HCPCS Code

HCPCS code E0175 – Commode chair foot rest

Code Definition

E0175 is the HCPCS Level II code for a foot rest, for use with commode chair, each. It describes a foot support used with a commode chair, billed as one unit per foot rest.

Medicare treats E0175 as non-covered, because the DME MACs consider a commode footrest not medical in nature. Suppliers bill the commode chair on its own line, then add E0175 with NU or UE plus GY. The patient or a secondary payer then pays for the foot rest.

Level: Level II
Category: E — Durable medical equipment
Code range: E0163-E0175 Commode chairs and supplies
Billable: No
Code also known as: commode footrest, commode chair footrest

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HCPCS code E0175 describes a foot rest for use with a commode chair, billed as one unit per foot rest.

Medicare does not cover E0175, because the DME MACs consider a commode footrest not medical in nature.

The commode chair itself bills on its own line under E0163, E0165, E0168, E0170 or E0171.

On a Medicare claim, E0175 takes NU or UE plus the GY modifier, never KX or rental modifiers.

Pabau, the practice management platform we build, keeps the order, delivery proof, claim and patient invoice in one record.

HCPCS code E0175: Official descriptor and key attributes

HCPCS code E0175 describes a foot rest, for use with commode chair, each. It is a HCPCS Level II code in the E-series, which CMS maintains for durable medical equipment, prosthetics, orthotics and supplies (DMEPOS). The code closes the E0163 to E0175 range of commode chairs and supplies.

Field	Detail
HCPCS code	E0175
Official descriptor	Foot rest, for use with commode chair, each
Code level	HCPCS Level II, E-series (DME)
Code range	E0163 to E0175, commode chairs and supplies
Effective date	January 1, 1996
Unit of service	Each, so one unit per foot rest
Payment category	Inexpensive or routinely purchased item, billed as a purchase
Medicare coverage	Non-covered, as the item is not medical in nature (Policy Article A52461)
Billed by	A DMEPOS-enrolled supplier, to the DME MAC
Code status	Active

Because E0175 is a purchased item, it never enters the 13-month capped rental cycle. Rental modifiers such as RR, KH, KI and KJ have no place on its claim line.

What E0175 covers and what it doesn’t

E0175 covers one foot rest made for use with a commode chair. The chair, its pail and any built-in seat lift each carry their own code.

Billed under E0175

A foot rest that supports the patient’s feet while they sit on a commode chair
A replacement foot rest for a commode chair the patient already owns
Each additional foot rest, billed as a separate unit

Billed under other codes

The commode chair: E0163 for fixed arms, E0165 for detachable arms, or E0168 for an extra wide or heavy duty chair
A commode chair with an integrated seat lift: E0170 when the lift is electric, E0171 when it is not
A replacement pail or pan: E0167
Wheelchair footrests and leg rests: these are wheelchair accessories with their own codes, such as E0990 for an elevating leg rest
Patient lifts and slings: E0630 for a hydraulic or mechanical patient lift, and E0621 for a canvas or nylon sling

If the order describes a lift, a sling or a wheelchair part, E0175 is the wrong code. Match the code to the item on the delivery ticket before the claim goes out.

E0175 is one of two codes in the commode range that Medicare never pays, with E0172, the toilet seat lift. Of the two, only E0175 is a commode accessory. The table sets it beside the chair codes it is billed with.

Code	Descriptor	Medicare coverage	Billing note
E0163	Commode chair, mobile or stationary, with fixed arms	Covered when the general commode criteria are met	Add KX only when the record supports the criteria
E0165	Commode chair, mobile or stationary, with detachable arms	Covered when detachable arms are needed for transfers or extra width	Needs the general and the specific criteria
E0168	Commode chair, extra wide and/or heavy duty, stationary or mobile, with or without arms, any type, each	Covered for patients who weigh 300 pounds or more	Record the patient’s weight
E0170 / E0171	Commode chair with integrated seat lift mechanism, electric / non-electric, any type	Covered when the seat lift mechanism criteria are also met	The lift is part of the chair, not a separate line
E0172	Seat lift mechanism placed over or on top of toilet, any type	Non-covered	Not primarily medical in nature
E0175	Foot rest, for use with commode chair, each	Non-covered	Bill as a purchase with GY

The commode chair and the foot rest go on separate claim lines. A covered chair keeps its KX modifier, while the foot rest line carries GY. The diagram below follows each line from the claim to the party that pays it.

Diagram of one commode order split into two claim lines: the commode chair (E0163, E0165, E0168, E0170 or E0171) with KX is covered under LCD L33736 and paid by Medicare; the E0175 foot rest with NU or UE plus GY is non-covered under Policy Article A52461 and billed to a secondary payer or the patient — *Only the chair line can be paid by Medicare, so the foot rest charge always ends with the secondary payer or the patient. Rules from CMS LCD L33736 and Policy Article A52461.*

Medicare coverage for HCPCS code E0175

Medicare does not cover HCPCS code E0175. The Commodes Policy Article (A52461) states that a footrest is non-covered because it is not medical in nature.

The rule is the same in every DME MAC jurisdiction. A joint letter from the four DME MAC medical directors lists the commode footrest as non-covered, alongside bidets and non-integrated toilet seat lifts.

When the commode chair itself is covered

Coverage for the chair runs under the Commodes LCD (L33736). A commode chair is covered when the patient is physically unable to use regular toilet facilities, because the patient is:

Confined to a single room
Confined to one level of the home, with no toilet on that level
Confined to the home, with no toilet facilities in the home

A covered chair does not bring the foot rest into coverage. Even when the E0163 or E0165 line pays, the E0175 line is still denied.

Medicaid and commercial plans

Other payers often reach the same answer, and some treat foot rests as convenience items. Confirm the patient’s insurance eligibility before delivery. If no payer will pay, quote the price to the patient up front.

Documentation to keep for E0175 claims

A non-covered item needs less clinical evidence, but the file still has to stand up to review. Keep these records for each E0175 delivery:

Standard written order: the prescriber’s order naming the commode chair and the foot rest, with the patient’s name and the order date
Commode chair records: notes showing the patient meets the commode criteria, which support the chair’s own claim line
Proof of delivery: signed and dated by the patient or caregiver, listing each foot rest delivered
Financial agreement: a signed note that Medicare won’t pay for the foot rest, with the agreed price
Secondary payer response: the remittance showing the Medicare denial, if a secondary plan asks for it

Do you need an ABN for E0175?

No, an Advance Beneficiary Notice is not required for an item that falls outside the Medicare benefit. A voluntary notice is allowed, and many suppliers use one so the patient sees the price in writing.

Modifiers used with HCPCS code E0175

E0175 claims use a short list of modifiers. The table shows which ones belong on the foot rest line and which belong elsewhere.

Modifier	Meaning	Use on E0175?
NU	New equipment	Yes, when the foot rest is new and purchased
UE	Used durable medical equipment	Yes, when the foot rest is used and purchased
GY	Item or service statutorily excluded, or does not meet the definition of any Medicare benefit	Yes, on every Medicare claim line for E0175
KX	Requirements in the medical policy have been met	No, it belongs on the commode chair line only
GA / GZ	Expected medical necessity denial, with or without an ABN	No, because E0175 is denied as a benefit exclusion
RR, KH, KI, KJ	Rental and capped rental month modifiers	No, because E0175 is purchased, never rented

Keep GY off the commode chair line unless the chair is used as a raised toilet seat. A52461 treats that use as non-covered too.

How to bill HCPCS code E0175: Step-by-step

An E0175 claim is short, but each step decides who pays. Sound medical billing here means planning the denial before delivery.

Confirm the code. Check that the order describes a foot rest for a commode chair, not a wheelchair leg rest or a lift.
Bill the chair on its own line. Code the commode chair as E0163, E0165, E0168, E0170 or E0171, with KX when the record supports it.
Tell the patient before delivery. Explain that Medicare won’t pay for the foot rest, agree on the price, and get the agreement signed.
Add the E0175 line. Enter one unit per foot rest, with NU or UE plus GY.
Submit to the DME MAC. Send the claim to the DME MAC for the patient’s state, with place of service 12 for the patient’s home.
Post the denial and bill the balance. Once the remittance shows the denial, bill the secondary payer or the patient.

Pabau remittance matching screen showing payment status by payer — *Pabau’s remittance matching marks each line as paid, unpaid or reissued, so a denied E0175 line is easy to find and bill to the patient.*

Pro Tip

Bill the foot rest on the same claim as the commode chair, not weeks later. One remittance then shows the chair payment and the E0175 denial together, ready for secondary billing.

Common denial reasons for E0175 and how to prevent them

An E0175 line on a Medicare claim is always denied. The aim is a clean denial that lets you bill the right party, plus a commode chair line that still pays.

Problem	Why it causes trouble	Fix
E0175 sent without GY	The line is denied as a non-covered charge (CARC 96) without the exclusion flag	Add GY to every Medicare E0175 line
KX added to E0175	KX attests that coverage criteria are met, and a footrest has none	Remove KX from E0175 and keep it on the chair line
E0175 used for a wheelchair foot rest or leg rest	The item is not a commode accessory	Use the wheelchair accessory code, such as E0990 for an elevating leg rest
E0175 used for a patient lift or sling	The code describes a different item entirely	Use E0630 for the lift and E0621 for a canvas or nylon sling
Rental modifiers on E0175	The foot rest is a purchase item	Bill it once, with NU or UE
Units don’t match the delivery	Proof of delivery lists one foot rest, but the claim bills two	Bill one unit per foot rest delivered
Commode chair line denied (CO-50)	The record doesn’t show the room, floor or home confinement criteria	Document the criteria before delivery, and add KX only when they are met

Don’t appeal an E0175 denial on medical necessity grounds. The policy article treats the foot rest as non-medical, so a redetermination will reach the same answer. Put that effort into denial management on the commode chair line, where documentation can change the outcome.

How Pabau keeps commode chair claims and E0175 charges in one place

A commode setup is often billed in two places. The chair goes to the DME MAC, while the foot rest becomes a patient charge tracked in a separate system.

In Pabau, the order, the proof of delivery, the claim and the patient invoice sit in the same record. Its claims management software tracks claim status, so the E0175 denial shows up next to the chair payment.

The signed financial agreement lives on the patient record as a digital form. When a patient asks about the foot rest charge, your team can show the signed agreement in seconds.

Keep DME claims and patient charges together

Pabau links orders, delivery records, claims and patient invoices in one record, so non-covered items like E0175 are billed to the right party. See how it works for your practice.

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Conclusion

Treat E0175 as a patient charge that needs a Medicare denial first. Bill the commode chair for coverage, and bill the foot rest for a clean GY denial.

The commode chair line is where documentation earns its keep. A record that shows the confinement criteria, with KX on the right line, protects that payment. The foot rest only needs the right modifiers and a signed price.

Book a demo to see how Pabau keeps DME orders, claims and patient invoices in one record.

Billing the chair that goes with the foot rest? HCPCS code E0163 explains the standard commode chair with fixed arms and its coverage criteria.

Does the patient need removable arms for transfers? HCPCS code E0165 covers the commode chair with detachable arms.

Supplying a patient who weighs 300 pounds or more? HCPCS code E0168 walks through the extra wide and heavy duty commode chair code.

Seeing the same denials on DME claims? Denial management in healthcare shows how to track, appeal and prevent recurring denials.

Building a compliance routine for DME billing? Medical billing compliance outlines the documentation and audit habits that reduce audit exposure.

Frequently asked questions

What is HCPCS code E0175?

HCPCS code E0175 is the Level II code for a foot rest, for use with commode chair, each. DMEPOS suppliers bill one unit per foot rest. It sits in the E0163 to E0175 range of commode chairs and supplies.

Does Medicare cover HCPCS code E0175?

No, Medicare does not cover E0175. Policy Article A52461 treats a commode footrest as non-covered because it is not medical in nature. The patient or a secondary payer pays for it.

What modifiers apply to HCPCS code E0175?

Use NU for a new foot rest or UE for a used one, plus GY on Medicare claims. Don’t add KX, GA, GZ or rental modifiers to the E0175 line.

Is E0175 rented or purchased?

E0175 is purchased. CMS places it in the inexpensive or routinely purchased category, so it never follows the 13-month capped rental cycle.

What is the difference between E0175 and E0163?

E0163 is the commode chair with fixed arms, which Medicare covers when the patient meets the commode criteria. E0175 is only the foot rest used with the chair. It is billed on its own line and is not covered.

Do I need an ABN for E0175?

No, an ABN is not required for an item that falls outside the Medicare benefit. Many suppliers still use a voluntary notice so the patient agrees to the price in writing.

Can E0175 be used for a wheelchair footrest?

No, E0175 applies only to a foot rest used with a commode chair. Wheelchair footrests and leg rests have their own accessory codes, such as E0990 for an elevating leg rest.

HCPCS code E0175 – Commode chair foot rest

Key takeaways

HCPCS code E0175: Official descriptor and key attributes