It comes up early in many procurement conversations, and it comes up well: «there's already reimbursement for virtual reality in the United States». That is true. And it is far narrower than the sentence suggests.
This article sets out exactly what exists, and what it does — or does not — mean for anyone building a budget in Portugal.
What exists
On 1 April 2023, CMS (the body running Medicare) created code E1905, described as a virtual reality cognitive behaviour therapy device, including pre-programmed therapy software. It was the first code assigned to a therapeutic VR device, following an application by AppliedVR, and came with a determination placing the product in the DMEPOS category — durable medical equipment.
The device in question, RelieVRx, had FDA authorisation for chronic low back pain, for home use, and had been through the breakthrough devices programme.
Those four things — the code, the category, the authorisation and the indication — travel together and do not come apart.
What follows is a supplier's reading of funding frameworks, not legal or coding advice. Always confirm with the payer, including against what is written here.
What the code is not
It is not a code for «virtual reality». It is a code for that device, with that indication, in that context of use. A second piece of equipment does not become reimbursable because the first obtained a code.
It is not a guarantee of payment, not even in the US. Having a code means there is a way to ask; actual coverage varies by payer, requires medical-necessity documentation and, in some cases, prior authorisation.
And it does not cross the Atlantic. Medicare is one country's system. Nothing decided there creates eligibility in Portugal — not in the NHS equivalent, not in the subsystems, not in private insurance.
Why it matters to buyers here
For two opposite reasons, both useful.
The first is a real signal. A large public payer accepted, for one concrete case, that virtual reality is clinical equipment and not a wellness accessory. That funds nothing in Lisbon, but it changes the tone of an internal conversation: the subject stopped being exotic.
The second is a defence. When a supplier quotes E1905 in a proposal, two questions settle it in thirty seconds:
- Is the code for your product, or someone else's? In the overwhelming majority of cases it is someone else's — and that is the honest answer.
- What practical consequence does it have for our budget? If the answer is «none directly», it is correct. If it is anything else, ask for it in writing.
Our answer to both is here: E1905 is not ours, we have no reimbursement code in Portugal, and no part of your investment is recoverable that way.
What actually exists here
The Portuguese framework is set out in funding and reimbursement, and the sentence worth repeating is this: medical device registration does not confer eligibility for public funding. They are separate things, and confusing them has already cost more than one project time.
What remains is the calculation an institution makes with its own numbers — the cost and return pillar — and honesty about what that calculation can prove, which we discuss in what cannot be proven.
What would sit behind a Portuguese code
It is worth understanding the distance, because it explains why this is not imminent.
A reimbursement code is not requested: it is built on a specific clinical indication, with evidence supporting it for that indication and a device in the matching risk class. RVer is Class I and its intended purpose is comfort and activity, not treatment. A product wanting a code would first have to change its claim — and with it its class, its regulatory burden and its cost.
That is a legitimate road and companies are walking it. It is not the road we are on, and saying so up front saves everyone a meeting.
The RVer platform's base product is a Class I medical device registered with Infarmed. Sessions are run by the institution's own professionals, complement existing care and do not replace clinical follow-up.