Supporting the Physiatrist, Strengthening the Specialty

The Centers for Medicare & Medicaid Services (CMS) has announced that the Inpatient Rehabilitation Facility (IRF) Review Choice Demonstration (RCD) will expand to all IRFs that bill to Medicare Administrative Contractor (MAC) Jurisdiction JJ, which covers additional sites in Alabama, Georgia and Tennessee. The expansion takes effect January 1, 2027. It applies to IRFs billing to MAC Jurisdiction JJ wherever they are physically located. The IRF RCD is currently in effect in Alabama, California, Texas and Pennsylvania.  

AAPM&R continues to express significant concerns about the IRF RCD. The Academy has worked to oppose this demonstration since it was first introduced and continues to strongly oppose extending it further. 

What Affected IRFs Need to Know 

Affected IRFs must choose either 100% pre-claim review or 100% post-payment review in the Palmetto GBA Provider Portal during the selection period: 

• Selection period: November 13 – December 14, 2026 

• Cycle 1: January 1 – June 30, 2027 

• Calculation period: July 1–15, 2027 

• Results letters: July 16–31, 2027 

For full details, see the Palmetto GBA IRF RCD resource page and the CMS IRF RCD landing page. 

Prepare with AAPM&R: Watch the Webinar Recording 

If you practice in an expansion state, we encourage you to watch the recording of AAPM&R’s Expert Conversations in PM&R Practice: Preparing for the IRF RCD. AAPM&R’s panelists share insights and best practices from PM&R physicians already working under the IRF RCD. You’ll gain practical strategies to stay compliant and help preserve timely access to care for your Medicare patients. 

Watch the Recording

Background on the Academy’s Extensive Advocacy Around the IRF RCD  

Under the IRF RCD, CMS contractors review 100% of Medicare Fee-for-Service claims for patients admitted to IRFs. CMS first proposed the program in 2021 and launched it in parts of Alabama in 2023. It expanded to Pennsylvania in 2024 and to Texas and California in 2026. CMS ultimately plans to expand the RCD to all providers in four MAC jurisdictions, covering 17 states, three U.S. territories and the District of Columbia. 

The Academy has worked to oppose the IRF RCD since it was introduced, including urging CMS to withdraw it when it was first proposed in 2021. Highlights include: 

• Formal comments to CMS: In July 2025, AAPM&R formally urged CMS to halt the expansion into Texas and California and to consider sunsetting the program. The Academy cited concerns about patient access to inpatient rehabilitation, unnecessary administrative burden and the continued lack of evidence of waste, fraud or abuse in IRFs. 

• AMA policy: The PM&R delegation to the AMA House of Delegates championed a successful policy proposal at the November 2025 Interim Meeting. That policy led the AMA to urge CMS to abandon the RCD. 

• Congressional engagement: The Academy supported a congressional letter urging CMS to halt the expansion into Texas and ran a grassroots campaign asking Texas members to contact their representatives to urge them to sign-on. The letter was signed by 24 of the 25 members of the Texas Republican House delegation and sent to CMS on November 26, 2025. 

AAPM&R will continue advocating against any further expansion of the IRF RCD and will provide any pertinent updates as they occur.  

Get Involved 

Make your voice heard. Get involved by joining a health policy committee, participating in grassroots campaigns and taking action through the Member Action Center. 

• Advocacy Action Center 

• Academy Comments Page 

Questions about the IRF RCD? Contact Academy staff at healthpolicy@aapmr.org. 

The Centers for Medicare & Medicaid Services (CMS) has announced that the Inpatient Rehabilitation Facility (IRF) Review Choice Demonstration (RCD) will expand to all IRFs that bill to Medicare Administrative Contractor (MAC) Jurisdiction JJ, which covers additional sites in Alabama, Georgia and Tennessee. The expansion takes effect January 1, 2027. It applies to IRFs billing to MAC Jurisdiction JJ wherever they are physically located. The IRF RCD is currently in effect in Alabama, California, Texas and Pennsylvania.  

AAPM&R continues to express significant concerns about the IRF RCD. The Academy has worked to oppose this demonstration since it was first introduced and continues to strongly oppose extending it further. 

What Affected IRFs Need to Know 

Affected IRFs must choose either 100% pre-claim review or 100% post-payment review in the Palmetto GBA Provider Portal during the selection period: 

• Selection period: November 13 – December 14, 2026 

• Cycle 1: January 1 – June 30, 2027 

• Calculation period: July 1–15, 2027 

• Results letters: July 16–31, 2027 

For full details, see the Palmetto GBA IRF RCD resource page and the CMS IRF RCD landing page. 

Prepare with AAPM&R: Watch the Webinar Recording 

If you practice in an expansion state, we encourage you to watch the recording of AAPM&R’s Expert Conversations in PM&R Practice: Preparing for the IRF RCD. AAPM&R’s panelists share insights and best practices from PM&R physicians already working under the IRF RCD. You’ll gain practical strategies to stay compliant and help preserve timely access to care for your Medicare patients. 

Watch the Recording

Background on the Academy’s Extensive Advocacy Around the IRF RCD  

Under the IRF RCD, CMS contractors review 100% of Medicare Fee-for-Service claims for patients admitted to IRFs. CMS first proposed the program in 2021 and launched it in parts of Alabama in 2023. It expanded to Pennsylvania in 2024 and to Texas and California in 2026. CMS ultimately plans to expand the RCD to all providers in four MAC jurisdictions, covering 17 states, three U.S. territories and the District of Columbia. 

The Academy has worked to oppose the IRF RCD since it was introduced, including urging CMS to withdraw it when it was first proposed in 2021. Highlights include: 

• Formal comments to CMS: In July 2025, AAPM&R formally urged CMS to halt the expansion into Texas and California and to consider sunsetting the program. The Academy cited concerns about patient access to inpatient rehabilitation, unnecessary administrative burden and the continued lack of evidence of waste, fraud or abuse in IRFs. 

• AMA policy: The PM&R delegation to the AMA House of Delegates championed a successful policy proposal at the November 2025 Interim Meeting. That policy led the AMA to urge CMS to abandon the RCD. 

• Congressional engagement: The Academy supported a congressional letter urging CMS to halt the expansion into Texas and ran a grassroots campaign asking Texas members to contact their representatives to urge them to sign-on. The letter was signed by 24 of the 25 members of the Texas Republican House delegation and sent to CMS on November 26, 2025. 

AAPM&R will continue advocating against any further expansion of the IRF RCD and will provide any pertinent updates as they occur.  

Get Involved 

Make your voice heard. Get involved by joining a health policy committee, participating in grassroots campaigns and taking action through the Member Action Center. 

• Advocacy Action Center 

• Academy Comments Page 

Questions about the IRF RCD? Contact Academy staff at healthpolicy@aapmr.org.