Explore the 2027 Home Health Final Rule in Detail
Choose by December 16, 2026, or you are assigned to post payment review. CMS announced on November 2 that the Review Choice Demonstration (RCD) is coming to California home health agencies that bill MAC Jurisdiction 6 (Wellpoint Federal), and the path you pick will shape your cash flow, staffing, and compliance workload well into 2027.
The selection period runs from November 16 to December 16, 2026, and the demonstration begins with billing periods starting on or after January 18, 2027. CMS notes that implementation depends on approval of revisions to its Paperwork Reduction Act package, so check the CMS RCD page for updates.
Agencies have 30 days to choose, then about a month before the first affected billing period begins.
Each agency selects one starting path. If you make no selection, you are assigned to post-payment review, which can be a costly default for an agency that has not weighed the options.
Many agencies start with pre-claim review because it gives certainty. Documentation gaps are fixed before a claim exists, rather than surfacing months later as recoupments. CMS statistics for fiscal year 2024 show that most demonstration providers chose pre-claim review and most of those requests were affirmed. Those figures are aggregated across the existing demonstration states, not California, but they suggest the process is manageable when documentation is strong.
Pre-claim review also matters for what comes after. Agencies that hold a 90% full affirmation rate across at least 10 requests in a six-month cycle become eligible for lighter review options, including relief from most reviews. Only fully affirmed decisions count toward that rate.
Post-payment review can still be the right call. It tends to suit an agency with very strong documentation, a volume of 30-day periods that would strain staff to submit one by one, or the cash reserves to absorb recoupment risk. The right choice depends on your documentation quality, volume, and staffing, which is the question we help agencies answer.
In California, each pre-claim request covers a single 30-day billing period, so every period needs its own submission and its own UTN. An agency with an average daily census (ADC) of 300, for example, submits roughly 450 to 600 requests every 30 days before those claims can bill. Even a modest review time per patient adds up quickly.
Selections are made at the PTAN level, so an agency with several PTANs or branches makes each choice separately and multiplies the work. That is why the operational side of pre-claim review deserves as much attention as the choice itself.
Billing without a decision on file. The claim stops for prepayment review and, if payable, takes a payment reduction that cannot be appealed.
Submitting an incomplete packet. It becomes a non-affirmed decision, which counts against your affirmation rate.
Billing a non-affirmed request. The claim will deny.
Strong packets start with the basics: a valid plan of care and physician orders, a face-to-face encounter within the required window, and clear documentation of homebound status, skilled need, and physician care.
We also bring experience from every other RCD demonstration state. We have gathered lessons learned and best practices along the way, and we share them with our customers, so California agencies do not have to learn them the hard way.
The selection period is only 30 days, and the preparation work does not end when you choose. Agencies that model their options and build their workflow now will enter 2027 ready. Book a readiness review with Maxwell TEC before November 16 by emailing sales@maxwelltec.com.
Sources: CMS, “Review Choice Demonstration for Home Health Services (RCD),” updated November 2026; CMS HH RCD Operational Guide. Confirm current requirements with CMS and Wellpoint Federal.