Downcoded

Your IDT Meeting Now Needs Its Own Chart Entry

CMS revised four sections of the IRF benefit policy manual on Thursday, stamped them effective October 1, and gave the MACs until November 17 to implement. Two of the instructions that landed are not in the regulation at all: the day of admission is day 1, and the initial team meeting has to be documented separately from the plan of care.


The four sections of the Medicare Benefit Policy Manual that decide whether an IRF stay is covered had carried the same words since August 2021.

On Thursday CMS rewrote them.

Transmittal 14001 posted at 12:04 GMT and revised Pub. 100-02 sections 110.1.1, 110.1.3, 110.2.2 and 110.2.5, all of them stamped effective October 1, 2026. Implementation date for the MACs: November 17.

The summary of changes calls the work "technical and conforming."

Two weeks of admissions already sit behind that effective date (chart below).

The Sentence That Reversed Itself

Here is what section 110.1.3 said until Thursday, about the first interdisciplinary team meeting:

"While CMS believes that it may be good practice to conduct the first interdisciplinary team meeting within the first 4 days of admission..."

Good practice. And here is the replacement:

"42 CFR § 412.622(a)(5)(ii) requires that the initial IDT meeting must occur on or before the fourth day from the date the patient is admitted."

The regulation did change on October 1, so the manual had to move. What the manual added on its own is the counting rule.

The new 110.1.3 ends the plan-of-care deadline with four words the old one did not have: "with the day of admission being day 1." Section 110.2.5 now carries the same clause for the meeting.

Go read 412.622(a)(5)(ii) and you will not find it. The regulation says "on or before 4 days from the date the patient is admitted" and stops.

The day-1 convention lives in a response to comments in the August final rule, where CMS wrote that "day 1 is the day of admission" and worked the example: a patient admitted on a Thursday has until end of day Sunday.

So if you admitted someone this afternoon, the meeting is due Sunday. Not Monday.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

$50 a month, or $500 a year.