Why Does One California Episode Need Two Pre-Claim Reviews?

Two sentences in the operational guide CMS posted on Monday apply to exactly one state.

"California: A pre-claim review request may include only one 30-day period of care."

And, four pages later: "The multiple billing period option is not currently available in California. California HHAs must submit a separate pre claim review request for each 30-day billing period."

Everywhere else, a request can carry two or more 30-day periods for the same beneficiary. In California it carries one, and the guide spells out what travels with it: "all documentation for the episode must be submitted with each request, regardless of whether the request covers the first or second 30 days of the episode."

So a 60-day certification that runs its length is one submission in Tampa and two in Fresno, with the same chart uploaded both times.

The Dates Are Already Set

California enters the Review Choice Demonstration for billing periods beginning on or after January 18, 2027. Every home health agency in the state that bills Jurisdiction 6 is in, and the selection window runs November 16 to December 16.

Miss it and you are not left alone. CMS's own language: providers who do not make an initial review choice selection "will default to participate in Choice 2: Postpayment Review."

There are two initial choices now, pre-claim review or postpayment review, and the six-month gate to anything lighter is a 90% affirmation or approval rate on a minimum of ten submissions.

Scale first, because it decides how much the carve-out is worth. California billed 1,339,384 30-day home health periods in CY2024 against $3.26 billion, which is 1.597x Texas and 50.7% of all six demonstration states put together (chart below).

It is the biggest state in the program and the only one that cannot pair a period.

The Approved Paperwork Says You Can Bundle

Here is the catch. The demonstration runs on an information collection, CMS-10599 under OMB control number 0938-1311, and the California expansion is a revision of it.

The RCD page says so in terms: "Implementation is dependent on approval of revisions to PRA package CMS-10599/OMB 0938-1311."

Supporting Statement A for the version OMB approved on December 22, 2025 describes the collection this way:

"Under the pre-claim review option, a pre-claim review request is submitted for each 30-day billing period. Providers may request multiple billing periods on one pre-claim review request for an individual beneficiary."

That sentence is the approved design. The operational guide turns it off for the one state being added, and the burden estimate attached to the revision is the sixteen-state 1,600,608 hours, carried over without a California line.