What a power mobility order asks of an office
One documented face-to-face mobility evaluation. One written order, signed and dated before delivery, by the same practitioner who performed that evaluation. That is the part only this office can do, and it is the whole of the part only this office can do.
This page is written for the practitioner and the staff who will handle the chart, and it is short on purpose: an office deciding whether to take this on should be able to see the whole obligation before deciding.
In each block below, the marker in the margin and the heading are ours. Everything between the heading and the red-ruled note is the coverage policy’s own wording, quoted, and the red-ruled note is the consequence recorded against that requirement, reproduced word for word. The citation under the marker locates each block in the source.
Where this comes from
Based on Medicare Local Coverage Determination L33789 — Power Mobility Devices, revision effective . Coverage policy is revised periodically. Confirm current requirements against the CMS Medicare Coverage Database before relying on this. This page is information, not medical or legal advice, and does not determine whether you qualify for anything.
Options and accessories criteria come from a second determination, L33792 — Wheelchair Options/Accessories. Printed from wheelchairdoc.com/for-my-doctor/. Wheelchair Doc is published by DMEdocRx, a product of AppDev GNV / Mendoza Bros. Wheelchair Doc is not a medical provider and does not give medical advice.
The ask, stated in full
A power mobility device (PMD) order — a power wheelchair (PWC) or a power-operated vehicle (POV, the scooter category) — is not a prescription written on the way out of a visit about something else. Medicare’s Local Coverage Determination (LCD) L33789 asks for five things. Three of them are this office’s work.
This office
- Holds and documents a face-to-face encounter about mobility — the F2F.
- Writes an encounter note addressing general criteria A, B and C: the mobility limitation and its effect on activities at home, why a cane or walker is not sufficient, and the upper-extremity findings that bear on a manual wheelchair.
- Signs a Standard Written Order (SWO) for the base item, dated before delivery — the written order prior to delivery, or WOPD. Plus an order for anything billed separately.
Someone else
- The supplier performs the home assessment against the specific chair supplied.
- A therapist performs the specialty evaluation, and the supplier’s Assistive Technology Professional (ATP) attends the selection, where the equipment level requires them. Both are described below so the office knows when to expect them, not because the office provides them.
What this office is not being asked to do
Offices decline power mobility work because the request arrives shapeless and sounds like it could run for months. The bounds are worth stating.
- Not to select the equipment. The chair group, base item, seating and accessories are the supplier’s and the evaluator’s work.
- Not to perform or verify the home assessment.
- Not to guarantee an outcome. Coverage is determined by the payer on the record submitted. Nothing here asks anyone to predict that determination, and no part of this page states or implies that a given patient qualifies or does not.
- Not to take on a standing obligation. One encounter, one order, plus an order for any separately billed accessory.
- Not to write anything the chart does not support. Every requirement below asks for findings that already exist, recorded in the terms the policy uses.
The one part that cannot be delegated is the same-practitioner rule, and that one is statute rather than coverage policy.
The order, the window, and the signature
Four requirements turn on dates and signatures rather than on findings. The policy states each of them separately from the clinical criteria, and states a denial consequence for each.
The order is not paperwork that follows the chair: if a signed order reaches the supplier after the delivery date, the sequence itself defeats the claim regardless of what the note says. The six-month window is a comparison of two dates, the encounter note and the order, so an encounter after the order date — or more than six months before it — falls outside it. Where mobility came up during a visit held for another reason, the note still has to be dated and still has to address mobility on its own terms.
The same-practitioner rule is the one ordinary workflow breaks without noticing: one practitioner sees the patient, another signs what comes back from the supplier. A countersignature does not repair that and a colleague in the same practice does not satisfy it, and because it is statute there is no contractor discretion. The fourth requirement, a separate order for each separately billed item, usually surfaces after the fact — when a cushion or a specialty control is denied while the chair itself is paid.
The written order has to exist before delivery
SWO/WOPD for the base item, signed and dated by the treating practitioner BEFORE the delivery date.
If the supplier does not receive the order for the base item prior to delivery, the claim WILL be denied as not reasonable and necessary.
The encounter has to fall inside the six months before the order date
Dated F2F encounter note, and the WOPD date, demonstrating the encounter falls in the 6 months before the order.
An out-of-window face-to-face is one of the most common audit findings on PMD claims.
The practitioner who performed the encounter has to sign the order
The treating practitioner who completed the face-to-face requirements is the SAME practitioner who wrote the order for the PMD base item (Social Security Act §1834[a][1][E][iv]).
F2F note and WOPD showing the same treating practitioner on both.
A WOPD written by a different practitioner than the one who performed the F2F does not satisfy the statute.
Each separately billed item needs its own order
SWO listing each separately-billed option/accessory, reviewed and signed by a treating practitioner.
Separately-billed accessories without an SWO prior to claim submission are denied.
What has to be on the order itself
Since 1 January 2020 there is one order for every DMEPOS item Medicare pays for, and it is the same order whether the item is a wheelchair or a walker. Final Rule CMS-1713-F replaced the separate order types that came before it — the detailed written order, the five-element order, the seven-element order and the detailed product description — with a single standard written order.
This matters in a practical way that has nothing to do with policy. Offices that built a template around a “seven-element order” are working from a form that has not existed for years, and the elements they are carefully filling in are not the elements that get checked. There are six, and two of them are “or” where offices habitually supply both.
The six elements
Either half of elements 1 and 5 below satisfies the requirement on its own. A beneficiary name alone is enough; an MBI alone is enough. Supplying both is harmless and is what most offices do.
The standard written order/prescription must include the following elements:
- Beneficiary name or Medicare Beneficiary Identifier (MBI)
- Description of the item
- Quantity, if applicable
- Order date
- Treating practitioner name or National Provider Identifier (NPI)
- Treating practitioner signature
An order missing any of the six is not a valid order. For a power mobility device that is not a correctable paperwork gap after the fact, because the order also has to have reached the supplier before the chair was delivered — a replacement order signed later carries a later date, and the delivery is then ahead of the order.
F2F
A telehealth encounter can be the face-to-face encounter
A face-to-face encounter means an in-person or telehealth encounter between the treating practitioner and the patient.
The encounter still has to fall inside the six months before the order date, and still has to address mobility on its own terms. A telehealth encounter used for this purpose also has to meet Medicare’s own telehealth conditions at 42 CFR 410.78 and 414.65.
This is Medicare’s rule, and only Medicare’s
CMS-1713-F governs what Medicare requires. Other payers set their own documentation, and several still ask for the order types Medicare retired — a detailed product description most commonly. An office that learns “the detailed product order is gone” and applies that to a commercial or managed-Medicaid patient will find out at the denial.
Before you build a template around any of this, ask the supplier which payer the patient has and what that payer wants. The answer is different often enough to be worth the phone call.
What the encounter note has to address: A, B and C
Every PMD pathway runs through these three, scooter or power wheelchair. They are a sequence rather than a list: a mobility limitation affecting mobility-related activities of daily living (MRADL) in the home, then cane and walker ruled out, then manual wheelchair ruled out on upper-extremity findings. A note that establishes the limitation but does not record the two rule-outs has not met criteria (B) and (C), whatever it says about (A).
Each is specific in a way that a conclusion does not satisfy. A asks what the patient cannot do, or cannot do safely, or cannot do in a reasonable time, in the customary locations inside their own home — named tasks carry it, a general statement about ambulation does not. B is phrased as a question the note has to answer, and patient preference does not answer it. C is an examination criterion whose comparator is an optimally-configured manual wheelchair across a typical day, not a single transfer or a short push down a corridor.
The mobility limitation and its effect at home
The beneficiary has a mobility limitation that significantly impairs their ability to participate in one or more mobility-related activities of daily living (MRADLs) in the home — it prevents an MRADL entirely, places them at heightened risk of morbidity or mortality attempting it, or prevents completing it within a reasonable time frame.
Face-to-face encounter note describing the mobility limitation and how it interferes with MRADLs (toileting, feeding, dressing, grooming, bathing) in customary locations in the home.
A PMD is not covered without a qualifying mobility limitation. Denied as not reasonable and necessary if this criterion is not met.
Cane and walker ruled out
The mobility limitation cannot be sufficiently and safely resolved by an appropriately fitted cane or walker.
F2F note answering: why can a cane or walker not meet this beneficiary’s mobility needs in the home?
The LCD requires cane/walker to be ruled out. Denied as not reasonable and necessary if this criterion is not met.
Manual wheelchair ruled out on upper-extremity findings
The beneficiary does not have sufficient upper extremity function to self-propel an optimally-configured manual wheelchair in the home to perform MRADLs during a typical day. Strength, endurance, range of motion, coordination, pain, and deformity or absence of an upper extremity are all relevant.
Examination findings on upper extremity strength, endurance, ROM, coordination and pain; and why an optimally-configured manual wheelchair is not sufficient.
Manual wheelchair must be ruled out on documented upper-extremity findings. Denied as not reasonable and necessary if this criterion is not met.
Where a power wheelchair rather than a scooter is ordered, the note also has to show a POV was considered and record why it does not meet the patient’s needs in the home — transfer, tiller operation, postural stability, or the home itself. The device-specific criteria are set out on what Medicare covers.
When a specialty evaluation and an ATP are required
These attach to the equipment level, not to every order: Group 3 power wheelchairs, and Group 2 chairs carrying a drive control other than a standard proportional joystick, or a powered tilt or recline seating system. What separates Group 3 from Group 2 is the cause of the mobility limitation, and establishing that cause is the treating practitioner’s finding on the record.
Neither of the two below is performed by the ordering office. An office that knows they are coming can set the expectation with the patient in the same visit, rather than having the order stall weeks later. The financial-independence requirement on the evaluation is part of the criterion rather than a formality, and the Assistive Technology Professional’s involvement has to be in person — a remote sign-off does not meet it. Asking the patient which supplier they are working with, before the order is written, is the cheapest way to avoid a stalled claim.
IV(B)
The criterion that separates Group 3 from Group 2
Diagnosis and clinical findings establishing a neurological condition, myopathy or congenital skeletal deformity as the cause of the mobility limitation.
A Group 3 PWC is denied as not reasonable and necessary if criteria IV(A)–(D) are not met. This is the criterion that distinguishes Group 3 from Group 2.
The specialty evaluation, and its financial independence
A specialty evaluation was performed by a licensed/certified medical professional — such as a PT or OT, or a practitioner with specific training and experience in rehabilitation wheelchair evaluations — documenting medical necessity for the wheelchair and its special features. That PT, OT or practitioner may have NO financial relationship with the supplier.
Written specialty evaluation report, signed and dated, plus an attestation of financial independence from the supplier.
Missing or financially-conflicted specialty evaluation. Denied as not reasonable and necessary if this criterion is not met.
A supplier employing a RESNA-certified ATP, in person
The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional (ATP) who specialises in wheelchairs and who had direct, in-person involvement in the wheelchair selection for the beneficiary.
The ATP’s current RESNA certificate, and documentation of their direct in-person involvement in selecting this chair for this beneficiary.
Missing ATP involvement or credential. Denied as not reasonable and necessary if this criterion is not met.
Group 4 chairs: a categorical denial, not a documentation gap
Worth knowing before an order is written rather than after. The policy does not treat a Group 4 base supplied for use in the home as an evidence question, so no quantity of documentation changes the result. An order written for one should be accompanied by an Advance Beneficiary Notice (ABN), so the patient learns their financial exposure in writing and in advance rather than from a denial.
Group 4 power wheelchairs supplied for in-home use
Group 4 PWCs have added capabilities that are not needed for use in the home.
If a Group 4 chair is being supplied, record why and obtain an ABN — Medicare will not cover it for in-home use.
If a Group 4 PWC is provided it WILL be denied as not reasonable and necessary. This is categorical, not a documentation gap.
Software that produces this documentation
The patient who handed you this page may be asking you to use DMEdocRx. It is the product this site is published by, and it exists because these requirements are stable, public, and tedious to check by hand.
It holds the L33789 and L33792 criteria as structured items, walks the encounter against them, and produces the face-to-face note and the written order with the criteria addressed and the dates checked against each other. It shows which criteria the record currently addresses and which it does not. It does not decide coverage, and it makes no claim about the outcome of any claim.
Free for up to 5 active patients at a time. Practices with more can move to a paid plan; details at dmedocrx.com.
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