The second denial was on a different ground.

It said the requested chair exceeded the plan’s criteria for the equipment category, and that a standard folding chair was sufficient to meet the member’s mobility needs within the home.

Within the home.

That is a real criterion and it is in a great many policies and it is the single most fought-over phrase in all of durable medical equipment, because a chair that gets you to your own bathroom is not a chair that gets a thirteen-year-old through a school building, and a plan that is only obliged to fund the first one will fund the first one.

And this time Jillian Lin did not put the letter on the microwave.