Supporting the Physiatrist, Strengthening the Specialty

Academy Representatives Continue Discussions with CMS About Further Policy Changes

CMS will not enforce the new Day 4 initial interdisciplinary team (IDT) meeting requirement for inpatient rehabilitation facility (IRF) admissions from October 1, 2026 through March 31, 2027. The FY 2027 IRF Prospective Payment System final rule requires the first IDT meeting by Day 4, with the admission date counted as Day 1.

According to CMS, during this six-month period, Medicare Administrative Contractors will not deny or non-affirm a claim based solely on the timing of the initial meeting, as long as an IDT meeting occurs at least once per week throughout the patient's stay. IRFs must still meet all other coverage and documentation requirements.

Read the full CMS Announcement: Inpatient Rehabilitation Facility PPS | CMS

While this welcome reprieve is a win for PM&R physicians, the Academy will continue its strong advocacy work to fight for further IRF policy flexibilities, and we will share news as it develops.

How Academy advocacy impacted the CMS decision

After several months of sustained advocacy, CMS announced this enforcement discretion in direct response to stakeholder feedback. The Academy's work included:

• Clearly and repeatedly communicating our concerns in three strongly worded responses to CMS:
  • Our comment letter on the FY 2027 IRF PPS proposed rule 
  • A letter raising serious concerns about the new IRF medical necessity requirements in the final rule
  • A letter from PM&R department chairs and division chiefs on the finalized FY 2027 coverage requirements
• Ensuring we’re at the table by meeting with CMS clinical leaders and policy experts, including an October 26 meeting with 12 CMS representatives to discuss further potential flexibilities related to the IDT conference policy and the new requirement to initiate therapy within 36 hours of admission.
• Participating in related coalition efforts including additional meetings and sign-on letters.

   

  A special thank you to Academy leaders Drs. Kerry DeLuca, Susan Hubbell, Darryl Kaelin, Lauren Shapiro and David Steinberg for attending meetings with CMS officials, and to all the PM&R department chairs and division chiefs who signed the Academy's letter to CMS. Your efforts made a meaningful difference!

   

  What this means for IRF Rehabilitation Physicians

• Keep meeting weekly. The reprieve applies only if an IDT meeting occurs at least once per week throughout each patient's stay.
• Use the window to prepare. CMS expects IRFs to build processes that meet the Day 4 requirement before the discretion period ends on March 31, 2027.
• Watch for updates. Academy representatives are continuing to advocate for PM&R physicians and the patients you serve and we will share news as it develops.
• Dive deeper. Our educational resources cover current IRF policies and CMS programs such as the IRF Review Choice Demonstration. Start with the October 26 AAPM&R webinar, “Expert Conversation: Strategies for Navigating New IRF Policies”

Questions... Contact healthpolicy@aapmr.org.

Academy Representatives Continue Discussions with CMS About Further Policy Changes

CMS will not enforce the new Day 4 initial interdisciplinary team (IDT) meeting requirement for inpatient rehabilitation facility (IRF) admissions from October 1, 2026 through March 31, 2027. The FY 2027 IRF Prospective Payment System final rule requires the first IDT meeting by Day 4, with the admission date counted as Day 1.

According to CMS, during this six-month period, Medicare Administrative Contractors will not deny or non-affirm a claim based solely on the timing of the initial meeting, as long as an IDT meeting occurs at least once per week throughout the patient's stay. IRFs must still meet all other coverage and documentation requirements.

Read the full CMS Announcement: Inpatient Rehabilitation Facility PPS | CMS

While this welcome reprieve is a win for PM&R physicians, the Academy will continue its strong advocacy work to fight for further IRF policy flexibilities, and we will share news as it develops.

How Academy advocacy impacted the CMS decision

After several months of sustained advocacy, CMS announced this enforcement discretion in direct response to stakeholder feedback. The Academy's work included:

• Clearly and repeatedly communicating our concerns in three strongly worded responses to CMS:
  • Our comment letter on the FY 2027 IRF PPS proposed rule 
  • A letter raising serious concerns about the new IRF medical necessity requirements in the final rule
  • A letter from PM&R department chairs and division chiefs on the finalized FY 2027 coverage requirements
• Ensuring we’re at the table by meeting with CMS clinical leaders and policy experts, including an October 26 meeting with 12 CMS representatives to discuss further potential flexibilities related to the IDT conference policy and the new requirement to initiate therapy within 36 hours of admission.
• Participating in related coalition efforts including additional meetings and sign-on letters.

   

  A special thank you to Academy leaders Drs. Kerry DeLuca, Susan Hubbell, Darryl Kaelin, Lauren Shapiro and David Steinberg for attending meetings with CMS officials, and to all the PM&R department chairs and division chiefs who signed the Academy's letter to CMS. Your efforts made a meaningful difference!

   

  What this means for IRF Rehabilitation Physicians

• Keep meeting weekly. The reprieve applies only if an IDT meeting occurs at least once per week throughout each patient's stay.
• Use the window to prepare. CMS expects IRFs to build processes that meet the Day 4 requirement before the discretion period ends on March 31, 2027.
• Watch for updates. Academy representatives are continuing to advocate for PM&R physicians and the patients you serve and we will share news as it develops.
• Dive deeper. Our educational resources cover current IRF policies and CMS programs such as the IRF Review Choice Demonstration. Start with the October 26 AAPM&R webinar, “Expert Conversation: Strategies for Navigating New IRF Policies”

Questions... Contact healthpolicy@aapmr.org.