Background
CMS launched the Review Choice Demonstration (RCD) for home health agencies (HHAs) on June 1, 2019, beginning with Illinois. The demonstration expanded to Ohio, Texas, North Carolina, Florida, and Oklahoma at periodic intervals through 2023. Every current RCD state falls under Medicare Administrative Contractor (MAC) Palmetto GBA Jurisdiction M.
Effective June 1, 2024, CMS extended RCD for an additional five years through May 31, 2029.
Recent Developments
On October 30, 2026, CMS posted a notice requesting a 14-day public comment period and expedited approval through the emergency clearance process under the Paperwork Reduction Act (PRA). The request supports the expansion of RCD to California. The notice states:
“A delay in the expansion means an extended time the public will be harmed through the continuation of significant fraud found in the traditional Medicare home health benefit in California through the waste of taxpayer money, a loss of funds from the Medicare Trust Funds that could have been used for truly needed care, paying for care that is never delivered, and beneficiaries potentially receiving non-medically necessary care.”
The Federal Register CMS-10599/OMB 0938-1311 was subsequently released on November 2, 2026 and revised on November 4, 2026, with official clarification of the comment period to ensure RCD is expanded to California within the specified time frame. California HHAs fall under MAC Wellpoint Federal Jurisdiction 6.
The CMS RCD webpage adds that “Implementation is dependent on approval of revisions to PRA package CMS-10599/OMB 0938-1311.”
Dates to Know
- November 16, 2026 – Deadline for public comments
- November 16, 2026 – California RCD selection period start date
- December 16, 2026 – California RCD selection period end date
- January 18, 2027 – Planned California demonstration start date
The Options
California HHAs will have the option to select between two initial review choices:
- Choice 1: 100% Pre-Claim Review (PCR)
- Choice 2: 100% Post-Payment Review
Under Choice 1, each billing period must go through the PCR process before the claim can be billed. The HHA submits a request to Wellpoint Federal with the required documentation for each billing period. Wellpoint Federal then assigns a Unique Tracking Number (UTN) to the billing period, reviews the documentation, and issues either a provisional affirmation or a non-affirmation. If provisionally affirmed, the UTN must be added to the billing period claim and submitted for payment following all standard Medicare billing requirements. If non-affirmed, the HHA should correct any issues and resubmit the PCR. There is no limit on how many times a non-affirmed billing period can be resubmitted in pursuit of a provisionally affirmed result. Claims billed without a provisional affirmation and accurate UTN are subject to full pre-payment medical review and a 25% payment reduction.
Under Choice 2, the HHA submits each billing period claim for payment, following all standard Medicare billing requirements. Once Wellpoint Federal processes the claim for payment, the HHA will receive an Additional Documentation Request (ADR) and must respond with the complete medical record documentation within the required time frame. If the claim is denied following the post-pay medical review, recoupment procedures will begin and the HHA will retain all appeal rights.
HHAs that do not make a selection will automatically be assigned to Choice 2. The selection process is expected to take place in the Wellpoint Federal provider portal.1
What to Expect
Billing periods beginning on or after January 18, 2027 are expected to be subject to RCD.
Every six months the HHA’s PCR affirmation rate or post-payment review approval rate will be calculated. Based on those results, HHAs may have additional choices for subsequent RCD rounds. The below HHA RCD flowchart is a helpful resource that outlines the initial and subsequent choices.
Source: cms.gov
Historically, Palmetto GBA has indicated that many providers continue with the PCR option even when given the additional choices. While PCR can initially be burdensome, once an HHA has internal processes in place, it offers added confidence of payment outcomes when affirmations are received in advance of claim submission. It also significantly reduces the likelihood of ADRs and having to work through appeal stages.
Although California and Wellpoint Federal are both new to the HHA RCD process, HHAs can draw on existing CMS guidance and resources. Wellpoint Federal has added RCD information to its website,2 and for additional details, the CMS RCD Home Health Operational Guide and FAQs are available for download.
If you have any questions about RCD or would like guidance preparing your HHA for participation, please reach out to our team at Forvis Mazars today.