What documentation does Medicare ask for with a TENS referral?
Medicare asks for a signed order, a record that matches the coverage criteria, and notes from a monitored trial. This guide lists each item, quoted from the CMS documents, so your office can check its own chart. It describes documentation only. It does not promise coverage for any claim.
The references are the Medicare TENS policy, LCD L33802, in the revision effective January 1, 2024. Also used are its policy article, A52520 (revision effective January 1, 2023), the standard documentation article, A55426 (revision effective January 1, 2024), and NCD 160.7.1. The LCD is issued by the DME MAC. CGS Administrators is the contractor for jurisdiction C, which lists Florida. A local coverage determination (LCD) is a contractor’s decision on whether an item is reasonable and necessary.
| Item | What the CMS text requires | Source |
|---|---|---|
| Treating practitioner | The ordering practitioner must be the treating practitioner for the condition | LCD |
| Face-to-face encounter | A treating practitioner encounter within the 6 months before the order, for items on the Required List | A55426 |
| Standard written order | Signed by the treating practitioner, with listed elements | A55426 |
| Written order prior to delivery | A completed order before delivery, for items that require it | LCD, A52520, A55426 |
| Pain history in the record | Location, severity, duration, presumed cause, prior treatment and results | A52520 |
| Trial and reevaluation | One to two months, monitored; use and results documented | LCD, A52520 |
| 4-lead justification | Why 2 leads are insufficient | LCD |
| Supplies | Usual maximums and refill rules | LCD, A52520 |
Who is the treating practitioner, and why does it matter?
The ordering practitioner must be the treating practitioner. The LCD says: “The practitioner ordering the Transcutaneous Electrical Nerve Stimulators (TENS) unit and related supplies must be the treating practitioner for the disease or condition justifying the need for the TENS unit.”
A55426 adds that all claims “require a written order/prescription from the treating practitioner as a condition for payment.” It also says the standard written order “must be signed by the treating practitioner.” Someone else may complete certain elements: “For DMEPOS items other than PMDs, someone other than the treating practitioner may complete certain required elements of the SWO; however, the SWO must be signed by the treating practitioner.”
If you are not the treating practitioner for the pain condition, route the order to the practitioner who is.
What is the face-to-face encounter requirement?
For items on the CMS Required List, the treating practitioner must have a face-to-face encounter with the patient within the 6 months before prescribing. A55426 says: “As a condition for payment, 42 CFR 410.38 and Final Rule 1713 (84 Fed. Reg Vol 217) require that a treating practitioner have a face-to-face encounter with a beneficiary within the six (6) months prior to prescribing items that appear on the Required List.”
The policy article A52520 ties the TENS policy to that rule: it says the rule “requires a face-to-face encounter and a Written Order Prior to Delivery (WOPD) for specified HCPCS codes.” Check the current CMS Required List for the TENS codes you order. The list is updated from time to time, so check which codes are on it.
What must the encounter note contain?
A55426 says the encounter “must support payment for the item(s) ordered/prescribed, and be documented in the pertinent portion of the medical record (for example, history, physical examination, diagnostic tests, summary of findings, progress notes, treatment plans or other sources of information that may be appropriate).” It adds: “The supporting documentation must include subjective and objective beneficiary specific information used for diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.”
Telehealth exams can count. A55426 says the requirement “includes examinations conducted via” telehealth, and that these “must meet the requirements of 42 CFR §§ 410.78 and 414.65 for purposes of DMEPOS coverage.” For the glossary entry, see face-to-face encounter.
Can another practitioner do the encounter?
A55426 says: “For items other than PMDs that appear on the Required List, the treating practitioner that conducted the face-to-face encounter does not need to be the prescriber for the DMEPOS item; however, the prescriber must: Verify that a qualifying face-to-face encounter occurred within the 6-months prior to the date of their prescription; and, Have documentation of the qualifying face-to-face encounter that was conducted.”
What goes in the written order, and when must it be received?
The order must contain set elements and reach the supplier before delivery. A55426 says: “A SWO must contain all of the following elements:” and lists:
- Beneficiary’s name or Medicare Beneficiary Identifier (MBI)
- Order date
- General description of the item
- Quantity to be dispensed, if applicable
- Treating practitioner name or NPI
- Treating practitioner’s signature
A55426 also says “Signature and date stamps are not allowed.” For supplies, “the DMEPOS order/prescription may include all concurrently ordered supplies that are separately billed (List each separately).”
What does “written order prior to delivery” mean?
It means a completed order that reaches the supplier before delivery. A55426 defines it: “A WOPD is a completed SWO that is communicated to the DMEPOS supplier before delivery of the item(s).” It also says “The date of the WOPD shall be on or before the date of delivery” and “A WOPD must be completed within six (6) months after the required face-to-face encounter.”
The TENS policy article states the effect of a late order. A52520 says: “If a supplier delivers an item prior to receipt of a WOPD, it will be denied as not reasonable and necessary. If the WOPD is not obtained prior to delivery, payment will not be made for that item even if a WOPD is subsequently obtained by the supplier.” The LCD also covers separately billed supplies. The supplier must have received a WOPD “which lists the base item and which may list all the associated options, accessories, and/or supplies that are separately billed prior to the delivery of the items.”
For a plain-language view, read what a written order prior to delivery means for a TENS unit. The glossary entry is written order prior to delivery.
What must the medical record show about the pain?
The record must show that the coverage criteria are met. A52520 says: “For all claims for TENS and related supplies there must be information in the medical record demonstrating that the coverage criteria are met.”
For chronic pain, “there must be information in the medical record describing:”
- The location of the pain
- The severity of the pain
- The duration of time the beneficiary has had the pain
- The presumed etiology of the pain
- Prior treatment and results of that treatment
For acute post-operative pain, the article asks for the date of surgery, the nature of the surgery, and the location and severity of the pain.
Which conditions will not meet the criteria?
Record the pain type accurately, because some types are not covered. The LCD says TENS for chronic, intractable pain other than chronic low back pain requires that “The presumed etiology of the pain must be a type that is accepted as responding to TENS therapy.” It lists examples not reasonable and necessary: headache, visceral abdominal pain, pelvic pain and temporomandibular joint (TMJ) pain. It adds: “TENS therapy for Chronic Low Back Pain (CLBP) will be denied as not reasonable and necessary.” And “A TENS unit will be denied as not reasonable and necessary for acute pain (less than three months duration) other than for post-operative pain.”
The LCD also requires that “The pain must have been present for at least three months” and that “Other appropriate treatment modalities must have been tried and failed.” Your notes on prior treatment should name what was tried. See medical necessity.
What must a TENS trial document?
For chronic pain, the LCD requires a monitored trial. It says: “the TENS unit must be used by the beneficiary on a trial basis for a minimum of one month (30 days), but not to exceed two months. The trial period will be paid as a rental. The trial period must be monitored by the treating practitioner to determine the effectiveness of the TENS unit in modulating the pain.”
The policy article lists what the end-of-trial reevaluation must indicate: “How often the beneficiary used the TENS unit”, “The typical duration of use each time” and “The results (effectiveness of therapy).” For a purchase, the LCD says: “the treating practitioner must determine that the beneficiary is likely to derive significant therapeutic benefit from continuous use of the unit over a long period of time.”
NCD 160.7.1 adds the other side: “if it produces no relief or greater discomfort than the original pain electrical nerve stimulation therapy is ruled out.” Document that outcome too. For patient-facing text on the trial, see what a 30-day TENS trial looks like and the TENS trial period guide.
How do I justify a 4-lead order?
Write down why 2 leads are not enough. The LCD says: “A 4-lead TENS unit may be used with either 2 leads or 4 leads, depending on the characteristics of the beneficiary’s pain. If it is ordered for use with 4 leads, the medical record must document why 2 leads are insufficient to meet the beneficiary’s needs.” The number of leads also sets the usual supply maximum, described next.
What documentation applies to supplies?
Supplies need an order and must follow the usual maximums. The LCD says: “Separate allowance will be made for replacement supplies when they are reasonable and necessary and are used with a covered TENS.” Its usual maximums are one unit of A4595 per month for 2 leads and two units per month for 4 leads, and “Replacement of lead wires (A4557) more often than every 12 months would rarely be reasonable and necessary.”
The LCD also says: “Suppliers must verify with the treating practitioners that any changed or atypical utilization is warranted.” If your office hears from a supplier about a change in use, a reply that is documented in the chart helps. For the patient side, see our electrode pads and supplies guide.
A52520 says CMNs are no longer submitted: “Providers and suppliers no longer need to submit Certificate of Medical Necessity (CMN) for services rendered on or after January 1, 2023.”
How does this fit with AHC’s preauthorization form?
AHC offers a preauthorization form for TENS units for doctors and physical therapists. It is the only AHC process this guide describes. Use the preauthorization form page for it. For the wider topic, see the guide for referring a patient for a TENS unit and our one-page referral checklist. The providers page has more.
Next step
Check your chart against the table above, then use the preauthorization form or visit providers.
Questions people ask
Who must order a TENS unit for Medicare?
The treating practitioner. LCD L33802 says the practitioner ordering the TENS unit and related supplies must be the treating practitioner for the disease or condition justifying the need for the unit. The order must be signed by that practitioner and contain the standard written order elements.
Is a written order required before delivery of a TENS unit?
Where the item requires a written order prior to delivery, yes. The policy article says that if a supplier delivers an item before receiving a written order prior to delivery, it is denied as not reasonable and necessary. Check the current CMS Required List for the codes you order.
What must the trial notes include?
For chronic pain, the policy article says the record must describe the reevaluation at the end of the trial: how often the beneficiary used the unit, the typical duration of use each time, and the results (effectiveness of therapy). The LCD requires a trial of at least one month and no more than two.
What must the record say for a 4-lead TENS order?
The LCD says a 4-lead unit may be used with 2 or 4 leads, depending on the characteristics of the beneficiary's pain. If it is ordered for use with 4 leads, the medical record must document why 2 leads are insufficient to meet the beneficiary's needs.
Does Medicare cover TENS for chronic low back pain or headache?
No. LCD L33802 says TENS therapy for chronic low back pain will be denied as not reasonable and necessary. It also lists headache among examples of conditions for which TENS therapy is not considered reasonable and necessary. Document the pain type accurately.
Does AHC have a form for TENS referrals?
AHC offers a preauthorization form for TENS units for doctors and physical therapists. You can find it on the preauthorization form page of this site. This guide covers Medicare documentation only, and it does not describe any other AHC step or service.
Terms on this page
Sources
- CMS Medicare Coverage Database: LCD L33802, Transcutaneous Electrical Nerve Stimulators (TENS)
- CMS Medicare Coverage Database: Article A52520, TENS Policy Article
- CMS Medicare Coverage Database: Article A55426, Standard Documentation Requirements for All Claims Submitted to DME MACs
- CMS Medicare Coverage Database: NCD 160.7.1, Assessing Patient's Suitability for Electrical Nerve Stimulation Therapy
Checked against the sources above on October 26, 2026. Coverage rules change, so check the linked page or your plan before you act.
This page gives general information, not medical advice. Talk with your doctor or physical therapist about your own care, and follow your clinician's and your device's instructions. In an emergency, call 911.
