Inpatient Rehabilitation Facility PPS

Exercise of Enforcement Discretion for the Initial Implementation of the Mandatory Initial Interdisciplinary Team Meeting Requirement for Inpatient Rehabilitation Facilities Through March 31, 2027

Starting October 1, 2026, an initial interdisciplinary team (IDT) meeting must occur on or before 4 days from the date a patient is admitted to an inpatient rehabilitation facility (IRF) to implement appropriate treatment services; establish or review the patient's stated rehabilitation goals; and identify any problems that could impede goals (42 CFR 412.622(a)(5)(ii)). This new requirement was finalized in the FY 2027 IRF final rule that appeared in the Federal Register in August 2026 (91 FR 48982).  Before the effective date of this final rule, IRFs had to provide the IDT meetings at least once per week throughout the duration of the patient's stay.

While IRFs are required to provide the initial IDT meeting on or before 4 days from the date a patient is admitted to an IRF, from October 1, 2026, through March 31, 2027, the Centers for Medicare & Medicaid Services (CMS) is exercising enforcement discretion during this 6-month period with respect to the timing of the initial IDT meeting under § 412.622(a)(5)(ii). For IRF admissions during this period, Medicare Administrative Contractors (MACs) will not deny or non-affirm a claim based solely on the timing of the initial IDT meeting if an IDT meeting occurs at least once per week throughout the duration of the patient's stay. During this 6-month period, MACs will enforce the timing requirement of the initial IDT meeting under § 412.622(a)(5)(ii) that had been in effect during FY 2026. All other applicable IRF coverage and documentation requirements remain in effect. This enforcement discretion applies only to the timing of the initial IDT meeting under § 412.622(a)(5)(ii) and does not modify the regulatory requirement or otherwise change the requirements at § 412.622.

CMS received feedback from stakeholders regarding the initial IDT meeting requirement. While CMS did receive comments on the proposed regulations, several of these stakeholders stated that they did not realize the impact of the regulatory changes and later expressed concern with a limited time to adjust processes for the effective date of the FY 2027 final rule. The enforcement discretion outlined above provides time for CMS to address these concerns. We anticipate that IRFs will use the enforcement discretion period to implement the processes necessary to comply with the 4-day requirement when this 6-month enforcement discretion expires.

For questions regarding this notice, please contact IRFCoverage@cms.hhs.gov.

Inpatient Rehabilitation Facilities: FY 2027 Final Rule – Learn What's New

CMS issued the FY 2027 Inpatient Rehabilitation Facilities (IRF) Prospective Payment System final rule to update payment policy and rates. CMS also issued an associated correction notice (CMS-1845-CN) on September 30, 2026.

IRF Provider Education Webinar: FY 2027 IRF Final Rule Updates

CMS hosted a national provider education webinar for inpatient rehabilitation facility (IRF) providers on September 29, 2026.

The webinar reviewed FY 2027 IRF Prospective Payment System (PPS) final rule policies and related Medicare coverage requirements, including revisions related to:

• The 36-hour requirement
• Initial interdisciplinary team meeting requirements
• Documentation expectations related to these requirements

The webinar was intended to help IRF providers understand finalized rule revisions, support consistent application of Medicare coverage requirements, and reduce the risk of documentation and billing errors.

Webinar recording: A recording of the webinar will be posted here as soon as it is available.

Materials: 

• Medicare Inpatient Rehabilitation Facility: FY 2027 Final Rule Education (PDF)
• IRF: 36-Hour Requirement (PDF)
• IRF: Initial IDT Meeting (PDF)
• IRF: FY 2027 Final Rule Frequently Asked Questions (PDF)

Providers may submit questions about the webinar or related materials to IRFCoverage@cms.hhs.gov.

***ATTENTION***  Please note that CMS has removed the file entitled, “ARCHIVED - IRF Coverage Requirements (ZIP)” from the CMS website.  This file no longer accurately reflects our policies. We encourage providers to reference the applicable statues, regulations, and other interpretive materials for complete and current information about CMS’s IRF PPS policies.