Hi Marsha,

Thank you for your question. L1971 relates to the Ankle-foot orthoses (AFO) base orthosis. L2220 X2 and L2265 refer to additions to the AFO. 
- L1971: ANKLE FOOT ORTHOSIS, PLASTIC OR OTHER MATERIAL WITH ANKLE JOINT, PREFABRICATED, INCLUDES FITTING AND ADJUSTMENT
- L2220 X2:  2x ADDITION TO LOWER EXTREMITY, DORSIFLEXION AND PLANTAR FLEXION ASSIST/RESIST, EACH JOINT
- L2265: ADDITION TO LOWER EXTREMITY, LONG TONGUE STIRRUP

As you mentioned, when ordering the device, all the codes above are to be used together. Each code represents a part of the product. The Zero G is an AFO that comes in two components: the Calf Lacer and the AFO Base. The "AFO base" has the base orthosis (L1971), to which 2 metal joints to assist dorsiflexion and plantar flexion (L2220) are attached. The long tongue stirrup corresponds to the Calf Lacer (L2265)

As a side note, L coded additions to AFO (L2220, L2265) will be denied as not reasonable and necessary if either the base orthosis is not reasonable and necessary or the specific addition is not reasonable and necessary. Note that ulcer is not a covered primary diagnosis. AFO L1971 is covered for ambulatory beneficiaries with weakness or deformity of the foot and ankle, who:
- Require stabilization for medical reasons, and,
- Have the potential to benefit functionally.
Also, one of the following criteria needs to be met:
and one of the following criteria are met:
- The beneficiary could not be fit with a prefabricated AFO; or,
- The condition necessitating the orthosis is expected to be permanent or of longstanding duration (more than 6 months); or,
- There is a need to control the knee, ankle or foot in more than one plane; or,
- The beneficiary has a documented neurological, circulatory, or orthopedic status that requires custom fabricating over a model to prevent tissue injury; or,
-The beneficiary has a healing fracture which lacks normal anatomical integrity or anthropometric proportions.

See medical necessity in Local Coverage Determination (LCD): Ankle-Foot/Knee-Ankle-Foot Orthosis (L33686) https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?lcdid=33686&ver=28&keyword=&keywordType=starts&areaId=all&docType=6,3,5,1,F,P&contractOption=all&hcpcsOption=code&hcpcsStartCode=L2220&hcpcsEndCode=L2220&sortBy=title&bc=AAAAAAQAAAAA

The manufacturer has templates for:
- Documentation of medical necessity http://zerogafo.com/downloads/ZeroG_Document_of_Medical_Necessity.pdf
- order form http://zerogafo.com/downloads/ZeroG_RX_Form.pdf
- Durable Medical Equipment Dispensing Form http://zerogafo.com/downloads/ZeroG_DME_Dispensing_Form.pdf

thank you, this was very helpful

Hi Elaine,
I have another question for you: why is the reason behind having three separate codes for one device (i.e. Zero G) when all three pieces make up the device and you cannot buy it without all three pieces?
thanks, Marsha

Hi Marsha,

In Zero G's case, when ordering the device for the first time, providers would use all 3 codes. But if a replacement part is needed, providers can order only a specific part without having to order the entire device again. For instance, if the Calf Lacer needs to be replaced, only L2265 would be used. 

Also, other devices may be composed of different parts. For instance, if you go to the DMECS website and search for L1971 (link below), you'll see several products to which this code has been assigned. When ordering those devices, depending on what other parts compose the product, providers would use L1971 alone or in combination with other HCPCS. codes. https://www4.palmettogba.com/pdac_dmecs/searchProductClassificationResults.do?codeDecision=L1971

Thank you Elaine; appreciate you getting back to me so quickly.
Best, Marsha