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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 legrests 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 information in Medicare's Local Coverage Determination (LCD): Wheelchair 
Options/Accessories (L33792). 
 
 
The rules say Non-Expandable Controller - An electronic system that controls the speed and direction of the 
power wheelchair drive mechanism. Only a standard proportional joystick (used for hand or chin control) can 
be used as the input device. This system may be in the form of an integral controller or a remotely placed 
controller. The non-expandable controller: 
 
    May have the ability to control up to 2 power seating actuators through the drive control (for example, seat 
elevator and single actuator power elevating legrests). (Note: Control of the power seating actuators though the 
Control Input Device would require the use of an additional component, E2310 or E2311.) 
 
    May allow for the incorporation of an attendant control. 
 
Expandable Controller - An electronic system that is capable of accommodating one or more of the following 
additional functions: 
 
    Proportional input devices (e.g., mini, compact, or short throw joysticks, touchpads, chin control, head 
control, etc.) other than a standard proportional joystick. 
 
    Non-proportional input devices (e.g., sip and puff, head array, etc.) 
 
    Operate 3 or more powered seating actuators through the drive control. (Note: Control of the power seating 
actuators though the Control Input Device would require the use of an additional component, E2310 or E2311.) 
 
An expandable controller may also be able to operate one or more of the following: 
 
    A separate display (i.e., for alternate control devices) 
 
    Other electronic devices (e.g., control of an augmentative speech device or computer through the chairs 
drive control) 
 
    An attendant control 
 
You can find this information in the Local Coverage Article: Power Mobility Devices - Policy Article 
(A52498). 
 
If you want to read these Medicare rules, you can go to this website www.medicareappeal.com.