HCPCS E0601: CPAP device billing and the 90-day rule
E0601 is the HCPCS code for a CPAP device. Medicare pays it as a 13-month capped rental and, from month four, wants a documented re-evaluation and proof of use.
Written by Salman Saeed, CEO and Co-Founder · Reviewed by a Certified Medical Coder · Last reviewed October 2026In short: E0601 is a capped rental under 42 CFR 414.229, so title passes to the patient after 13 paid months. KX belongs on months one to three only if the initial criteria in LCD L33718 are met, and on month four and later only if the day 31 to 91 re-evaluation and adherence data are also on file.
What does HCPCS E0601 report?
E0601 is the HCPCS Level II code for a continuous positive airway pressure device. The long descriptor in the October 2026 CMS HCPCS file is "Continuous positive airway pressure (cpap) device".
Auto-titrating single-level devices also use E0601, per policy article A52467. Bi-level devices are E0470 and E0471.
| Item | Value |
|---|---|
| Added to HCPCS | January 1, 1988; no termination date |
| Pricing indicator | 36, capped rental DME |
| Coverage code | D, special coverage instructions apply |
| MUE, DME supplier table, October 1, 2026 | 1 per date of service (indicator 3, clinical) |
What must be true before Medicare pays for E0601?
LCD L33718, in effect since January 1, 2024, covers E0601 for obstructive sleep apnea (OSA) when three things are documented. If any one is missing, the LCD says the claim is denied as not reasonable and necessary.
- An in-person clinical evaluation by the treating practitioner before the sleep test.
- A sleep test with an AHI or respiratory disturbance index of 15 or more events an hour and at least 30 events, or 5 to 14 events an hour with at least 10 events plus documented daytime sleepiness, impaired cognition, a mood disorder, insomnia, hypertension, ischemic heart disease or a history of stroke.
- Supplier instruction to the patient or caregiver on using the equipment.
A DME supplier may not perform any part of a home sleep test. The facility test is covered under CPT 95810.
How does the 13-month capped rental work?
Under 42 CFR 414.229(f), Medicare pays a monthly rental amount for the period of medical need but for no longer than 13 months of continuous use. The supplier must transfer title to the patient on the first day after the 13th paid month.
The supplier that bills month one must keep supplying through month 13 unless the patient moves away, chooses another supplier or CMS grants an exception.
Under 42 CFR 414.230 a break of up to 60 consecutive days plus the rest of the rental month does not restart the count. A longer one starts a new rental period only with a new prescription, new documentation and a statement of why use stopped.
What is the 90-day adherence rule?
Continued coverage past the first three months requires an in-person re-evaluation by the treating practitioner no sooner than the 31st day and no later than the 91st day after therapy starts. LCD L33718 sets that window.
The note must show improved symptoms and objective adherence data the practitioner reviewed. Adherence means use of at least 4 hours a night on 70 percent of nights during a consecutive 30-day period in the first three months.
Article A52467 wants a download or visual inspection of usage data in a written report. A supplier-made form does not replace the chart.
| Situation | What the LCD says |
|---|---|
| Visit on day 31 to 91, benefit and adherence shown | Coverage continues |
| Visit after day 91, benefit and adherence shown | Coverage resumes on the date of that visit |
| Trial failed | New in-person evaluation and a repeat facility-based (Type I) sleep test |
Does E0601 need a face-to-face encounter and a written order before delivery?
Not under the CMS Required Face-to-Face Encounter and Written Order Prior to Delivery List, which shows an effective date of October 28, 2026 and does not name E0601. It does name E1390.
A standard written order is still required. Article A55426 calls for a new order on all claims for purchases or initial rentals, communicated to the supplier before the claim goes out.
Lines billed before a signed, dated order is in hand carry the EY modifier.
How does E0601 sit on the claim?
A supplier reports E0601 in box 24D of the CMS-1500 with modifiers that tell the DME MAC whether the rules were met.
- RR for rental. Chapter 20 of the Claims Processing Manual also lists KI (second or third rental month) and KJ (capped rental months four to fifteen); follow your DME MAC on which it wants.
- KX on months one to three only when every initial criterion is met. From month four, only when the initial and continued criteria are both met.
- GA when criteria are not met and a valid ABN is on file, GZ when there is none. A line with no GA, GZ or KX is rejected as missing information.
- Accessories bill on their own lines at first issue and at replacement.
Without the month-four information, the supplier may send the claim without KX or hold it. A held claim can carry KX once the visit is confirmed, but after a late visit only for later dates of service.
Which fields carry a CPAP rental month?
A supplier bills E0601 on the CMS-1500 with the code in Item 24D and its modifiers beside it, up to four per Chapter 26. Item 24G holds the rental units and Item 24A the service dates. Item 24E points to the sleep diagnosis. Item 17 carries the ordering physician, and Chapter 26 says that for DME claims Item 32 holds the name and address of the location where the order was accepted.
Example: A patient starts CPAP rental in October. The line for October reads E0601 with the modifiers the rules require, pointer A (G47.33), 1 unit, $68.00, with the physician in Item 17. The month-four line carries the adherence data, as the page above explains, or the claim may deny under CO-16.
Why do E0601 claims deny?
| Code | What X12 says | What usually causes it on E0601 |
|---|---|---|
| CO-50 | Non-covered because the payer does not deem it medically necessary | KX sent without the day 31 to 91 visit or adherence data. RARC N115 means the decision rested on an LCD. |
| CO-16 with MA130 | Claim lacks information or has a billing error; MA130 says the claim is unprocessable | No KX, GA or GZ on the line. Correct and resubmit. |
| CO-4 | The procedure code is inconsistent with the modifier used | A modifier that does not fit the line or the month. |
If these denials keep coming back, our denial management team can work them.
Related codes
- LCD L33718: Positive Airway Pressure (PAP) Devices for the Treatment of Obstructive Sleep Apnea · CMS Medicare Coverage Database
- Policy Article A52467: Positive Airway Pressure (PAP) Devices · CMS Medicare Coverage Database
- Article A55426: Standard Documentation Requirements for All Claims Submitted to DME MACs · CMS Medicare Coverage Database
- Required Face-to-Face Encounter and Written Order Prior to Delivery List · CMS
- HCPCS quarterly update, October 2026 alpha-numeric file · CMS
- Medicare NCCI Medically Unlikely Edits, DME supplier services table, effective 10-01-2026 · CMS
- 42 CFR 414.229: Other durable medical equipment, capped rental items · eCFR
- 42 CFR 414.230: Determining a period of continuous use · eCFR
- Medicare Claims Processing Manual, Chapter 20: Durable Medical Equipment · CMS
- Claim Adjustment Reason Codes · X12
- Remittance Advice Remark Codes · X12
- Medicare Claims Processing Manual, Chapter 26: Completing and Processing Form CMS-1500 Data Set · CMS
- Physician Fee Schedule relative value files, RVU26D (October 2026) · CMS
We check every rule, code and deadline against the official source. See our editorial policy.
Common questions
Straight answers from the team that does the work.
Ask a billing lead directly. A 20-minute call, Monday to Friday, 9am to 5pm Eastern.
01How do I bill CPAP rentals?
Send E0601 each month with the RR rental modifier. Add KX only when the criteria are met: initial criteria for months one to three, initial plus continued criteria from month four. Stop after the 13th paid month, when title passes to the patient. Without KX, use GA or GZ.
02How do I bill CPAP initiation and management?
The supplier bills the device. The practitioner bills the visits, the in-person evaluation before the sleep test and the re-evaluation between day 31 and day 91, on the practitioner's own claim. The LCD sets what those notes must show, including the adherence data reviewed.
03What if the re-evaluation happens after day 91?
Coverage resumes on the date of that visit if it shows improved symptoms and adherence, per LCD L33718. Months before that date cannot carry KX, so the supplier should not bill them as covered, and a held fourth-month claim is cut back to later dates.
04What happens if the patient stops using the CPAP?
The LCD expects the supplier to find out and stop billing the device and its accessories. A restart after a break of more than 60 days plus the rest of the rental month needs a new prescription, new documentation and a statement explaining the gap.
CPAP claims held at month four?
We track the day 31 to 91 window and the adherence report so KX goes on only when the chart supports it.