HCPCS code E0167 – Replacement commode pail or pan

Key takeaways

HCPCS Code E0167 covers a replacement pail or pan for a commode chair the patient already owns, not the chair itself.

The pail supplied with a new commode chair is bundled into the chair code, such as E0163, E0165 or E0168. It is never billed as E0167.

Bill E0167 with the RA modifier when a worn, broken or lost pail is replaced and the commode chair remains in use.

Missing orders, undocumented medical necessity for the commode and early replacements with no recorded reason are the denials to prevent.

Pabau’s claims management software submits E0167 claims and tracks their status, so replacement claims stay visible until they are resolved.

HCPCS Code E0167: Official descriptor and code details

HCPCS Code E0167 is a Level II code that the Centers for Medicare and Medicaid Services (CMS) maintains for durable medical equipment. The official descriptor reads Pail or pan for use with commode chair, replacement only.

The words “replacement only” set the billing rule. Suppliers bill E0167 when a patient’s existing pail or pan wears out, breaks or goes missing, and the commode chair stays in use.

What E0167 covers and what it excludes

E0167 covers the pail or pan that sits beneath a commode seat to collect waste, when it replaces one the patient already has. The first pail that ships with a chair falls outside the code.

• Included: A replacement pail or pan when the original is worn, broken or lost and the patient’s commode chair remains in use
• Excluded: The initial pail or pan supplied with a new commode chair, which is bundled into the chair code
• Excluded: The commode chair itself, billed under E0163, E0165, E0168, E0170 or E0171
• Excluded: Seat lifts, foot rests and other commode accessories that carry their own HCPCS codes, such as E0172 and E0175
• Excluded: A pail or pan for a commode chair that does not meet Medicare coverage criteria

Medicare’s commode policy article A52461 lists E0167 as a Column II code to the chair codes. A Column II item supplied at the same time as the chair is included in the chair’s allowance.

The decision below shows which of the three supply paths bills E0167.

A pail or pan bought over the counter, with no order and no qualifying commode chair, is not payable by Medicare under E0167.

Medicare coverage criteria for E0167

Medicare Part B covers commodes under the durable medical equipment benefit, and E0167 follows the chair. A replacement pail is payable when these conditions hold together.

• The patient owns a qualifying commode chair: The chair, coded E0163, E0165, E0168, E0170 or E0171, must meet the coverage criteria. It also has to still be in use.
• Medical necessity established: The Commodes LCD (L33736) requires that the patient be physically unable to use regular toilet facilities. Confinement to one room, or to a floor without a toilet, are typical examples.
• Written order on file: Keep a written order that meets the requirements of the applicable LCD and policy article.
• Replacement reason documented: Record why the original pail or pan needs replacing, whether wear, damage or loss.
• DMEPOS supplier accreditation: The billing supplier must hold current CMS DMEPOS accreditation. Claims from non-accredited suppliers are rejected regardless of clinical justification.

Two contractors administer these rules across the four DME MAC jurisdictions. Noridian handles Jurisdictions A and D, and CGS Administrators handles Jurisdictions B and C. Confirm the current LCD for the patient’s state before billing.

Related commode chair HCPCS codes

E0167 is billed only against a commode chair the patient already has. The table maps it to the chair codes behind that replacement. Billing E0167 with a new chair, instead of as a later replacement, is the quickest route to a denial.

The E0163 and E0168 pages cover the chair-level coverage and documentation that a replacement pail relies on.

Documentation requirements for billing E0167

The documentation set for E0167 has to show two facts. The commode chair qualifies, and the pail or pan needed replacing.

• Written order: Names the patient, the item (a replacement pail or pan for a commode chair) and the treating practitioner, with a signature. Follow the order rules in the applicable LCD and policy article.
• Medical necessity for the commode: Clinical notes that document the diagnosis and the functional limitation behind the commode chair.
• Commode chair history: Records showing the patient owns the chair and still uses it, such as the original order and delivery record.
• Reason for replacement: A note on whether the original pail was worn, broken or lost.
• Proof of delivery: A signed delivery receipt from the beneficiary or an authorized representative. DMEPOS signature requirements apply.
• Supplier records: Accreditation certificate, supplier number and claim records, kept for the retention period your MAC and the DMEPOS supplier standards set.

Replacement frequency and quantity limits

The standard expectation for E0167 is one pail or pan per commode chair in use. A second claim inside a short window needs a documented reason, such as damage or loss.

Frequency allowances can differ by DME MAC. Check your contractor’s current guidance before billing a second replacement close to the first.

How to bill E0167 step by step

E0167 billing depends on the commode chair claim that came before it. If DME claims are new to your team, our guide to medical billing basics covers the full claim cycle.

1. Confirm the replacement scenario. Check that the patient owns a qualifying commode chair, such as E0163, E0165 or E0168, and still uses it. A pail delivered with a new chair is not billed as E0167.
2. Obtain a written order. Get an order that meets the applicable LCD and policy article. It names the item, the patient and the treating practitioner.
3. Verify LCD applicability. Identify the patient’s DME MAC by state and review the Commodes LCD. Confirm the diagnosis and functional status meet its criteria.
4. Record the reason for replacement. Note whether the original pail was worn, broken or lost, and keep that note with the order.
5. Apply the correct modifier. Add RA to show the item replaces a DME item. Pair it with NU when the replacement is a new purchased item, following your MAC’s guidance.
6. Submit the claim with the correct code, modifier and place of service. Place of service for most DME is the beneficiary’s home (POS 12). Include the ordering practitioner’s NPI and the supplier NPI.
7. Retain the full documentation set. Keep the order, delivery receipt, replacement reason and commode chair records on file for audit requests.

Modifiers applicable to HCPCS Code E0167

Modifiers on E0167 tell the payer that the item replaces equipment and how it was supplied. Commode accessories are generally purchased, so rental modifiers rarely apply.

Validate modifier requirements against the applicable HCPCS Level II coding resources and your DME MAC’s current billing guidance. A missing RA on a replacement-only code invites an edit or a denial.

Common E0167 claim denial reasons

E0167 denials cluster around a few recurring errors, and most are preventable with a pre-submission check. The table maps each denial pattern to its root cause and fix.

Each denial arrives with a CARC and RARC pair. The guide to medical billing denial codes explains each pair, and a clear denial management process routes the rework to the right person.

How claims management software keeps E0167 replacement claims moving

Replacement pails are small claims that are easy to lose track of. When the order, delivery receipt and claim status sit in separate places, a denial can go unnoticed for weeks.

Pabau, the practice management platform we build, keeps those records on the patient’s file. Its end-to-end claims management submits the E0167 claim and tracks its status after submission.

Digital forms capture the written order and the signed delivery receipt against the same record. Your team can see what was sent, what came back and what still needs work.

Submit and track E0167 claims in one place

Pabau’s claims management submits your DME claims and tracks their status after submission. Orders and delivery receipts sit on the same patient record, ready for an audit request.

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Conclusion

E0167 has one rule worth building your process around. It pays for a replacement pail or pan, never for the one that ships with the chair.

Check the commode chair history before every E0167 claim, record why the pail needed replacing and add RA. That routine heads off the bundling, documentation and modifier denials this code attracts. Book a demo to see how Pabau submits and tracks DME replacement claims for your team.

Continue your research

Need a clearinghouse that handles HCPCS DME claims cleanly? Medical claims clearinghouse guide explains how clearinghouse routing works for DME suppliers and what to look for in a compliant setup.

Seeing denial codes you do not recognize on HCPCS claims? Denial codes in medical billing breaks down the most common CARC and RARC codes and what each one requires for a successful appeal.

Billing the chair with detachable arms? E0165 covers coverage criteria and documentation for the detachable-arm commode chair.

Working with a seat-lift commode? E0170 explains the electric seat-lift commode chair and how it is billed.

Want to understand the full revenue cycle behind DME billing? Revenue cycle management guide covers the end-to-end process from order through remittance posting.

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