Wednesday, May 25, 2022

Re: responses for PA and NP signatures.

Doris Wilkes

I disagree…

See below:
Prescriptions for DMEPOS, must be signed and dated by the physician, NOT by a PA, NP, or CNS.

The following practitioners may document the medical necessity of durable medical equipment,
prosthetics, orthotics and supplies (DMEPOS) items, including completing orders and Certificates of
Medical Necessity (CMNs), in place of a physician provided that they meet the practitioner
requirements defined in Chapter 15 of the Benefit Policy Manual (Publication 100-02), the services
performed are within their scope of practice as defined by their state, and they are treating the
beneficiary for the condition for which the item is needed.
• Physician Assistant
• Nurse Practitioner
• Clinical Nurse Specialist

Detailed written orders (DWO) are required for all transactions involving DMEPOS. Someone other
than the physician may complete the detailed description of the item (except when specified by
policy); however, the treating physician must review the detailed description and personally sign and
date the order to indicate agreement. Refer to the “Signature Requirements” section in this chapter.

Thank You,
Doris Wilkes
C H Martin Company
Director of Contracts and Claims
Senior Billing, Collections, and Appeals
(478) 224-1061 Direct
(478) 224-1501 Fax
[email protected]

“Sometimes you will never know the value of a moment until it becomes a memory”

—–Original Message—–
From: Orthotics and Prosthetics List [mailto:[email protected]] On Behalf Of Jim Del Bianco
Sent: Tuesday, November 24, 2015 4:23 PM
To: [email protected]
Subject: [OANDP-L] responses for PA and NP signatures.

Replies for PA, NP signing Rx’s and chart notes, specifically for prosthetics.

assessment of responses: Most say yes and one even had notes pas pre payment with PA and NP signatures. 2 people did not agree. Perhaps someone can comment on the 2 who felt otherwise.


I can see how it could be interpreted either way, but I have always read it as a physician is the only one who can sign the Rx:

• Doctor of medicine
• Doctor of osteopathy (including osteopathic practitioner) – must be licensed to practice medicine and surgery • Doctor of dental surgery or dental medicine • Chiropractor (see below) • Doctor of podiatry (see below) or surgical chiropody • Doctor of optometry

It seems to be they are distinguishing the above list of physicians, who can sign Rx, from the additional professionals who may contribute to medical necessity only.

-You’re right about the Rx that Rx can be signed on their own, but the medical record/visit notes for a PA must be cosigned by MD.


We have used both a pa and np, and claims were paid after prepayment audit.

-You are correct Jim – FNP, PA can do full Prosthesis. WE have found that when an MD signs off, it can lead to problems. Medicare likes to see only ONE prescriber name throughout the documentation (DWO, chart notes). At least that has been our experience.

-Yes, that is correct. Hopefully someday Medicare will update all their corresponding LCD’s to “Physician/Practitioner (PA, NP

-the manual says they have to meet the practitioner requirement in Chapter
15 and
the services are within their scope of practice as defined by the state that licenses them and they have to be treating them for the condition (I’d get their note to make sure they are treating them and not just signing

-I agree as long as that person had their own separate NPI#.

-make sure they are individually enrolled in PECOS.

Jim Del Bianco

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