CMS adding California to RCD states

Effective Nov 2, 2026

Published Nov 2, 2026

Last Reviewed Nov 2, 2026

All California home health providers are expected to face new documentation review requirements under the Review Choice Demonstration (RCD) currently active in six other states.

If approved by the Office of Management and Budget, CMS says implementation in California will begin for billing periods on or after Jan. 18, 2027. Comments on the proposal must be submitted by Nov. 16, 2026.

Currently active in Florida, Illinois, North Carolina, Ohio, Oklahoma and Texas, RCD involves pre-claim or post-payment review. After proving claim compliance at 90% or greater, agencies can select a less burdensome review process, but most agencies begin with and continue on under pre-claim review as a safer way to protect reimbursement.

All existing RCD states are serviced by Palmetto GBA. If California is added to the model, it will be the first serviced by Wellpoint Federal.

In its argument for emergency consideration, CMS pointed to “significant fraud found in the traditional Medicare home health benefit in California.” Officials could be expanding RCD to California ahead of the expiration of the nationwide moratoria for home health and hospice providers on Nov. 13, 2026.

More info:

See the notice in the Federal Register at https://www.federalregister.gov/documents/2026/11/02/2026-22297/emergency-clearance-public-information-collection-requirements-submitted-to-the-office-of-management
See CMS’ RCD resources at https://www.cms.gov/data-research/monitoring-programs/medicare-fee-service-compliance-programs/prior-authorization-and-pre-claim-review-initiatives/review-choice-demonstration-home-health-services
See PalmettoGBA’s overview of RCD Choices at https://api-prod.palmettogba.com/h/elearn/rcd/story.html.

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