosthetic devices, orthotics, and prosthetics, require, as a condition of payment, a written order before delivery supported by documentation of a face- to-face encounter with the beneficiary consistent with section 1834(a)(11)(B) (ii) of the Act. [Emphasis added]

What does this mean for me?

If you're an O&P supplier, the Detailed Written Order requirements that you've always followed remain unchanged. If you have the doctor sign the DWO before billing the prosthetic or orthotic device, you are Medicare compliant.

However, the new "DWO-before-delivery" rule does apply to items other than prosthetics and orthotics, effective July 1, 2013.

Our Apology

We know you trust us to get it right the first time. We also know that trust is hard to earn and easy to lose. We've implemented new safeguards to prevent this kind of error in the future.

We apologize for the confusion we caused. And we thank you for subscribing to and reading Össur R&R.

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