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The rules say that plans must pay for a medical service or item if regular Medicare would pay for it in this case. 
You can find this rule at 42 Code of Federal Regulations (CFR) Section 422.101. 
 
The rules say that power tilt and/or recline seating systems (E1002, E1003, E1004, E1005, E1006, E1007, 
E1008, E1009, E1010, E1012): 
 
A power seating system  tilt only, recline only, or combination tilt and recline  with or without power 
elevating leg rests will be covered if criteria 1, 2, and 3 are met and if criterion 4, 5, or 6 is met: 
 
    The beneficiary meets all the coverage criteria for a power wheelchair described in the Power Mobility 
Devices LCD; and 
 
    A specialty evaluation that was performed by a licensed/certified medical professional, such as a physical 
therapist (PT) or occupational therapist (OT) or practitioner who has specific training and experience in 
rehabilitation wheelchair evaluations of the beneficiarys seating and positioning needs. The PT, OT, 
or practitioner may have no financial relationship with the supplier; and 
 
    The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional 
(ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection 
for the beneficiary. 
 
    The beneficiary is at high risk for development of a pressure ulcer and is unable to perform a functional 
weight shift; or 
 
    The beneficiary utilizes intermittent catheterization for bladder management and is unable to independently 
transfer from the wheelchair to bed; or 
 
    The power seating system is needed to manage increased tone or spasticity. 
 
If these criteria are not met, the power seating component(s) will be denied as not reasonable and necessary. 
You can find this rule in the Local Coverage Determination (LCD) Wheelchair Options/Accessories L33792. 
 
 
 
 
 The rules say that a power tilt and recline seating system (E1006, E1007, E1008) includes: a solid seat platform 
and a solid back; any frame width and depth; detachable or flip-up fixed height or adjustable height armrests; 
fixed or swingaway detachable leg rests; fixed or flip-up footplates; two motors and related electronics with or 
without variable speed programmability; a switch control which is independent of the power wheelchair drive 
control interface; any hardware that is needed to attach the seating system to the wheelchair base. It does not 
include a headrest. It must have the following features: ability to tilt to greater than or equal to 20 degrees from 
horizontal; ability to recline to greater than or equal to 150 degrees from horizontal; back height of at least 20 
inches; ability to support beneficiary weight of at least 250 pounds. 
 
Coding for a power tilt system (E1002), power recline system (E1003, E1004 and E1005), and tilt/recline 
system (E1006, E1007 and E1008) are all-inclusive. Usage of K0108 to bill for additional heavy duty or 
bariatric features is considered unbundling and is not allowed. 
 
A power tilt seating system or power tilt and recline seating system which does not achieve a tilt of greater than 
or equal to 20 degrees is considered to be the same as the standard seat included in the base wheelchair. Codes 
E1002, E1003, E1004, E1005, E1006, E1007, E1008 must not be used to describe a power tilt seating system 
or a power tilt and recline seating system which does not achieve a tilt of greater than or equal to 20 degrees. 
These seating systems must be coded as A9900 and are not separately payable. 
 
A mechanical shear reduction feature (E1004 and E1007) consists of two separate back panels. As the posterior 
back panel reclines or raises there is a mechanical linkage between the two panels which allows the 
beneficiary's back to stay in contact with the anterior panel without sliding along that panel. You can find these 
rules in the Local Coverage Article Wheelchair Options/Accessories - Policy Article A52504. 
 
If you want to read these Medicare rules, you can go to this website www.medicareappeal.com. 
 
The Plan contract says that the Plan covers items and services in accordance with Medicare rules.