What does a TENS referral need to show?
Under Medicare’s TENS policy, the record needs to show a treating practitioner’s order, a qualifying pain type and duration, prior treatments, and a monitored trial. This post lists those items in one table. It describes documentation only, taken from the policy text as of the LCD revision effective January 1, 2024. It is not legal or billing advice. Check the current policy and your Medicare contractor.
A TENS unit sends mild electrical pulses through pads on the skin to relieve pain. The rules differ for plans other than Original Medicare, so check with the plan.
What is on the one-page checklist?
| # | Item to document | What the policy says | Source |
|---|---|---|---|
| 1 | Treating practitioner | The ordering practitioner “must be the treating practitioner for the disease or condition justifying the need for the TENS unit.” | LCD L33802 |
| 2 | Pain type | Covered for chronic, intractable pain or acute post-operative pain when criteria are met. Acute post-operative: 30 days from surgery, rental only. | LCD L33802 |
| 3 | Pain duration | For chronic pain, “The pain must have been present for at least three months.” | LCD L33802 |
| 4 | Prior treatment | “Other appropriate treatment modalities must have been tried and failed.” | LCD L33802 |
| 5 | Cause of pain | The presumed cause “must be a type that is accepted as responding to TENS therapy.” | LCD L33802 |
| 6 | Trial plan | Minimum one month (30 days), not over two months, paid as a rental, monitored by the treating practitioner. | LCD L33802; NCD 160.7.1 |
| 7 | Purchase determination | For a purchase, the treating practitioner makes the determination the LCD describes about continuous use of the unit over a long period of time. | LCD L33802 |
| 8 | Number of leads | If ordered for 4 leads, the record must document why 2 leads are insufficient. | LCD L33802 |
| 9 | Standard Written Order | Must reach the supplier before a claim is submitted. | LCD L33802 |
| 10 | Written order prior to delivery | Where required, the signed order must be received before delivery. | LCD L33802; Article A52520 |
| 11 | Face-to-face encounter | Required with a WOPD for “specified HCPCS codes” under Final Rule 1713. | Article A52520 |
Row 7 is listed because the LCD makes this practitioner determination a condition for coverage of a purchase.
Which pain types are not covered?
Document the diagnosis clearly, because some are denied. The LCD says: “TENS therapy for Chronic Low Back Pain (CLBP) will be denied as not reasonable and necessary.” It lists headache, visceral abdominal pain, pelvic pain and temporomandibular joint (TMJ) pain as examples of conditions for which TENS “is not considered to be reasonable and necessary.” It also says TENS “will be denied as not reasonable and necessary for acute pain (less than three months duration) other than for post-operative pain.”
For the history of the low back pain rule, read why Medicare does not cover TENS for chronic low back pain. A local coverage determination is a regional Medicare policy that sets when an item is covered. Medical necessity is the term payers use for whether an item is reasonable and needed.
How does the order timing work?
A written order prior to delivery is a signed order the supplier must hold before delivering certain items. Article A52520 says: “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.” A face-to-face encounter is a visit in which a practitioner evaluates the patient before ordering certain equipment.
Ask your supplier or the DME MAC which TENS items are on the “specified HCPCS codes” list. Our post on what written order prior to delivery means goes through the wording.
What documents are no longer needed?
Article A52520 says “Providers and suppliers no longer need to submit Certificate of Medical Necessity (CMN) for services rendered on or after January 1, 2023.” It adds that claims received with those forms attached will be rejected and returned. It also says “A CMN is not needed for a TENS rental.”
What about the trial and supplies?
During a rental, the article says supplies “are included in the rental allowance.” After a purchase, the LCD sets usual maximums for supply code A4595, and suppliers verify unusual use with the treating practitioner. The trial rule is above.
What safety screening can the record note?
This part is our suggestion, not a CMS requirement. The NHS says not to use TENS if you have epilepsy or a pacemaker, or are pregnant unless your doctor or midwife says so. University of Iowa Health Care lists a cardiac pacemaker or defibrillator, a spinal cord stimulator and any implanted metallic or electronic device. A record note that the screening questions were asked is one way to show the check was made. Our TENS unit safety guide lists them.
Where can clinics read more?
Our guide on TENS referral documentation covers the paperwork in detail. The pillar guide on how to refer a patient for a TENS unit covers the process from first visit to follow-up.
Next step
Analgesic Healthcare offers a preauthorization form for TENS units for doctors and physical therapists. The company also has medical sales representatives for practices. See the providers page.
Questions people ask
Who must order a TENS unit for a Medicare patient?
The LCD 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 TENS unit.
What must the medical record show?
The LCD says it is expected that the beneficiary's medical records will reflect the need for the care provided. For a 4-lead order, it says the medical record must document why 2 leads are insufficient to meet the beneficiary's needs.
Does the order have to come before delivery?
A Standard Written Order must reach the supplier before a claim is submitted. For items that require a written order prior to delivery, the supplier must hold the signed order before delivering the item, or the claim is denied as not reasonable and necessary.
Terms on this page
Sources
- CMS Medicare Coverage Database: LCD Transcutaneous Electrical Nerve Stimulators (TENS) (L33802)
- CMS Medicare Coverage Database: Article Transcutaneous Electrical Nerve Stimulators (TENS) - Policy Article (A52520)
- CMS Medicare Coverage Database: NCD Assessing Patient's Suitability for Electrical Nerve Stimulation Therapy (160.7.1)
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.


