What Medicare covers, and in what order
Coverage runs as a ladder: cane or walker, then manual wheelchair, then scooter, then power wheelchair. Each rung has to be ruled out in writing before the next one is on the table, and the coverage policy says who writes it and what it has to say.
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, which carries its own revision history. Confirm it in the same database.
The words you will hear
None of these are words anyone uses at home. They are the words on the forms, and knowing them makes the next appointment shorter.
- LCD — Local Coverage Determination. The written coverage policy the Medicare contractor applies to a claim. Power mobility is L33789; the seating and accessory rules are L33792.
- NCD — National Coverage Determination. A national rule that sits above an LCD. One of them, NCD 280.16, governs power seat elevation.
- PMD — power mobility device. The umbrella term covering scooters and power wheelchairs alike.
- POV — power-operated vehicle. The policy's name for a scooter.
- PWC — power wheelchair.
- MRADL — mobility-related activity of daily living. The tasks the policy measures against: toileting, feeding, dressing, grooming, bathing, done in your own home.
- F2F — face-to-face. The visit about how you get around that every power mobility claim rests on. It does not have to be in person: Medicare accepts a telehealth encounter, provided it meets the telehealth conditions that apply to any other visit.
- SWO — standard written order. The signed, dated order for a piece of equipment. Since 2020 it is the same order for everything Medicare covers, and it has to carry six specific things — listed on the page for your doctor.
- WOPD — written order prior to delivery. The same order, with the requirement that the supplier holds it before the equipment arrives.
- ATP — Assistive Technology Professional, certified by RESNA, the Rehabilitation Engineering and Assistive Technology Society of North America. Required, in person, for the specialty levels of chair.
- SPO and MPO — single power option and multiple power options. How many powered seat or drive functions a chair carries.
- ABN — Advance Beneficiary Notice. The form a supplier gives you, before delivery, stating in writing what you would owe if Medicare does not pay.
Before the ladder: what the note has to establish
Nothing on the ladder matters until the record answers a first question — what, at home, is hard, unsafe or impossibly slow because of how you move around.
A mobility limitation that gets in the way of everyday tasks at home
Your note has to name the everyday things at home that are hard, unsafe, or take far too long because of how you move around — using the toilet, eating, getting dressed, grooming, bathing. Not only that walking is hard — which task, in which room, and what happens when you try.
Two words in that requirement do a lot of work. Home: the policy measures the tasks you do inside your own home, not the parking lot or the grocery store. And the standard is not only that a task is impossible — it also counts if attempting it puts you at serious risk, or if it takes far longer than a reasonable time.
A PMD is not covered without a qualifying mobility limitation. Denied as not reasonable and necessary if this criterion is not met.
The ladder
The policy does not ask which device you want. It asks, in order, why each cheaper and simpler one will not do — and it wants the answers written down by a practitioner, not assumed.
Rung 1 — a cane or a walker
Your note has to answer one question in writing: why will a cane or a walker, fitted properly for you, not be enough at home? “The patient would prefer a wheelchair” is not an answer to that question.
The word fitted matters. The comparison the policy has in mind is a walker set up correctly for you, not one borrowed years ago at the wrong height.
The LCD requires cane/walker to be ruled out. Denied as not reasonable and necessary if this criterion is not met.
Rung 2 — a manual wheelchair you push yourself
Your note has to describe what your arms and shoulders can actually do — strength, how long before they tire, how far they move, pain, coordination — and why pushing a manual wheelchair around your home all day is not realistic for you.
The comparison is an optimally-configured manual wheelchair — one set up properly for you — used for a typical day of tasks at home. Findings, not adjectives: what the examination showed about strength, endurance, range of motion, coordination and pain.
Manual wheelchair must be ruled out on documented upper-extremity findings. Denied as not reasonable and necessary if this criterion is not met.
Rung 3 — a scooter, and whether your body can drive one
For a scooter, your note has to say whether you can get on and off it safely, work the tiller — the steering handle you hold and turn — and stay sitting upright while you drive it around your home.
POV denied if criteria A–I are not met. Denied as not reasonable and necessary if this criterion is not met.
Rung 3 — and whether it is safe to drive one
For a scooter, your note has to address your thinking, your judgment and your eyesight, and say whether they are up to driving one safely inside your home.
POV denied if criteria A–I are not met. Denied as not reasonable and necessary if this criterion is not met.
Rung 3 — and whether one fits your home
For a scooter, someone has to look at your home and write down the doorway widths, how much room you have to turn, and what the floors are like. Measurements, not “home is accessible”.
POV denied if criteria A–I are not met. Denied as not reasonable and necessary if this criterion is not met.
The scooter section runs to letter I. The remaining letters ask that your weight is inside the weight class of the scooter supplied (L33789 POV Criteria (G)), that the scooter improves specific tasks you do at home and will be used indoors (L33789 POV Criteria (H)), and that you have not said you would refuse to use one (L33789 POV Criteria (I)).
Rung 4 — the power wheelchair, once the scooter is ruled out
Before a power wheelchair, your note has to show a scooter was considered and say why it will not work for you at home — getting on and off it, steering it, sitting upright in it, or getting it through your rooms.
This is the rung people are most often surprised by. The policy reaches a power wheelchair by a specific route: criteria A, B and C are met, and one of the scooter criteria D, E or F is not. A record that never mentions a scooter has not walked that route, however clearly it describes the need for a chair.
A PWC is only covered once a POV has been ruled out on documented grounds. Denied as not reasonable and necessary if this criterion is not met.
The power wheelchair section then continues through letter O: who will drive the chair, and whether they can do it safely (L33789 PWC Criteria (J)/(K)); your weight against the chair's weight class (L33789 PWC Criteria (L)); the home assessment for the exact chair ordered (L33789 PWC Criteria (M)); the specific tasks at home the chair restores (L33789 PWC Criteria (N)); and that you are willing to use it indoors (L33789 PWC Criteria (O)). Why claims get denied takes the home assessment apart in full — it is the one the policy calls the most common audit finding.
Groups 1 and 2: the standard power wheelchairs
Power wheelchairs are sorted into five groups. Groups 1 and 2 are the standard chairs, and the difference between them lives in the equipment codes rather than in a coverage criterion — the coverage policy transcribed here does not draw a line between a Group 1 chair and a basic Group 2 chair. Your evaluator and the supplier's ATP choose between them.
What the policy does spell out begins where a Group 2 chair carries powered options. A chair at that level has to earn the option, and the two criteria below are how.
Group 2 with one powered option
If the chair needs a way to drive it other than a standard joystick — a head control, a sip-and-puff tube, switches — or it needs a powered tilt or powered recline seat, a specialist has to examine you and write that up. A chair at this level asked for only to get a raising seat, a standing feature, or powered legrests is denied.
That last sentence is worth reading twice. A seat that raises is a real need for a lot of people, and the policy still does not accept it, on its own, as the reason for a chair at this level.
A Group 2 SPO PWC provided only to accommodate seat elevation, a power standing feature, or power elevating legrests is denied as not reasonable and necessary.
Group 2 with more than one powered option
For a chair carrying more than one powered seat function, your file has to show you need powered tilt and powered recline together, or that a ventilator is mounted on the chair.
A Group 2 MPO PWC is denied as not reasonable and necessary if III(A) or III(B) is not met.
Group 3: the specialty level
Group 3 chairs are the specialty level, and the policy gates them three ways at once: the cause of the mobility limitation, an independent specialty evaluation, and a certified ATP in the room. All three, not one of three.
The cause the policy asks about
Group 3 chairs are for people whose trouble moving comes from a condition of the nerves or brain, a disease of the muscles, or a difference in the bones present from birth. Your doctor is the one who decides and writes down whether that fits your situation. You do not have to name anything yourself.
This is the single criterion that separates Group 3 from Group 2. It is a clinical finding, recorded by the practitioner who examined you.
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.
An independent specialty evaluation
A physical therapist, an occupational therapist, or a practitioner trained in wheelchair evaluations has to examine you and write a signed, dated report on why this chair and its features are needed. That person cannot have a money relationship with the company supplying the chair, and the file has to say so.
Missing or financially-conflicted specialty evaluation. Denied as not reasonable and necessary if this criterion is not met.
A RESNA-certified ATP, in person
The company supplying the chair has to employ an ATP — an Assistive Technology Professional, certified by RESNA, the Rehabilitation Engineering and Assistive Technology Society of North America — who specializes in wheelchairs. That person has to be with you in person while your chair is chosen. Their current certificate and a record of their involvement both go in the file.
This is a question worth asking a supplier on the first phone call, because it decides whether they can serve this order at all.
Missing ATP involvement or credential. Denied as not reasonable and necessary if this criterion is not met.
A Group 3 chair that also carries powered options
If a Group 3 chair also carries powered seat functions or a special way to drive it, the same write-up the Group 2 version of that chair needs has to be in the file as well.
The requirements stack rather than replace each other. Reaching Group 3 does not excuse the Group 2 option paperwork; it adds to it.
A Group 3 SPO or MPO PWC is denied as not reasonable and necessary if V(A) or V(B) is not met.
Group 4: not covered for use in the home
Added capabilities the policy says are not needed at home
Medicare will not pay for a Group 4 chair for use inside the home. Better paperwork does not change this — the policy states that a Group 4 chair supplied for use in the home will be denied. If one is still being ordered, ask the supplier for an ABN, an Advance Beneficiary Notice: the form that tells you in writing what you would owe before you agree to anything.
Everything else on this page is about what a record has to say. This is not. The policy's position is about the equipment class and about use in the home, so no amount of documentation moves it.
If a Group 4 PWC is provided it WILL be denied as not reasonable and necessary. This is categorical, not a documentation gap.
That is worth knowing before months go into pursuing one, and it is not a reason to stop. Ask your evaluator what a Group 3 chair, configured with the right seating and controls, would do for the tasks that are hard at home — and ask the supplier for the ABN in writing before anything is delivered, so any cost is a decision you make rather than a bill that arrives.
Group 5: chairs for a person who is still growing
Expected growth in height
Group 5 chairs are built for a person who is still growing. Your note has to say that growth in height is expected.
These are the pediatric configurations — a frame that can be let out as a child grows, rather than replaced. Everything on the ladder above still applies.
A Group 5 PWC is denied as not reasonable and necessary if criteria VII(A)–(C) are not met.
Power seating and seat elevation
Powered tilt, powered recline and a seat that raises are not part of the chair's own coverage. They are billed separately and judged under a second coverage policy — L33792, Wheelchair Options/Accessories — which is why a chair can be approved and a seat function on it denied.
What a powered tilt or recline seat requires
For a powered tilt or recline seat, three things have to be in the file: the paperwork that supports the power wheelchair itself, a seating and positioning evaluation by a therapist with no money relationship to the supplier, and a certified ATP — Assistive Technology Professional — who was there in person.
If these criteria are not met the power seating component(s) will be denied as not reasonable and necessary.
And the reason it is needed
Your note also has to give the reason the powered seat is needed. The policy accepts three: you are at high risk of a pressure sore and cannot shift your own weight; you use a catheter on a schedule and cannot get yourself from the chair to the bed; or the seat is needed to manage muscle tightness or spasms.
One of the three has to be documented, with clinical findings behind it. Comfort, on its own, is not one of the three.
If none of the three qualifying indications is documented the power seating component is denied as not reasonable and necessary.
A seat that raises
A seat that raises up is judged under two rules at once: this coverage policy, and a separate national rule — NCD 280.16, a National Coverage Determination covering power seat elevation. Your file has to satisfy both, so both have to be written to.
This page quotes L33789 and L33792. It does not carry the text of NCD 280.16 — ask your evaluator to document against that rule by name, and read it at the CMS Medicare Coverage Database alongside the coverage policy.
Seat elevation is governed by both this LCD and NCD 280.16 — both must be satisfied.
Where to go next
Knowing the ladder is most useful the hour before an appointment. Take the vocabulary with you, and take a list of what the note has to say.