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Short answer. A standard written order (SWO) is the Medicare order for durable medical equipment, prosthetics, orthotics and supplies (DMEPOS). Under 42 CFR 410.38 it has six elements: beneficiary name or MBI, a general description of the item, quantity where applicable, order date, treating practitioner name or NPI, and the practitioner’s signature. For most items it must reach the supplier before the claim is submitted. For power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List it must reach the supplier before delivery.
This page is a documentation workflow for supplier and clinic staff who take in orders. It is general information about a regulation, not advice about any individual’s coverage or care.
What a standard written order is
The SWO is the order requirement in the Medicare DMEPOS rule at 42 CFR 410.38, effective January 1, 2020 (CMS-1713-F). It sets a fixed list of six elements for the order. The treating practitioner for this purpose is a physician, physician assistant, nurse practitioner or clinical nurse specialist (410.38(c)(2)).
Related documents are covered elsewhere on CASRAI: the certificate of medical necessity (CMN), the letter of medical necessity and the supplier-side obligations in the DMEPOS supplier standards. An SWO states what was ordered; it does not by itself establish that the item is medically necessary.
The six required elements: an intake checklist
Each element below comes from 42 CFR 410.38(d)(1)(i). The right-hand column adds the point where intake most often needs a second look, taken from the CMS Standard Documentation Requirements article A55426 and the CGS Medicare (DME MAC Jurisdiction B) SWO FAQ.
| Element | What to check at intake |
|---|---|
| Beneficiary name or Medicare Beneficiary Identifier (MBI) | Present on the order itself. If a name was pre-populated and is wrong, the CGS FAQ describes the correction as a strike-through per standard clinical practice, with the supplier signing and dating the change and the practitioner signing the order. |
| General description of the item | The rule requires a general description of the item; the record, not the order, carries the detail. |
| Quantity to be dispensed, if applicable | Needed where quantity applies, such as drugs, dressings and periodic supplies. Not every item has a quantity. |
| Order date | One date only. Per A55426, signature and date stamps are not allowed. |
| Treating practitioner name or NPI | Either is sufficient (CGS FAQ). |
| Treating practitioner signature | Signed by the practitioner; A55426: “Signature and date stamps are not allowed.” |
Two items that staff often expect on the order are not required elements: frequency of use and length of need. The CGS FAQ states that neither is a required SWO element, and that length of need is judged from the medical record instead.
SWO versus written order prior to delivery (WOPD)
The timing rule is where intake decisions are made. Both come from 42 CFR 410.38(d)(1)(ii) and A55426.
| SWO | Written order prior to delivery (WOPD) | |
|---|---|---|
| What it is | An order with the six elements | A completed SWO communicated to the supplier before delivery (A55426) |
| Deadline for the supplier to hold it | Prior to claim submission | On or before the date of delivery (A55426: the date of the WOPD “shall be on or before the date of delivery”) |
| Applies to | All other DMEPOS items | Power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List |
For a WOPD, A55426 also requires that it be completed within six months after the required face-to-face encounter. Under 410.38(d)(2), for that same set of items, where a face-to-face encounter is required, the treating practitioner documents and communicates that it occurred within the 6 months before the order date.
Who can prepare the order and who must sign
The practitioner signs. Who drafts it depends on the item, per the CGS FAQ: for power mobility devices the treating practitioner completes the elements (a supplier may offer a template), while for other items the supplier may prepare the SWO and send it for the practitioner’s signature. The FAQ also notes that a practitioner who is also the supplier does not need a separate SWO if the required elements are in the medical record. State law may add its own order requirements.
When a base item and separately billed accessories are ordered together, the CGS FAQ says the MAC prefers one SWO, although the rule permits separate orders.
What the medical record must back up
An order is not the source of payment justification. A55426 states that templates and forms are subject to corroboration with information in the medical record, and that the medical record is the source used to justify payment. Under 410.38(d)(3) the supplier must maintain the written order and supporting documentation, and a required encounter is documented in the pertinent portion of the medical record. A55426 sets record retention at 7 years from the date of service, and defines timely documentation as a record in the preceding 12 months unless a specific policy says otherwise. Local coverage determinations and policy articles for a given product take precedence over this general article.
Refills and ongoing supplies
A55426 says a routine prescription for refills is not needed. Refill requests should be individualized and documented before shipment, and “a retrospective attestation statement by the supplier or beneficiary is not sufficient.”
Common misunderstandings
- “A standard written order Medicare form is a single government form.” The rule specifies elements, not a form. Per the CGS FAQ, a supplier may provide a template, and per A55426 any template is still corroborated against the medical record.
- “The SWO replaces the CMN.” They are different documents; see what a CMN is and what replaced it.
- “Every order needs frequency and length of need.” Neither is a required SWO element, per the CGS FAQ.
- “A date stamp is fine.” A55426 says signature and date stamps are not allowed.
- “The SWO is the only paperwork.” Claim lines also rely on correct coding, which is why teams pair order intake with DME modifier checks.
FAQ
What is a standard written order for Medicare?
It is the order document required for Medicare DMEPOS items under 42 CFR 410.38, containing six elements and signed by the treating practitioner. It took effect January 1, 2020.
Is a standard written order required for every DME item?
The rule’s timing differs by item: the order must reach the supplier before claim submission for most DMEPOS, and before delivery for power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List. Local coverage determinations and policy articles supersede the general article A55426, so check the one for the item.
Does a standard written order need a quantity?
Only where quantity is applicable, such as drugs, dressings and periodic supplies.
Can the supplier fill in the order?
For items other than power mobility devices, the supplier may prepare the SWO for the practitioner’s signature (CGS FAQ). The practitioner must still sign it.
Sources
- eCFR, 42 CFR 410.38, Durable medical equipment: Scope and conditions (checked 2026-11-01): ecfr.gov, 42 CFR 410.38
- CMS Medicare Coverage Database, Standard Documentation Requirements for All Claims Submitted to DME MACs, article A55426 (checked 2026-11-01): cms.gov, article A55426
- CGS Medicare, DME MAC Jurisdiction B, Standard Written Order FAQ on Final Rule CMS-1713-F (published 2020-03-12, reviewed 2025-12-01; checked 2026-11-01): cgsmedicare.com, SWO FAQ
Related CASRAI reading: hospital bed Medicare requirements and what Medicare-approved DME suppliers means.
