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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 state that a power tilt seating system (E1002) 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 legrests; fixed or flip-up footplates; a motor 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; back 
height of at least 20 inches; ability for the supplier to adjust the seat to back angle; ability to support 
beneficiary weight of at least 250 pounds. 
 
A power recline seating system (E1003, E1004, E1005) includes: a solid seat platform and a solid back; any 
frame width and depth; detachable or flip-up fixed height or adjustable height arm rests; fixed or swingaway 
detachable legrests; fixed or flip-up footplates; a motor 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 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. 
 
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 legrests; 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. 
 
You can find this information 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.