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Key Takeaways: HCPCS A9270

  • Definition: A9270 is a miscellaneous code for “Non-covered item or service.” It is used to billing items excluded from coverage (e.g., convenience items, experimental devices).
  • Outcome: Assigning A9270 to a claim line will almost always result in an automatic denial.
  • Medicare Rule: A9270 is generally restricted to DME suppliers. Part A/B providers should not use it on standard claims unless instructed (e.g., with Condition Code 21).
  • Modifiers: Use modifiers like GY (statutorily excluded), GA (ABN on file), or GL (medically unnecessary upgrade) to indicate liability.

HCPCS A9270 is a Level II code officially defined as a “Non-covered item or service.” It falls under the category of miscellaneous DME (Durable Medical Equipment) supplies and serves as a catch-all for products that Medicare and other payers do not cover. When providers use this code, they are effectively signaling that the item is excluded from benefits, and no payment is expected.

This guide explains when to use A9270, how to apply CMS rules, and which modifiers are critical for correct billing.

What is HCPCS A9270?

HCPCS A9270 is a “catch-all” code used when a healthcare item is furnished but is excluded from coverage. Assigning this code to a claim line item signals that the charge is non-covered under the payer’s rules.

It is primarily used to generate a formal denial, which is often necessary to bill a secondary insurer or to document patient liability.

When and Why is A9270 Used?

Common scenarios for using A9270 include:

  • Statutorily Excluded Items: Items Medicare never covers by law (e.g., personal comfort items, hearing aids).
  • Experimental Items: New devices without a specific HCPCS code. For example, in 2025, items like the “Q-Collar” neck device and certain cushions were billed with A9270.
  • Deluxe/Convenience Features: Upgrades not medically necessary (e.g., custom paint on a wheelchair). Medicaid programs may require A9270 for these items.
  • Wrong Category Items: Items that do not meet the definition of DME (e.g., vehicle-mounted wheelchair tie-downs, which should not be billed as K0108).

Decision Flowchart: When to Use A9270

flowchart TD
    A[Item furnished to patient] --> B{Does a specific<br>HCPCS/CPT code exist?}
    B -->|Yes| C[Use specific code<br>with GY/GZ modifier]
    B -->|No| D{Is item covered<br>by any payer?}
    D -->|Yes| E[Use appropriate<br>NOC code]
    D -->|No| F{Are you a<br>DME supplier?}
    F -->|Yes| G[Bill A9270 to<br>DME MAC]
    F -->|No| H{Part A outpatient<br>with Condition Code 21?}
    H -->|Yes| I[Bill A9270 for<br>denial purposes]
    H -->|No| J[Do NOT use A9270]
    G --> K{ABN on file?}
    K -->|Yes, medical necessity| L[Add modifier GA]
    K -->|Statutorily excluded| M[Add modifier GY]
    K -->|Voluntary ABN + excluded| N[Add modifiers GY + GX]
    K -->|No ABN| O[Add modifier GZ<br>Provider liable]

CMS Guidance for DME Suppliers

Warning: Code A9270 is generally not accepted on claims billed to Medicare Part A or Part B MACs. It is designated specifically for DME suppliers billing the DME MAC.

According to the Medicare Claims Processing Manual, A9270 should be used by suppliers only when an item has no specific code, no appropriate NOC code, and is statutorily non-covered.

Note for Part A Providers: Some MACs allow outpatient facilities to bill A9270 with Condition Code 21 (billing for denial) to receive a rejection notice for secondary billing.

Required Modifiers (GY, GA, GL, GX)

When billing A9270, you must attach a modifier to explain why it is non-covered and who is liable.

Modifier Definition Liability
GY Item is statutorily excluded or not a Medicare benefit. Patient Liable
GA Waiver of liability (ABN) on file. Used when medical necessity is denied. Patient Liable
GZ Item expected to be denied, but no ABN on file. Provider Liable
GL Medically unnecessary upgrade provided (no charge, no ABN). Patient Liable (Upgrade)
GX Voluntary ABN issued for a statutorily excluded service (often used with GY). Patient Liable

Using the correct modifier ensures the denial is processed correctly and protects the provider’s ability to bill the patient if an ABN was obtained.

Payer-Specific Rules

  • Medicare (Traditional): Will deny A9270 automatically. Do not use on professional claims (use specific codes with GY/GZ modifiers instead).
  • Medicaid: Varies by state. Some require A9270 for non-covered convenience items; others simply disallow the charge.
  • Commercial Payers: Many recognize A9270 as a denial code, but some prefer generic supply codes (e.g., 99070) or proprietary “S” codes. Always check payer policy.

Common Billing Mistakes

  • Using A9270 when a specific code exists: Always use a specific HCPCS/CPT code with a GY/GZ modifier if one exists. A9270 is a last resort.
  • Billing on Part B claims: Doctors should avoid A9270 on professional claims; it will likely be rejected.
  • Missing the ABN: If you expect a medical necessity denial, get an ABN signed and use modifier GA. Without it, you cannot bill the patient.
  • Expecting Payment: A9270 is a zero-pay code with a payment indicator of “00”. Do not use it if you believe the item should be reimbursed.

Frequently Asked Questions (FAQ)

Q: Can a physician bill A9270 to Medicare?

A: Generally, no. Medicare Part B MACs do not accept A9270 on professional claims. Physicians should use the specific procedure/supply code with a GY or GZ modifier to indicate non-coverage.

Q: Does A9270 ever get paid?

A: No. A9270 is designed to be denied. It creates a record that the item was provided but is non-covered, which helps in billing secondary insurance or the patient.

Q: What modifier should I use if I have an ABN on file?

A: Use modifier GA. This tells Medicare you have a signed Advance Beneficiary Notice, allowing you to bill the patient after the denial.

Official Description

Non-covered item or service
Short Descr Non-covered item or service
Coverage Non-covered by Medicare
Pricing Indicator(s) 00 – Service not separately priced by part B (e.G., services not covered, bundled, used by part a only, etc.)
MPI 9 – Not applicable, as HCPCS not priced separately by part B (pricing indicator is 00) or value is not established (pricing indicator is '99')
MCM 2303
Processing Note FOR MEDICARE CLAIMS - CODE
BETOS Z2 – Undefined codes
TOS Code(s) 9 – Other medical items or services
Added Date 1/1/1986
Status Code Non-Covered Service
Global Days XXX - Global Concept Does Not Apply
PC/TC Indicator (26, TC) 9 - Not Applicable
Multiple Procedures (51) 9 - Concept does not apply.
Bilateral Surgery (50) 9 - Concept does not apply.
Physician Supervisions 09 - Concept does not apply.
Assistant Surgeon (80, 82) 9 - Concept does not apply.
Co-Surgeons (62) 9 - Concept does not apply.
Team Surgery (66) 9 - Concept does not apply.
Diagnostic Imaging Family 99 - Concept Does Not Apply
APC Status Indicator Non-Covered Service, not paid under OPPS
MUE 0
MUE 0
IOM 100-02, 16, 20
OTS Orthotic No
CCS Clinical Classification 243 - DME and supplies
GY Item or service statutorily excluded, does not meet the definition of any medicare benefit or, for non-medicare insurers, is not a contract benefit
GA Waiver of liability statement issued as required by payer policy, individual case
SD Services provided by registered nurse with specialized, highly technical home infusion training
GX Notice of liability issued, voluntary under payer policy
BO Orally administered nutrition, not by feeding tube
GZ Item or service expected to be denied as not reasonable and necessary
KX Requirements specified in the medical policy have been met
A1 Dressing for one wound
LT Left side (used to identify procedures performed on the left side of the body)
SH Second concurrently administered infusion therapy
RT Right side (used to identify procedures performed on the right side of the body)
SS Home infusion services provided in the infusion suite of the iv therapy provider
GW Service not related to the hospice patient's terminal condition
EY No physician or other licensed health care provider order for this item or service
76 Repeat procedure or service by same physician or other qualified health care professional: it may be necessary to indicate that a procedure or service was repeated by the same physician or other qualified health care professional subsequent to the original procedure or service. this circumstance may be reported by adding modifier 76 to the repeated procedure or service. note: this modifier should not be appended to an e/m service.
A2 Dressing for two wounds
SJ Third or more concurrently administered infusion therapy
26 Professional component: certain procedures are a combination of a physician or other qualified health care professional component and a technical component. when the physician or other qualified health care professional component is reported separately, the service may be identified by adding modifier 26 to the usual procedure number.
JW Drug amount discarded/not administered to any patient
U9 Medicaid level of care 9, as defined by each state
32 Mandated services: services related to mandated consultation and/or related services (eg, third party payer, governmental, legislative or regulatory requirement) may be identified by adding modifier 32 to the basic procedure.
77 Repeat procedure by another physician or other qualified health care professional: it may be necessary to indicate that a basic procedure or service was repeated by another physician or other qualified health care professional subsequent to the original procedure or service. this circumstance may be reported by adding modifier 77 to the repeated procedure or service. note: this modifier should not be appended to an e/m service.
CC Procedure code change (use 'cc' when the procedure code submitted was changed either for administrative reasons or because an incorrect code was filed)
CR Catastrophe/disaster related
SC Medically necessary service or supply
U1 Medicaid level of care 1, as defined by each state
22 Increased procedural services: when the work required to provide a service is substantially greater than typically required, it may be identified by adding modifier 22 to the usual procedure code. documentation must support the substantial additional work and the reason for the additional work (ie, increased intensity, time, technical difficulty of procedure, severity of patient's condition, physical and mental effort required). note: this modifier should not be appended to an e/m service.
50 Bilateral procedure: unless otherwise identified in the listings, bilateral procedures that are performed at the same session, should be identified by adding modifier 50 to the appropriate 5 digit code. note: this modifier should not be appended to designated "add-on" codes (see appendix d).
51 Multiple procedures: when multiple procedures, other than e/m services, physical medicine and rehabilitation services or provision of supplies (eg, vaccines), are performed at the same session by the same individual, the primary procedure or service may be reported as listed. the additional procedure(s) or service(s) may be identified by appending modifier 51 to the additional procedure or service code(s). note: this modifier should not be appended to designated "add-on" codes (see appendix d).
59 Distinct procedural service: under certain circumstances, it may be necessary to indicate that a procedure or service was distinct or independent from other non-e/m services performed on the same day. modifier 59 is used to identify procedures/services, other than e/m services, that are not normally reported together, but are appropriate under the circumstances. documentation must support a different session, different procedure or surgery, different site or organ system, separate incision/excision, separate lesion, or separate injury (or area of injury in extensive injuries) not ordinarily encountered or performed on the same day by the same individual. however, when another already established modifier is appropriate it should be used rather than modifier 59. only if no more descriptive modifier is available, and the use of modifier 59 best explains the circumstances, should modifier 59 be used. note: modifier 59 should not be appended to an e/m service. to report a separate and distinct e/m service with a non-e/m service performed on the same date, see modifier 25.
79 Unrelated procedure or service by the same physician or other qualified health care professional during the postoperative period: the individual may need to indicate that the performance of a procedure or service during the postoperative period was unrelated to the original procedure. this circumstance may be reported by using modifier 79. (for repeat procedures on the same day, see modifier 76.)
95 Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system: synchronous telemedicine service is defined as a real-time interaction between a physician or other qualified health care professional and a patient who is located at a distant site from the physician or other qualified health care professional. the totality of the communication of information exchanged between the physician or other qualified health care professional and the patient during the course of the synchronous telemedicine service must be of an amount and nature that would be sufficient to meet the key components and/or requirements of the same service when rendered via a face-to-face interaction. modifier 95 may only be appended to the services listed in appendix p. appendix p is the list of cpt codes for services that are typically performed face-to-face, but may be rendered via a real-time (synchronous) interactive audio and video telecommunications system.
99 Multiple modifiers: under certain circumstances 2 or more modifiers may be necessary to completely delineate a service. in such situations modifier 99 should be added to the basic procedure, and other applicable modifiers may be listed as part of the description of the service.
A3 Dressing for three wounds
CG Policy criteria applied
F1 Left hand, second digit
F2 Left hand, third digit
F6 Right hand, second digit
F8 Right hand, fourth digit
GG Performance and payment of a screening mammogram and diagnostic mammogram on the same patient, same day
GK Reasonable and necessary item/service associated with a ga or gz modifier
GL Medically unnecessary upgrade provided instead of non-upgraded item, no charge, no advance beneficiary notice (abn)
GP Services delivered under an outpatient physical therapy plan of care
HH Integrated mental health/substance abuse program
HN Bachelors degree level
JB Administered subcutaneously
KD Drug or biological infused through dme
KT Beneficiary resides in a competitive bidding area and travels outside that competitive bidding area and receives a competitive bid item
KV Dmepos item subject to dmepos competitive bidding program that is furnished as part of a professional service
KY Dmepos item subject to dmepos competitive bidding program number 5
NU New equipment
RA Replacement of a dme, orthotic or prosthetic item
SQ Item ordered by home health
ST Related to trauma or injury
SV Pharmaceuticals delivered to patient's home but not utilized
T5 Right foot, great toe
T6 Right foot, second digit
TB Drug or biological acquired with 340b drug pricing program discount, reported for informational purposes
TF Intermediate level of care
TS Follow-up service
TU Special payment rate, overtime
U6 Medicaid level of care 6, as defined by each state
U8 Medicaid level of care 8, as defined by each state
XS Separate structure, a service that is distinct because it was performed on a separate organ/structure
XU Unusual non-overlapping service, the use of a service that is distinct because it does not overlap usual components of the main service
Date
Action
Notes
1986-01-01 Added Code added 1/1/1986
Code
Description
Code
Description
Code
Description
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