Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

Inspector General 

April 2004 

OEI-03-02-00600 

MEDICARE PAYMENTS FOR 

POWER WHEELCHAIRS 
Office of Inspector General

http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, 

as amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The OIG's Office of Audit Services (OAS) provides all auditing services for HHS, either by 

conducting audits with its own audit resources or by overseeing audit work done by others. 

Audits examine the performance of HHS programs and/or its grantees and contractors 

in carrying out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations in order to reduce waste, abuse, and 

mismanagement and to promote economy and efficiency throughout the department. 

Office of Evaluation and Inspections 

The OIG's Office of Evaluation and Inspections (OEI) conducts short-term management 

and program evaluations (called inspections) that focus on issues of concern to the 

department, the Congress, and the public. The findings and recommendations contained 

in the inspections reports generate rapid, accurate, and up-to-date information on the 

efficiency, vulnerability, and effectiveness of departmental programs. 

Office of Investigations 

The OIG's Office of Investigations (OI) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries 

and of unjust enrichment by providers. The investigative efforts of OI lead to criminal 

convictions, administrative sanctions, or civil monetary penalties. The OI also oversees 

state Medicaid fraud control units, which investigate and prosecute fraud and patient 

abuse in the Medicaid program. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support in OIG's internal operations. The OCIG imposes program exclusions and 

civil monetary penalties on health care providers and litigates those actions within the 

department. The OCIG also represents OIG in the global settlement of cases arising 

under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops model compliance plans, renders advisory opinions on OIG sanctions to the 

health care community, and issues fraud alerts and other industry guidance. 
� ABSTRACT

In 2001, Medicare and its beneficiaries paid $513 million for all K0011 

power wheelchairs. Payments for this procedure code have risen 

dramatically, increasing 43 percent from the year 2000 to 2001 alone. 

In order to determine whether K0011 power wheelchairs provided in 

2001 met Medicare’s coverage and documentation requirements, we 

selected a simple random sample of 300 claims. We then contacted the 

suppliers, ordering physicians, and beneficiaries associated with these 

claims, and provided medical documentation to an independent 

contractor for a coverage review. Our review indicated most claims did 

not meet Medicare’s coverage criteria for K0011 power wheelchairs; 

however, some claims met criteria for a less expensive mobility device. 

We also identified a number of other problems with Medicare claims for 

K0011 power wheelchairs, including missing and incomplete supporting 

documentation, and equipment that is not used by Medicare 

beneficiaries. We recommend that the Centers for Medicare & Medicaid 

Services (CMS) improve compliance with Medicare’s coverage criteria 

for power wheelchairs. We suggest that CMS require durable medical 

equipment regional carriers to revise current coverage policies for power 

wheelchairs; conduct frequent reviews of K0011 claims; and educate 

ordering physicians and beneficiaries about power wheelchair coverage 

criteria. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS i 
� EXECUTIVE SUMMARY

OBJECTIVE 

To determine whether power wheelchair claims meet Medicare’s 

coverage and documentation requirements, and to examine 

beneficiaries’ use of equipment and selection of suppliers. 

BACKGROUND 

Title XVIII of the Social Security Act established coverage and benefits 

under Part B of the Medicare program. Medicare beneficiaries covered 

by Part B are eligible to receive durable medical equipment (DME), such 

as power wheelchairs, when the items are deemed medically necessary 

by a physician and needed for use in the home. To qualify for power 

wheelchairs, patients must be bed or chair confined, unable to operate a 

wheelchair manually, and capable of safely operating the controls of the 

power wheelchair. 

According to supplier manuals published by the durable medical 

equipment regional carriers (DMERCs), initial claims for power 

wheelchairs must include a Certificate of Medical Necessity (CMN) that 

has been signed and dated by a physician. The supplier must maintain 

a copy of this signed CMN in their records. Suppliers must also 

maintain documentation showing that items were delivered to 

beneficiaries. 

In calendar year (CY) 2001, Medicare and its beneficiaries paid a total 

of $513 million for procedure code K0011, a standard-weight power 

wheelchair with programmable control parameters. Medicare allows 

approximately $5,000 for each K0011 power wheelchair claim. Total 

allowances for the K0011 code have risen dramatically, increasing 

43 percent from the year 2000 to 2001 alone. Although many 

beneficiaries need power wheelchairs, DMERCs and the Office of 

Inspector General (OIG) have identified fraud cases involving power 

wheelchairs that were not supplied, not medically necessary, or both. 

For this inspection, we selected a simple random sample of 300 claims 

for procedure code K0011 from the Centers for Medicare & Medicaid 

Service’s (CMS’s) 2001 National Claims History File. We then collected 

CMNs and delivery documentation from suppliers, and medical records 

from ordering physicians. Using Medicare coverage criteria, an 

independent medical review contractor conducted a coverage review of 

medical records received from physicians or suppliers. We did not assess 

the appropriateness of the Medicare coverage criteria themselves. We 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS ii 
EXECUTIVE SUMMARY 

also spoke with 166 of the 300 beneficiaries on whose behalf Medicare 

paid sample claims. 

FINDINGS 

Most reviewed claims did not meet Medicare’s coverage criteria for 

a K0011 power wheelchair; however, some claims may have met 

coverage criteria for a less expensive mobility device. Almost onethird of reviewed claims did not meet Medicare’s coverage criteria for 

any type of wheelchair. An additional 45 percent of reviewed claims did 

not meet Medicare’s coverage criteria for the K0011 power wheelchair 

but may have met criteria for another type of wheelchair or scooter (also 

known as a power-operated vehicle). Physicians, however, may not be 

familiar with Medicare’s coverage criteria when ordering mobility 

devices for their patients. The only document that physicians are 

required to review and complete when ordering a wheelchair is the 

CMN. Coverage guidelines are not listed on the CMN for power 

wheelchairs, and medical necessity questions on CMNs are not totally 

consistent with coverage policy. In CY 2001, Medicare and its 

beneficiaries paid an estimated $178 million for claims that did not 

meet Medicare’s coverage criteria for K0011 power wheelchairs. Only 

13 percent of reviewed claims actually met the coverage criteria for 

K0011 power wheelchairs. Due to insufficient documentation, the 

reviewer could not determine whether another 11 percent of reviewed 

claims met the coverage criteria for the K0011 power wheelchair. 

For over half of claims, CMNs and/or delivery documentation were 

missing, incomplete, or dated after the date of service. For 5 percent 

of K0011 power wheelchair claims, suppliers did not provide a CMN 

and/or proof of delivery. We estimate that Medicare and its 

beneficiaries paid an additional $19 million in CY 2001 for K0011 

claims that could not be substantiated by either a CMN or delivery 

documentation. Even when suppliers did submit CMNs or proof of 

delivery, the documentation was often incomplete or dated after the 

date of service. 

Most responding beneficiaries reported using their power 

wheelchairs at home; other beneficiaries either do not use their 

power wheelchairs or use them for outside activities only. Sixtyeight percent of beneficiaries who responded to our survey (113 of 166) 

currently use their power wheelchairs inside their homes. Four percent 

of respondents said that they have never used their power wheelchairs. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS iii 
EXECUTIVE SUMMARY 

An additional 12 percent of respondents said that they do not currently 

use their power wheelchairs but have used them in the past. Another 

12 percent of respondents reported that they currently use their power 

wheelchairs outside the home only. 

Many beneficiaries who completed our survey responded to 

suppliers’ direct marketing practices. Almost one-quarter of 

beneficiaries who responded to our survey learned about their power 

wheelchair suppliers from a television commercial. An additional 

9 percent of respondents chose their suppliers after receiving something 

in the mail. Another 4 percent of respondents obtained their power 

wheelchairs from suppliers who visited their homes. 

RECOMMENDATION 

A power wheelchair can greatly improve the quality of life for an 

individual who otherwise suffers from limited mobility. However, our 

coverage review indicates that Medicare and its beneficiaries spent an 

estimated $178 million in 2001 for K0011 power wheelchairs that did 

not meet Medicare’s coverage criteria. These inappropriate payments 

waste taxpayer dollars that could otherwise fund appropriate 

equipment for needy Medicare beneficiaries. 

CMS has recognized the dramatic growth in payment for and utilization 

of power wheelchairs and is currently taking steps to address these 

issues as part of its 10-point plan of action to curb power wheelchair 

fraud, waste, and abuse. In fact, CMS has already begun implementing 

some of the options listed in the following recommendation. We believe 

that continued attention to Medicare payments for K0011 power 

wheelchairs is warranted. 

We recommend that CMS improve compliance with Medicare’s 

coverage criteria for K0011 power wheelchairs. CMS should consider 

the following options in order to improve compliance: 

Require DMERCs to revise the coverage policy for K0011 power wheelchairs 

to include specific information about the medical conditions for which Medicare 

will cover this item. Our findings show that many beneficiaries did not 

meet coverage criteria for the K0011 power wheelchair but may have 

qualified for a lower-priced power wheelchair, a scooter, or a manual 

wheelchair. Given that patients frequently received K0011 power 

wheelchairs when their conditions warranted a lower level of 

equipment, CMS should evaluate the medical conditions and functional 

abilities that are associated with different types of mobility aids and 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS iv 
EXECUTIVE SUMMARY 

describe these conditions/abilities in the coverage policies. This will 

ensure that beneficiaries have access to the equipment that is most 

appropriate for their conditions. DMERCs should also consider 

removing guidelines regarding the specialties of physicians who order 

scooters. In addition, DMERCs should require that physicians treat the 

patients for whom they order equipment. 

Require DMERCs to conduct frequent reviews of the K0011 procedure code to 

ensure appropriate payments. When performing reviews of K0011 claims, 

DMERCs should ensure that suppliers have complete and thorough 

documentation. DMERCs should also request medical records from 

ordering physicians in addition to supporting documentation from 

suppliers. DMERCs should also consider routinely contacting 

beneficiaries during the course of reviews to ensure that the equipment 

provided by suppliers is appropriate for and useful to beneficiaries. 

Educate ordering providers about Medicare’s coverage criteria for different 

types of assistive devices, including power wheelchairs, manual wheelchairs, 

and scooters. Ordering providers play a key role in determining the 

need for and utilization of equipment billed to Medicare. According to 

the Medicare Prescription Drug, Improvement, and Modernization Act 

of 2003, payment may not be made for power wheelchairs unless a 

physician, physician’s assistant, nurse practitioner, or clinical nurse 

specialist has conducted a face-to-face examination of the patient and 

written a prescription for the item. CMS relies on the clinical judgment 

of these health care professionals to ensure that Medicare only pays for 

items that are most appropriate for beneficiaries. However, ordering 

providers may not be aware of Medicare’s coverage requirements for 

mobility devices. A lack of provider education about Medicare’s 

coverage criteria for wheelchairs could adversely affect physicians’ 

ability to make informed decisions about the types of mobility devices 

that are best for their patients, which could ultimately lead to 

inappropriate Medicare payments. 

Educate Medicare beneficiaries about coverage criteria for wheelchairs and 

scooters. Beneficiaries also play a key role in ensuring that Medicare 

does not pay for medically unnecessary or unused items. Beneficiaries 

who are knowledgeable about Medicare’s coverage guidelines can make 

more informed choices about the assistive devices that would meet both 

their own needs and Medicare’s coverage requirements. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS v 
EXECUTIVE SUMMARY 

AGENCY COMMENTS 

CMS concurred with our recommendation and agreed with our 

suggestions regarding coverage policy revisions and provider and 

beneficiary education. They also agreed that more frequent reviews of 

the K0011 code will help ensure appropriate payments; however, they 

do not believe that routinely contacting beneficiaries would yield 

meaningful results. CMS confirmed that they have already begun 

implementing many of our report recommendations through their power 

wheelchairs workgroup, which was established to develop a plan of 

action to ensure that payments are only made for power wheelchairs 

that are reasonable and necessary. Specific actions by CMS include: 

requiring DMERCs to develop a complete picture of a patient’s medical 

condition before making medical review coverage determinations; 

developing a regulation to remove the current requirement that scooters 

be prescribed only by certain specialists; and developing a regulation 

that requires a face-to-face examination by the treating physician prior 

to ordering a power wheelchair. CMS is also poised to release an 

educational campaign designed to provide both physicians and 

beneficiaries with needed information regarding Medicare and DMERC 

coverage policy. The full text of CMS’s comments is presented in 

Appendix B. 

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� TABLE OF CONTENTS

ABSTRACT ................................ ....................... i

EXECUTIVE SUMMARY ................................ ......... ii

INTRODUCTION ................................ .................. 1

FINDINGS ................................ ........................ 9

K0011 claims that did not meet Medicare coverage guidelines ........ 9

Missing, incomplete, or post-dated documentation ......................... 12

Beneficiaries’ reported use of power wheelchairs ............................ 13

Beneficiaries responded to direct marketing practices.................... 14

RECOMMENDATION ................................ ............ 16

AGENCY COMMENTS ................................ ........... 17

APPENDICES ................................ .................... 19

A: Estimates and Confidence Intervals .......................................... 19

B: CMS’s Comments........................................................................ 20

ACKNOWLEDGEMENTS ................................ ........ 23
� INTRODUCTION

OBJECTIVE 

To determine whether power wheelchair claims meet Medicare’s 

coverage and documentation requirements, and to examine 

beneficiaries’ use of equipment and selection of suppliers. 

BACKGROUND 

Title XVIII of the Social Security Act established coverage and benefits 

under Part B of the Medicare program. Medicare beneficiaries covered 

by Part B are eligible to receive durable medical equipment (DME) 

deemed medically necessary by a physician. Medicare Part B classifies 

certain items of DME, such as wheelchairs, as capped rental items. 

Payments for capped rental items are made on a monthly basis not to 

exceed 15 continuous months; however, power wheelchairs may be 

purchased outright. A DME supplier must give beneficiaries that 

qualify for a power wheelchair the option to purchase the item when it 

is first provided. If the beneficiary chooses to purchase the power 

wheelchair at that time, the supplier receives a lump-sum payment. 

Medicare beneficiaries are responsible for 20 percent of this lump-sum 

payment in the form of coinsurance. 

To obtain reimbursement for medical equipment such as power 

wheelchairs, suppliers submit claims to one of four durable medical 

equipment regional carriers (DMERCs). The Centers for Medicare & 

Medicaid Services (CMS) contracts with these DMERCs to process and 

pay medical equipment claims. 

Medicare Coverage Criteria for Wheelchairs and Scooters 

Medicare covers many different types of wheelchairs, from basic manual 

wheelchairs and scooters (also known as power-operated vehicles) to 

high-end power wheelchairs. Section 1862(1)(A) of the Social Security 

Act states that all DME items provided under Medicare Part B, 

including wheelchairs and scooters, must be “reasonable and necessary 

for the diagnosis or treatment of illness or injury or to improve the 

functioning of a malformed body member.” In addition, Section 1861(n) 

of the Social Security Act stipulates that patients must need the 

equipment for use in their homes. Payment is approved for the least 

costly medically acceptable item. Options that are beneficial primarily 

in allowing beneficiaries to perform leisure or recreational activities are 

not covered by Medicare. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 1 
INTRODUCTION 

Coverage Criteria for Manual Wheelchairs. A manual wheelchair is covered 

if the patient’s condition is such that without the use of a wheelchair, 

the patient would otherwise be bed or chair confined. Additional 

criteria may apply for non-standard manual wheelchairs such as 

lightweight, ultra-lightweight, and heavy-duty manual wheelchairs. 

Coverage Criteria for Scooters. Unlike other mobility devices covered by 

Medicare, a scooter must be prescribed by a specialist. A scooter is 

usually covered only if it is ordered by a physician in one of the 

following specialties: Physical Medicine, Orthopedic Surgery, Neurology, 

or Rheumatology. For coverage of scooters, all of the following 

additional criteria must be met: 

o The patient’s condition is such that, without the use of a 

wheelchair, the patient would not be able to move around in their 

residence. 

o The patient is unable to operate a manual wheelchair. 

o The patient is capable of safely operating the controls for the 

scooter. 

o The patient can transfer safely in and out of the scooter and has 

adequate trunk stability to be able to safely ride in the scooter. 

Coverage Criteria for Power Wheelchairs. A power wheelchair is covered 

when all of the following criteria are met: 

o The patient’s condition is such that, without the use of a 

wheelchair, the patient would otherwise be bed or chair confined. 

o The patient’s condition is such that a wheelchair is medically 

necessary, and the beneficiary is unable to operate a wheelchair 

manually. 

o The patient is capable of safely operating the controls for the 

power wheelchair. 

According to the DMERC supplier manuals, “A patient who requires a 

power wheelchair usually is totally non-ambulatory and has severe 

weakness of the upper extremities due to a neurologic or muscular 

disease/condition.” Unlike scooters, a physician does not need to have a 

particular specialty in order to prescribe a power wheelchair. 

Documentation Required by DMERCs for Power Wheelchair Claims 

According to the DMERC supplier manuals, initial claims for power 

wheelchairs must include a Certificate of Medical Necessity (CMN). 

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INTRODUCTION 

These initial CMNs are usually submitted to DMERCs electronically. 

The CMN for power wheelchairs, CMS Form 843, is divided into 

different sections. Suppliers complete sections relating to their 

company, the beneficiary, and the ordering physician. They also provide 

information about the type of equipment ordered, their charge for the 

equipment, and the Medicare allowance. The ordering physician or an 

employee of the physician completes sections regarding the patient’s 

medical condition. In order for a power wheelchair to be covered by 

Medicare, the physician must respond, “Yes” to the following questions 

on the CMN: 

o Does the patient require and use a wheelchair to move around in 

their residence? 

o Does the patient have severe weakness of the upper extremities 

due to a neurologic, muscular, or cardiopulmonary 

disease/condition? 

o Is the patient unable to operate any type of manual wheelchair? 

The ordering physician must then sign and date the CMN. The supplier 

must maintain a hard copy of this signed CMN in its records and 

present it to the DMERC upon request. Information submitted to the 

DMERC by the supplier must be substantiated by documentation in the 

patient’s medical records. 

According to the Medicare Program Integrity Manual and the supplier 

manuals, suppliers must also maintain documentation showing that 

items were delivered to beneficiaries. Delivery documents must include 

the date of delivery, the patient’s name and signature, the quantity of 

the item(s) delivered, a detailed description of the item(s) delivered, and 

the brand name and serial number of the item(s). Proof of delivery 

must be available to the DMERC upon request. If a supplier cannot 

furnish this documentation, the DMERC can deny the claim and 

request an overpayment. 

Concerns About Medicare Payments for Power Wheelchairs 

In calendar year (CY) 2001, Medicare and its beneficiaries paid 

$538 million for all power wheelchairs. Payments for procedure code 

K0011, a standard-weight power wheelchair with programmable control 

parameters, accounted for 95 percent of this total ($513 million). In 

CY 2001, Medicare allowed approximately $5,000 for each K0011 power 

wheelchair. Payments for the K0011 code have been rising 

dramatically, increasing 43 percent from the year 2000 to 2001 alone. 

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INTRODUCTION 

In September 2003, CMS and the Office of Inspector General (OIG) 

issued a joint press release that cited a number of fraud cases involving 

power wheelchairs that were not supplied, not medically necessary, or 

both. OIG has also investigated cases where suppliers billed Medicare 

for a K0011 power wheelchair but provided beneficiaries with scooters, 

which are reimbursed at less than half the amount of K0011 power 

wheelchairs. In order to address significant increases in allowances for 

power wheelchairs and indications of improper billing activity, CMS has 

launched a campaign to curb abuse of the Medicare program by 

unscrupulous suppliers of mobility products. Initiatives in this 

campaign include: revising coverage policy for power wheelchairs and 

scooters to ensure that national policy accurately defines the conditions 

under which Medicare will cover mobility products; adopting a 

consistent approach to medical review; clarifying physicians’ 

responsibilities as prescribers of mobility devices; and educating 

beneficiaries about Medicare coverage guidelines. 

METHODOLOGY 

Sample Design 

We focused our review on procedure code K0011, which is a standardweight power wheelchair with programmable control parameters for 

speed adjustment, tremor dampening, acceleration control, and braking. 

We extracted all paid claims for procedure code K0011 from CMS’s 2001 

National Claims History File. According to this claims data, 99 percent 

of all expenditures for K0011s were for first-month purchases. 

Therefore, our sampling frame of 100,124 claims included only K0011 

power wheelchairs that were purchased by the beneficiary in the first 

month. Claims for rentals were not included. We selected a simple 

random sample of 386 claims from the sampling frame. Using 

information from CMS’s beneficiary enrollment database, we then 

removed claims associated with deceased beneficiaries. We also 

removed claims with suppliers or ordering physicians that were under 

investigation by OIG’s Office of Investigations. We removed a total of 

86 claims, resulting in a final sample of 300 power wheelchair claims. 

These 300 sample claims represent an estimated $394 million in 

allowances for K0011 power wheelchairs.

Data Collection

Supplier Contacts. We identified suppliers who submitted the sample 

claims and contacted these suppliers using address information from 

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INTRODUCTION 

CMS’s National Supplier Clearinghouse. We requested that suppliers 

provide us with CMNs and additional documentation in support of 

sample claims. We also requested that suppliers provide delivery 

records for these sample items. 

We made up to three attempts to contact each supplier by overnight 

mail with a signature request. We received responses for 272 of the 300 

claims in our sample. We could not locate suppliers for 17 claims due to 

incorrect address information; therefore, we did not include these claims 

in our analysis of supplier documentation. We did not receive responses 

for 11 claims. For the purposes of our study, we concluded that the 

suppliers for these claims did not have supporting documentation, and 

included the claims in our analysis of missing CMNs and delivery 

documentation. Therefore, a total of 283 claims were used in our 

analysis of CMNs and delivery documentation. 

Physician Contacts. Using address information collected from suppliers, 

we contacted the ordering physicians for sample claims. We requested 

copies of Medicare beneficiaries’ medical records in support of sample 

claims for power wheelchairs. Specifically, we requested all 

documentation (including office visit notes, referrals for physical or 

occupational therapists, and hospital admission histories and discharge 

summaries) from the 6-month period prior to and including the date on 

the sample claim. 

Suppliers were able to provide physician address information for 271 

claims. We made up to three written attempts to contact these 

physicians. We did not receive responses for 15 claims and were unable 

to contact ordering physicians for an additional 9 claims due to incorrect 

addresses. We did receive responses for 247 claims; however, 

physicians did not submit the requested information for 35 of these 

claims. For 7 of the 35 claims, the physicians indicated that they never 

ordered the power wheelchairs. These seven claims have been referred 

to OIG’s Office of Investigations for further development. 

Beneficiary Contacts. Using numbers obtained from both suppliers and 

the Internet, we telephoned the beneficiaries for whom sample 

wheelchairs were ordered. We asked beneficiaries how they learned 

about suppliers, whether suppliers provided them with equipment, and 

whether they have used the equipment. We also asked each beneficiary 

specific questions about the equipment provided, such as the brand 

name, model number, and serial number of the item. 

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INTRODUCTION 

We completed telephone interviews with 166 of the 300 beneficiaries in 

our sample. Responses from these 166 beneficiaries formed the basis for 

our analysis. We did not project our results to the population. Of the 

134 non-respondents, 69 were beneficiaries for whom we could not find 

telephone numbers, 41 were beneficiaries who could not be reached by 

telephone, and 24 were beneficiaries who refused to participate. 

Coverage Review. We ultimately forwarded a total of 230 medical 

records received from physicians and/or suppliers to an independent 

medical review contractor. Claims for these 230 medical records 

represent an estimated $303 million in allowances for K0011 power 

wheelchairs. Table 1 below shows the results of our effort to collect 

medical information that could be used in a coverage review. 

Number of Claims 

Table 1. Data Collection Results: Records for Coverage Review 

Claims That Were Sent for Coverage Review 230 

Physician Provided Useable Medical Records 

Physician Responded But Did Not Provide Useable Medical 

Records; Supplier Provided Useable Records 

Physician Could Not Be Contacted But Supplier Provided Useable 

Medical Records 

Physician Did Not Respond But Supplier Provided Useable Medical 

Records 

212 

11 

2 

5 

Claims That Were Not Sent for Coverage Review 70 

Supplier Did Not Respond, Could Not Be Contacted, Or Did Not 

Provide Address Information for Physician 

Physician Responded But Did Not Provide Useable Medical 

Records; Supplier Did Not Provide Useable Records 

Physician Could Not Be Contacted And Supplier Did Not Provide 

Useable Medical Records 

Physician Did Not Respond And Supplier Did Not Provide Useable 

Medical Records 

29 

24 

7 

10 

Total Claims in Sample 300 

Source: OEI Analysis of Supplier and Physician Data Collection Results, 2003 

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INTRODUCTION 

The medical review contractor conducted a coverage review of the 

records using a data collection instrument jointly developed by our office 

and the contractor. The coverage review instrument included questions 

regarding the patient’s diagnosis, physical condition, ability to 

ambulate, and ability to operate a power wheelchair. The reviewer 

determined whether the K0011 power wheelchair met the Medicare 

coverage criteria outlined in the DMERC supplier manuals. For cases 

where the physician reviewer determined that the K0011 power 

wheelchair did not meet the Medicare coverage criteria, the reviewer 

indicated whether another, less expensive, mobility device would have 

been appropriate for the patient, given both the coverage criteria and 

the information in the medical records. The reviewer had the option of 

“downcoding” to one of the following mobility devices: a K0010 power 

wheelchair, which is a standard-weight power wheelchair without 

programmable controls; a scooter; or a manual wheelchair. It is 

important to note that we did not specifically request records to support 

any item other than the K0011 power wheelchair. Also, we did not 

assess the appropriateness of the Medicare coverage criteria. 

Data Analysis 

We reviewed CMNs for sample claims to determine whether the 

information was complete. We then estimated the proportion of claims 

for power wheelchairs with incomplete CMNs. We also determined 

whether suppliers’ delivery records for sample wheelchairs included the 

required information. We analyzed beneficiary survey responses to 

determine whether suppliers actually provided equipment to the 

beneficiary and whether beneficiaries used the equipment. We also 

identified the ways in which beneficiaries learned about their suppliers. 

We aggregated data received from the medical review contractor and 

estimated the proportion of sample claims that did not meet Medicare’s 

coverage criteria for a K0011 power wheelchair. To compute 

inappropriate payments, we totaled the allowances for all claims that 

did not meet Medicare’s coverage criteria for procedure code K0011. 

However, we used adjusted allowances for cases where beneficiaries did 

not meet the coverage criteria for a K0011 power wheelchair but would 

have qualified for a K0010 power wheelchair, a scooter, or a manual 

wheelchair. We then computed the difference between the original and 

adjusted allowances for these claims. Adjusted allowances were derived 

from the 2001 DME fee schedule ceiling amounts for procedure codes 

K0010, E1230 (scooter), and K0005 (ultra-lightweight manual 

wheelchair). We used procedure code K0005 for the adjusted allowance 

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INTRODUCTION 

because it has the highest reimbursement amount of any manual 

wheelchair and is, therefore, the most conservative figure. 

This study was conducted in accordance with the Quality Standards for 

Inspections issued by the President=s Council on Integrity and 

Efficiency. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 8 
� FINDINGS

Most reviewed claims did not meet Medicare’s 

coverage criteria for a K0011 power wheelchair; 

however, some claims may have met coverage 

criteria for a less expensive mobility device 

Only a small percentage of 

reviewed claims (13 percent) met 

Medicare’s coverage criteria for a 

K0011 power wheelchair, as 

illustrated in Chart 1 below. 

CHART 1

Results of Coverage 

Review for K0011 

Power Wheelchairs, 

n = 230.

Although 31 percent of claims did not meet coverage criteria for any 

mobility device, another 45 percent of claims may have met criteria for 

another, less expensive item. 

Claim Did Not Meet 

Criteria for Any 

Mobility 

31% 

Claim Met Criteria 

for Another 

Mobility Device 

45% 

Claim Met K0011 

Criteria 

13% 

Could Not 

Determine if Claim 

Met K0011 Criteria 

11% 

Device 

Source: OEI Analysis of Coverage Review Results, 2003 

Almost one-third of reviewed claims did not meet Medicare’s coverage 

criteria for any type of wheelchair or scooter. 

A medical review contractor determined that 31 percent of reviewed 

claims did not meet Medicare’s coverage criteria for either a K0011 

power wheelchair or any other type of wheelchair or scooter. In 

CY 2001, Medicare and its beneficiaries paid an estimated $96 million 

for claims that did not meet Medicare’s coverage criteria for any type of 

wheelchair or scooter. The estimate does not account for any 

accessories that may have been billed in conjunction with the power 

wheelchairs (e.g., arm rests, leg rests, and cushions). If a power 

wheelchair does not meet Medicare’s coverage criteria, then any 

associated accessories would not be covered. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 9 
FINDINGS 

Beneficiaries in all of these cases were able to ambulate, although some 

did so with the assistance of a cane or walker. According to the 

coverage criteria for any type of wheelchair, the patient’s condition must 

be “such that without the use of a wheelchair the patient would 

otherwise be bed or chair confined.” Therefore, if beneficiaries are 

ambulatory (i.e., not bed or chair confined), they do not qualify for a 

wheelchair or scooter under Medicare’s coverage guidelines. Physicians, 

however, may not be familiar with this coverage criterion when ordering 

mobility devices for their patients. Medicare’s coverage criteria for 

power wheelchairs are outlined only in DMERC supplier manuals, 

which are provided to the suppliers who bill for medical equipment but 

not the physicians who order it. The only document that physicians are 

required to review and complete when ordering a wheelchair is the 

CMN. Coverage guidelines are not listed on the CMN for power 

wheelchairs, nor do any of the medical necessity questions on the CMN 

require physicians to address whether patients are non-ambulatory. 

An additional 45 percent of reviewed claims did not meet Medicare’s 

coverage criteria for the K0011 power wheelchair but may have met criteria 

for another type of wheelchair or scooter. 

According to the medical review contractor, 45 percent of reviewed 

claims did not meet Medicare’s coverage criteria for a K0011 power 

wheelchair but may have met criteria for a scooter, K0010 power 

wheelchair, or manual wheelchair. In CY 2001, Medicare and its 

beneficiaries spent an estimated $82 million in excessive payments for 

claims that could have been billed using a code for a less expensive 

mobility device. Physicians may not be aware of the differences in 

coverage criteria among the mobility devices available to Medicare 

beneficiaries. Discrepancies between medical necessity questions on the 

CMN and coverage criteria could also cause confusion about the medical 

conditions for which K0011 power wheelchairs would be most beneficial. 

For example, question 6 in section B of the CMN for power wheelchairs 

allows physicians to attribute an upper extremity weakness to a 

cardiopulmonary disease/condition, whereas the coverage guidelines 

refer only to a neurologic or muscular disease/condition. 

Twenty-three percent of reviewed claims did not meet the coverage 

criteria for a K0011 power wheelchair but would have met the coverage 

criteria for a scooter. The beneficiaries in these cases were nonambulatory, unable to self-propel a manual wheelchair, and had 

sufficient trunk stability and transfer ability to safely operate a scooter. 

Their medical conditions did not warrant a higher-level power 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 10 
FINDINGS 

wheelchair. Some beneficiaries may have received K0011 power 

wheelchairs rather than scooters because their ordering physicians were 

not able to prescribe scooters. A scooter is usually covered only if it is 

ordered by a specialist in physical medicine, orthopedic surgery, 

neurology, or rheumatology; however, there are no such restrictions for 

a K0011 power wheelchair, which costs twice as much as a scooter. 

Guidelines regarding the specialties of physicians who order scooters 

may actually prevent beneficiaries from getting the equipment that best 

suits their needs, and could lead to excessive Medicare payments if 

K0011 power wheelchairs are provided in lieu of scooters. 

For 8 percent of reviewed claims, the beneficiary did not meet 

Medicare’s coverage criteria for a K0011 power wheelchair but would 

have qualified for a K0010 power wheelchair. In most of these cases, 

the beneficiaries were non-ambulatory with significant trunk instability 

and upper extremity weakness but did not have a medical condition 

that would require programmable controls. Medicare coverage 

requirements do not currently provide any guidance as to the medical 

conditions that might benefit from programmable controls. 

An additional 3 percent of reviewed claims would have met the coverage 

criteria for a manual wheelchair rather than a K0011 power wheelchair. 

For these cases, the medical records usually indicated that the 

beneficiaries were non-ambulatory but had sufficient upper extremity 

strength to operate some type of manual wheelchair. 

Eleven percent of reviewed claims did not meet the coverage guidelines 

for a K0011 power wheelchair but may have met criteria for another 

type of wheelchair or scooter. These claims did not meet coverage 

criteria for a K0011 power wheelchair because the beneficiary did not 

need programmable controls. However, due to scanty medical 

documentation, the reviewer was unable to determine what other 

mobility device may have been appropriate for the beneficiary. 

Only 13 percent of reviewed claims met the coverage criteria for a K0011 

power wheelchair. 

In CY 2001, Medicare paid an estimated $38 million for claims that met 

the coverage criteria for K0011 power wheelchairs. The beneficiaries in 

these cases were clearly non-ambulatory, had upper extremity 

weaknesses, and required programmable controls, usually due to 

contractures, tremors, or spasticity. 

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FINDINGS 

Due to insufficient documentation, the reviewer could not determine 

whether another 11 percent of reviewed claims met the coverage criteria for 

the K0011 power wheelchair. 

Insufficient documentation prevented the medical reviewer from 

determining whether an additional 11 percent of reviewed claims met 

the coverage criteria for K0011 power wheelchairs. In CY 2001, 

Medicare and its beneficiaries paid an estimated $34 million for these 

claims. In half of these cases, the medical record did not provide a clear 

description of the beneficiaries’ ambulatory or functional status. In 

other cases, it was clear that the beneficiary was bed or chair confined, 

but there was not enough information to determine whether 

programmable controls were necessary. 

For over half of K0011 claims, CMNs and/or CMNs and/or delivery 

delivery documentation were missing, incomplete, documentation for 52 percent of 

or dated after the date of service. K0011 power wheelchair claims 

were missing, incomplete, or 

dated after the date of service on the claim. Some claims had one or more 

of these documentation problems. Typically, CMNs are submitted 

electronically to the DMERCs; therefore, original copies of CMNs are not 

reviewed unless DMERCs specifically request this information from the 

supplier on a pre- or post-pay basis. Similarly, suppliers are not required 

to submit proof of delivery with the initial claim for payment, and 

DMERCs only collect delivery documentation as part of a pre- or post-pay 

review. 

Five percent of power wheelchair claims did not have the required 

supporting documentation. 

For 5 percent of K0011 power wheelchair claims, suppliers did not provide 

a CMN and/or proof of delivery. According to DMERC requirements, 

suppliers must maintain copies of signed CMNs and furnish them upon 

request. Suppliers must also maintain documentation showing that items 

were delivered to beneficiaries. If suppliers cannot provide this 

documentation, DMERCs can deny the claims and request overpayments. 

We estimate that Medicare and its beneficiaries paid an additional 

$19 million in CY 2001 for K0011 claims that could not be substantiated 

by either a CMN or delivery documentation. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 12 
FINDINGS 

Even when suppliers did submit CMNs or proof of delivery, the 

documentation was often incomplete or dated after the date of service. 

Although DMERCs require that all elements contained on CMNs be 

completed, original paper CMNs obtained from suppliers for 20 percent of 

claims had at least one item missing. The supplier’s National Supplier 

Clearinghouse number and the supplier’s charge for the wheelchair were 

the items most often missing from CMNs. 

In addition, CMNs for 13 percent of claims were dated after the service 

date. Almost one-quarter of these CMNs were dated more than a month 

after the date of service on the sample claim, with three CMNs dated 

almost a year after the date of service. 

Although most suppliers submitted proof that power wheelchairs were 

delivered, delivery documentation supporting 29 percent of claims was 

missing one or more of the required elements. Quantity, serial number, 

and brand name of items delivered were the elements most often missing 

from delivery documents. In addition, delivery documentation for 

5 percent of claims showed that the power wheelchair was delivered to the 

beneficiary after the date of service listed on the Medicare claim. In one 

case, the wheelchair was delivered 2 months after the supplier billed 

Medicare. 

Most responding beneficiaries reported using their Sixty-eight percent of 

power wheelchairs at home; other beneficiaries beneficiaries who responded to 

either do not use their power wheelchairs or use our survey (113 of 166) 

currently use their power them for outside activities only. wheelchairs inside their 

homes. The wife of one beneficiary explained that the power wheelchair 

“is a necessary part of [her husband’s] life. It’s given him back a sense 

of mobility...It gave him back quality of life.” Another beneficiary 

volunteered, “It’s a wonderful invention, without it I would be crawling 

on the floor.” 

Although many beneficiaries offered positive comments about their 

wheelchairs and the sense of freedom they provide, 4 percent of 

respondents said that they have never used their power wheelchairs. 

One of these beneficiaries stated, “I don’t need it yet...When my doctor 

approved it he said for later use. I am walking with a walker.” Two 

other beneficiaries said that they never used their power wheelchairs 

because no one showed them how to use the equipment. 

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FINDINGS FINDINGS 

An additional 12 percent of respondents said that they do not currently 

use their power wheelchairs but have used them in the past. Some of 

these beneficiaries no longer use their wheelchairs because the 

equipment is too big and heavy. One beneficiary stated, “It's not the 

chair my doctor said I needed when they brought it out and I told them 

so...The wheelchair is too large and too fast...If I used it in my house I 

would tear up my furniture...I just don't like it.” Other beneficiaries do 

not currently use their power wheelchairs due to unresolved 

maintenance problems, such as dead batteries or flat tires. One 

beneficiary said, “I haven’t had my chair since July 2002. The chair was 

picked up to be adjusted. I have contacted [the supplier] many, many 

times asking about my chair...I just keep getting the run around.” 

Another beneficiary reported, “The tires are flat...This is the second 

time the tires have gone flat...The supplier has been saying for months 

that they would pick up their chair but they have not.” 

Another 12 percent of respondents reported that they currently use 

their power wheelchairs outside the home only. According to Section 

1861(n) of the Social Security Act, a wheelchair must be needed for use 

in the home. Almost half of these beneficiaries indicated that they do 

not use their wheelchairs inside because the equipment is too large and 

does not fit in their homes. One respondent noted, “My apartment isn’t 

big enough. I use it when I go out like for a baby shower or to see my 

grandkids play baseball.“ Another beneficiary said, “I wanted a smaller 

model.” 

Many beneficiaries who completed our Almost one-quarter of beneficiaries 

survey responded to suppliers’ who responded to our survey learned 

direct marketing practices. about their power wheelchair 

suppliers from a television 

commercial. As one beneficiary explained, “I saw the commercial. They 

said it is free and I thought ‘why not.’ They were thrilled, I gave them 

my doctor’s fax number. I had it in 2 days.” However, this same 

beneficiary commented that the wheelchair she received was “not what I 

thought they advertised for.” Another beneficiary said, “I saw it on TV. 

They were advertising. I called the company up. They sent me a video. 

They got in touch with my doctor and he came back and said it was 

approved.” The beneficiary also noted, “If I knew what it cost I would 

not have gotten it. I would have gotten something cheaper. I had no 

idea how much it cost until I got the Medicare bill.” An additional 

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FINDINGS FINDINGS 

9 percent of respondents chose their suppliers after receiving something 

in the mail. Four percent of respondents obtained their power 

wheelchairs from suppliers who visited their homes. One of these 

beneficiaries commented, “the door-to-door sales rep gave me $50 for 

signing up and offered me $50 for referrals.” 

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OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 16

EXECUTIVE SUMMARY

A power wheelchair can greatly improve the quality of life for an 

individual who otherwise suffers from limited mobility. However, our 

coverage review indicates that Medicare and its beneficiaries spent an 

estimated $178 million in 2001 for K0011 power wheelchairs that did 

not meet Medicare’s coverage criteria. These inappropriate payments 

waste taxpayer dollars that could otherwise fund appropriate 

equipment for needy Medicare beneficiaries.

CMS has recognized the dramatic growth in payment for and utilization 

of power wheelchairs and is currently taking steps to address these 

issues as part of its 10-point plan of action to curb power wheelchair 

fraud, waste, and abuse. In fact, CMS has already begun implementing 

some of the options listed in the following recommendation. We believe 

that continued attention to Medicare payments for K0011 power 

wheelchairs is warranted.

We recommend that CMS improve compliance with Medicare’s coverage 

criteria for K0011 power wheelchairs. CMS should consider the following 

options in order to improve compliance:

Require DMERCs to revise the coverage policy for K0011 power wheelchairs 

to include specific information about the medical conditions for which Medicare 

will cover this item. Our findings show that many beneficiaries did not 

meet coverage criteria for the K0011 power wheelchair but may have 

qualified for a lower-priced power wheelchair, a scooter, or a manual 

wheelchair. Given that patients frequently received K0011 power 

wheelchairs when their conditions warranted a lower level of 

equipment, CMS should evaluate the medical conditions and functional 

abilities that are associated with different types of mobility aids and 

describe these conditions/abilities in the coverage policies. This will 

ensure that beneficiaries have access to the equipment that is most 

appropriate for their conditions. DMERCs should also consider 

removing guidelines regarding the specialties of physicians who order 

scooters. In addition, DMERCs should require that physicians treat the 

patients for whom they order equipment. 

Require DMERCs to conduct frequent reviews of the K0011 procedure code to 

ensure appropriate payments. When performing reviews of K0011 claims, 

DMERCs should ensure that suppliers have complete and thorough 

documentation. DMERCs should also request medical records from 

ordering physicians in addition to supporting documentation from 

suppliers. DMERCs should also consider routinely contacting 

0 RECOMMENDATION
RECOMMENDATION RECOMMENDATION 

beneficiaries during the course of reviews to ensure that the equipment 

provided by suppliers is appropriate for and useful to beneficiaries. 

Educate ordering providers about Medicare’s coverage criteria for different 

types of assistive devices, including power wheelchairs, manual wheelchairs, 

and scooters. Ordering providers play a key role in determining the 

need for and utilization of equipment billed to Medicare. According to 

the Medicare Prescription Drug, Improvement, and Modernization Act 

of 2003, payment may not be made for power wheelchairs unless a 

physician, physician’s assistant, nurse practitioner, or clinical nurse 

specialist has conducted a face-to-face examination of the patient and 

written a prescription for the item. CMS relies on the clinical judgment 

of these health care professionals to ensure that Medicare only pays for 

items that are most appropriate for beneficiaries. However, ordering 

providers may not be aware of Medicare’s coverage requirements for 

mobility devices. A lack of provider education about Medicare’s 

coverage criteria for wheelchairs could adversely affect physicians’ 

ability to make informed decisions about the types of mobility devices 

that are best for their patients, which could ultimately lead to 

inappropriate Medicare payments. 

Educate Medicare beneficiaries about coverage criteria for wheelchairs and 

scooters. Beneficiaries also play a key role in ensuring that Medicare 

does not pay for medically unnecessary or unused items. Beneficiaries 

who are knowledgeable about Medicare’s coverage guidelines can make 

more informed choices about the assistive devices that would meet both 

their own needs and Medicare’s coverage requirements. 

Agency Comments 

CMS concurred with our recommendation and agreed with our 

suggestions regarding coverage policy revisions and provider and 

beneficiary education. They also agreed that more frequent reviews of 

the K0011 code will help ensure appropriate payments; however, they 

do not believe that routinely contacting beneficiaries would yield 

meaningful results. CMS confirmed that they have already begun 

implementing many of our report recommendations through their power 

wheelchairs workgroup, which was established to develop a plan of 

action to ensure that payments are only made for power wheelchairs 

that are reasonable and necessary. Specific actions by CMS include: 

requiring DMERCs to develop a complete picture of a patient’s medical 

condition before making medical review coverage determinations; 

developing a regulation to remove the current requirement that scooters 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 17 
RECOMMENDATION 

be prescribed only by certain specialists; and developing a regulation 

that requires a face-to-face examination by the treating physician prior 

to ordering a power wheelchair. CMS is also poised to release an 

educational campaign designed to provide both physicians and 

beneficiaries with needed information regarding Medicare and DMERC 

coverage policy. The full text of CMS’s comments is presented in 

Appendix B. 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 18 
� APPENDIX ~ A 

Table 1. Estimates and Confidence Intervals 

Point Estimate 95 % Confidence Interval 

Claims Where No Other Item Would Have Been Appropriate 31.30% 25.31% - 37.30% 

Claims That Did Not Meet K0011 Coverage Criteria But May Have 

Met Criteria For Another Item 44.78% 38.35% - 51.21% 

Total Medicare Allowances in 2001 for Claims That Did Not Meet 

Coverage Criteria for Any Wheelchair or Scooter $95,732,940 $77,333,457 - $114,132,423 

Excessive Medicare Allowances in 2001 for Claims That Did Not 

Meet K0011 Coverage Criteria But May Have Met Criteria for 

Another Item 

$82,274,760 $68,472,518 - $96,077,002 

Claims That Did Not Meet K0011 Coverage Criteria But Would Have 

Qualified For Scooter 23.04% 17.60% - 28.49% 

Claims That Did Not Meet K0011 Coverage Criteria But Would Have 

Qualified For K0010 8.26% 4.70% - 11.82% 

Claims That Did Not Meet K0011 Coverage Criteria But Would Have 

Qualfied For Manual Wheelchair 2.61% 0.55% - 4.67% 

Claims That Did Not Meet K0011 Coverage Criteria And Reviewer 

Could Not Determine If Another Item Would Have Been Appropriate 10.87% 6.85% - 14.89% 

Claims That Met K0011 Coverage Criteria 12.61% 8.32% - 16.90% 

Total Medicare Allowances in 2001 for Claims that Met K0011 

Coverage Criteria $38,288,606 $25,217,076 - $51,360, 135 

Claims Where Reviewer Could Not Determine Whether K0011 

Coverage Criteria Were Met 11.30% 7.21% - 15.40% 

Total Medicare Allowances in 2001 for Claims Where Reviewer 

Could Not Determine Whether K0011 Coverage Criteria Were Met $34,117,123 $21,722,810 - $46,511,437 

Claims With Documentation That Was Missing, Incomplete, or Dated 

After Date of Service 51.94% 46.12% - 57.76% 

Claims Without CMNs or Delivery Documentation 5.30% 2.69% - 7.91% 

Total Medicare Allowances in 2001 for Claims Without CMNs 

and/or Proof of Delivery $19,141,660 $9,692,065 - $28,591,254 

Claims With CMNs With At Least One Item Missing 19.63% 14.89% - 24.37% 

Claims With CMNs Dated After Date of Service 12.69% 8.70% - 16.67% 

Claims With CMNs Dated After Date of Service That Were Dated 

More Than a Month After Date of Service 23.53% 9.08% - 37.97% 

Claims With Delivery Documentation With At Least One Item Missing 29.00% 23.57% - 34.42% 

Claims With Delivery Documentation Dated After Date of Service 4.83% 2.27% - 7.40% 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 19
� A PPENDIX ~ B

Comments from the Centers for Medicare & Medicaid Services 

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APPENDIX~B 

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APPENDIX~B 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 22
� ACKNOWLEDGEMENTS

This report was prepared under the direction of Robert A. Vito, Regional 

Inspector General for Evaluation and Inspections in the Philadelphia 

Regional Office, and Linda M. Ragone, Deputy Regional Inspector 

General. Other principal Office of Evaluation and Inspections staff who 

contributed include: 

Lauren McNulty, Team Leader 

Jennifer Baraldi, Program Analyst 

Cynthia Hansford, Program Assistant 

Stephanie London, Program Specialist 

OEI - 03 - 02 - 00600 MEDICARE P AYMENTS F OR P OWER W HEELCHAIRS 23