CMS to exercise enforcement discretion regarding initial interdisciplinary team meeting requirement for IRF admissions 

The Centers for Medicare & Medicaid Services announced that it will exercise enforcement discretion for inpatient rehabilitation facility admissions from Oct. 1, 2026 through March 31, 2027, with respect to the timing of the initial interdisciplinary team meeting requirement. As of Oct. 1, the initial IDT meeting must occur on or before four days from the date a patient is admitted to an IRF in order to implement appropriate treatment services; establish or review the patient’s stated rehabilitation goals; and identify problems that could impede those goals. This requirement was finalized in the fiscal year 2027 IRF prospective payment system final rule. The AHA had urged CMS not to finalize this requirement, in part due to its inconsistent descriptions of when the four-day threshold would be met relative to admission. 

During this six-month moratorium, Medicare Administrative Contractors will enforce the initial IDT meeting timing requirement that had been in effect during FY 2026. This means they 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 a patient’s stay. CMS said that all other applicable IRF coverage and documentation requirements remain in effect.