Hi-Lo Bed: What It Is, FDA Classes and Medicare Codes

This page describes products and general use; it is not medical advice.

A hi-lo bed is a bed whose sleeping surface height can be raised and lowered, usually by a built-in electric motor. This page maps the trade term “hi-lo” to the FDA device types and the Medicare billing categories that actually describe height adjustment.

What is a hi-lo bed?

“Hi-lo” is a trade term for a bed with an adjustable height: the frame goes high for a caregiver to work at a comfortable level and low for getting in and out. It is not a classification used by the FDA. The regulations instead describe adjustable hospital beds by how the height is moved: by the patient with an electric motor, or by an attendant with a hydraulic or manual mechanism. Users include nursing and care staff, clinic buyers and people arranging a bed for home care. For the fixed-height bed that a hi-lo bed is usually compared with, see what is a hospital bed.

How height adjustment is built

Under 21 CFR 880.5100, an AC-powered adjustable hospital bed has “a built-in electric motor and remote controls that can be operated by the patient to adjust the height and surface contour of the bed.” Under 21 CFR 880.5110 a hydraulic adjustable hospital bed uses “a hydraulic mechanism operated by an attendant,” and under 21 CFR 880.5120 a manual adjustable hospital bed uses “a manual mechanism operated by an attendant,” in both cases to adjust the height and surface contour. All three regulations state that the device includes movable and latchable side rails.

Types and how the FDA classifies them

Type of adjustable bed	Who operates the height	FDA class	Regulation
AC-powered adjustable hospital bed	Patient, with remote controls	Class II (special controls), exempt from 510(k) subject to 21 CFR 880.9	21 CFR 880.5100
Hydraulic adjustable hospital bed	Attendant	Class I (general controls), exempt from 510(k) subject to the limits in 21 CFR 880.9	21 CFR 880.5110
Manual adjustable hospital bed	Attendant	Class I (general controls), exempt from 510(k) subject to the limits in 21 CFR 880.9	21 CFR 880.5120

Source: 21 CFR 880.5100, 880.5110 and 880.5120 as published at Cornell Legal Information Institute, checked 2026-10-30. In the FDA classification database (openFDA, checked 2026-10-30) the records under 880.5100 are “Bed, Ac-Powered Adjustable Hospital” (class 2, product code FNL), “Bariatric Bed” (class 2, OSI) and “Bed, Therapeutic, Ac-Powered, Adjustable Home-Use” (class 2, LLI).

Medicare coding: fixed-height, variable-height and electric beds

Medicare is a clear published example of how height adjustment is treated differently from other bed features. The table follows the CMS Medicare Learning Network compliance tip “Hospital Beds & Accessories” (checked 2026-10-30), which cites Local Coverage Determination L33820. It describes Medicare coverage only and is not a rule for choosing a bed.

Bed category	HCPCS codes	What CMS says
Fixed-height	E0250, E0251, E0290, E0291, E0328	Covered if the patient meets one or more listed criteria, such as a condition requiring body positioning that an ordinary bed cannot provide.
Variable-height	E0255, E0256, E0292, E0293	Covered if the patient meets one of the fixed-height criteria and requires a bed height different from a fixed-height bed to transfer to a chair, wheelchair or standing position.
Semi-electric	E0260, E0261, E0294, E0295, E0329	Covered if the patient meets one of the fixed-height criteria and requires frequent changes in body position or has an immediate need for one.
Total electric	E0265, E0266, E0296, E0297	Not covered: CMS states the height adjustment feature is a convenience feature, so these are denied as not reasonable and necessary.

A bed sold as “hi-lo” can therefore fall into more than one of these categories, depending on which functions are electric. The category, not the marketing name, is what the coverage text addresses.

Safe use and handling basics

All three FDA bed types above include movable and latchable side rails, so rails are part of how these beds are defined. Gaps around rails and mattresses are a separate hazard covered in bed rail covers. Follow the manufacturer’s instructions for use for the specific model. Related equipment used when moving a person between surfaces is covered in what is a patient lift and what is a gurney.

Common mistakes

• Treating “hi-lo” as an FDA category. The regulations describe powered, hydraulic and manual adjustable beds instead.
• Assuming every height-adjustable bed is covered by Medicare. CMS separates variable-height, semi-electric and total electric beds and does not cover total electric ones.
• Assuming the person in the bed controls the height. Under the FDA definitions only the AC-powered type is described as operated by the patient; hydraulic and manual types are operated by an attendant.

Frequently asked questions

What does hi-lo mean on a bed?

It means the bed height can be raised and lowered. It is a trade term, not an FDA category; the FDA regulations call these adjustable hospital beds (21 CFR 880.5100, 880.5110, 880.5120).

Is a hi-lo bed a hospital bed?

A bed that adjusts height and surface contour fits the FDA’s adjustable hospital bed definitions. The AC-powered type is Class II; hydraulic and manual types are Class I (checked 2026-10-30).

Does Medicare cover a hi-lo bed?

It depends on the category. CMS covers a variable-height bed when the patient meets a fixed-height criterion and needs a different bed height to transfer or stand, and does not cover total electric beds (CMS compliance tip, checked 2026-10-30).

Sources

• 21 CFR 880.5100, 880.5110, 880.5120, law.cornell.edu/cfr/text/21/880.5100, checked 2026-10-30.
• openFDA device classification API, api.fda.gov/device/classification.json, checked 2026-10-30.
• CMS Medicare Learning Network, Hospital Beds & Accessories, cms.gov, checked 2026-10-30.