The Centers for Medicare and Medicaid Services (CMS) has announced plans to expand the Inpatient Rehabilitation Facility (IRF) Review Choice Demonstration (RCD) to Texas effective March 2, 2026, and California effective May 1, 2026.
AAPM&R has significant concerns about this expansion and strongly opposes extending the IRF RCD to additional states. This project dramatically increases physician burden in a field already subject to onerous documentation requirements and serves as an unprecedented intrusion by CMS contractors in the exercise of independent physician judgment.
IRF providers in Texas will need to make their selection for how to engage with the RCD from January 15–February 13, 2026, selecting either 100% pre-claim review or 100% postpayment. IRF providers in California will need to make their selection in the March 16 – April 14 window.
Please visit the CMS website for additional updates and reference materials on the IRF RCD.
Background on the IRF RCD
As you may know, the IRF RCD, which is currently underway in Alabama and Pennsylvania, involves CMS contractors reviewing all Medicare Fee-for-Service claims for patients being admitted for care in the IRF setting. This program was first proposed in 2021 and was initiated by CMS in the state of Alabama in 2023. This program expanded to Pennsylvania in 2024.
CMS is eventually planning to eventually expand the RCD to all providers in four Medicare Administrative Contract (MAC) jurisdictions, covering 17 states, three U.S. territories, and the District of Columbia.
Academy Advocacy
The Academy has been actively engaged with CMS on this matter since the IRF RCD was first proposed in 2021. This work has included engaging with impacted Academy members, meeting and corresponding with CMS staff and policymakers, and working in coalition with allied stakeholder organizations to try to either halt, or delay, this program or to blunt its impact on PM&R physicians and their patients.
As part of the Academy’s continuing advocacy efforts on this critical issue, AAPM&R formally urged CMS in July of this year to halt the expansion of the IRF RCD into Texas and California and consider sunsetting the entire program, citing serious concerns related to patient access to inpatient rehabilitation care, unnecessary administrative burden on providers, and the continuing absence of evidence demonstrating waste, fraud, or abuse within IRFs.
The Academy also supported a recent initiative led by U.S. Representatives from the state of Texas, a congressional letter urging CMS to halt the expansion of the IRF RCD before it expanded to Texas. The Academy engaged members from Texas via a grassroots advocacy campaign, asking them to contact their congressional representatives and urge them to support this effort. This letter, signed by 24 out of 25 members of the Texas Republican congressional delegation in the U.S. House of Representatives, was sent to CMS on November 26.
The Academy remains committed to ensuring that physiatrists and the patients they serve are not subjected to unnecessary regulatory burden or restricted access to appropriate rehabilitative care and will continue to advocate against any further expansion of the IRF RCD and for the eventual sunsetting of this program.
Please contact Academy staff at healthpolicy@aapmr.org if you have any questions about the IRF RCD.