Medicare Program Integrity Manual (Pub. 100-08), Ch. 3 § 3.3.2.1.2
DMEPOS Orders
3.3.2.1.2 –DMEPOS Orders
(Rev. 10190; Issued: 06-19-2020, Effective: 01-01-2020; Implementation: 07-01-
2020)
Totality of the Record
All DMEPOS items require a Standard Written Order (SWO) from the treating
practitioner as a condition of payment. Medicare contractors shall consider the totality of
the medical record when reviewing for compliance of the SWO elements. This will allow
contractors to account for the dynamic nature of electronic medical record documentation
systems, and give them additional discretion when they believe the entirety of the record
demonstrates compliance with our order requirements. For example, a contractor may
nonetheless support payment when an order has a missing or flawed element that is
clearly documented elsewhere in the record.
Contractors acting as a secondary reviewer shall grant deference to the initial reviewer’s
discretion, if such an initial decision resulted in a reasonably prudent decision that aligns
with Medicare coverage and coding instructions.