RCD pre-claim review is a Medicare process in which a home health agency (HHA) sends supporting documentation for a 30-day billing period to its Medicare Administrative Contractor (MAC) before submitting the final claim. The MAC returns a provisional affirmed or non-affirmed decision, generally within 10 business days, and the agency reports the decision’s Unique Tracking Number (UTN) on the claim. Pre-claim review is one of two initial choices under the Review Choice Demonstration (RCD), which applies today to agencies in Illinois, Ohio, Texas, North Carolina, Florida, and Oklahoma, and is scheduled to begin in California for billing periods starting on or after January 18, 2027.
Last verified against CMS guidance on November 5, 2026. RCD details can change, so confirm current requirements with CMS and your MAC before acting on them.
The Review Choice Demonstration for Home Health Services is a CMS program that lets agencies choose how they demonstrate compliance with Medicare home health requirements. According to the CMS RCD page, the demonstration is intended to reduce appeals, improve provider compliance, and avoid delaying care. It does not change the Medicare home health benefit itself.
CMS extended the demonstration for five years effective June 1, 2024, and removed the former option of minimal review with a 25% payment reduction.
Definition: Pre-claim review under RCD is a review of an agency’s supporting documentation for a 30-day billing period, completed before the final claim is submitted. The decision letter and UTN show whether the MAC provisionally affirmed or non-affirmed the request.
The CMS RCD page (last modified November 4, 2026) and the updated RCD Operational Guide identify two MAC jurisdictions:
RCD applies to HHAs located in these states that bill the named MACs, and to Original Medicare fee-for-service beneficiaries. Requests for Medicare Advantage or Medicaid beneficiaries are rejected. HHAs under Unified Program Integrity Contractor (UPIC) review are not eligible to participate. CMS has previously stated that it can add states within the Jurisdiction M MAC when claims data support it, as it did with Oklahoma, so agencies outside the current states should keep watching CMS updates.
Agencies start with one of two choices, selected at the PTAN level through the MAC’s provider portal no later than two weeks before the demonstration begins in their state:
Agencies that do not make a selection default to Choice 2.
Performance is measured in six-month cycles. An agency with a full affirmation rate (pre-claim review) or claim approval rate (postpayment review) of at least 90%, based on at least 10 requests or claims, may then choose:
Below 90%, or with fewer than 10 submissions, the agency returns to the two initial choices. Only fully affirmed decisions count toward a pre-claim review affirmation rate, and the MAC reports results within 30 days after each cycle ends.
If a claim that should carry a UTN is submitted without pre-claim review, the MAC stops it for prepayment review and sends an ADR with a 45-day response window. If the claim is found payable, it is subject to a 25% payment reduction that cannot be passed to the beneficiary and is not appealable.
The demonstration covers final home health claims (type of bill 329), replacement and adjustment bill types, and the visit-level HCPCS G-codes listed in the Operational Guide.
At a minimum, the Operational Guide calls for:
The medical record must support that the patient is:
Chapter 7 of the Medicare Benefit Policy Manual explains the underlying coverage criteria. When one request covers more than one period, a valid plan of care is required for each additional period. When 30-day periods are submitted separately, CMS directs agencies to include all documentation for the episode with each request. Agencies should also use the pre-claim review checklist on their MAC’s provider portal.
Agencies can submit through the MAC’s online portal, through esMD, by fax, or by mail. Responses return by the same method where available, and a fax response requires a return fax number. Palmetto GBA handles Jurisdiction M, and Wellpoint Federal handles California. In California, each request may include only one 30-day period because the multiple billing period option is not available.
A workable internal sequence looks like this: clinicians finalize the record, a quality reviewer checks the packet against the MAC checklist, the designated submitter sends the request, someone tracks the UTN and decision date, and billing applies the UTN to the claim. Naming one owner for each step prevents the gaps that cost agencies time.
A provisional affirmation is a preliminary finding that a future claim likely meets Medicare coverage, coding, and payment requirements. It is not a guarantee of payment. CMS notes that an affirmed claim can still be denied for technical requirements that can only be checked after the claim is processed, or because information was not available when the request was reviewed. Review contractors may audit affirmed claims when fraud or inappropriate utilization is suspected, and claims can be selected for the Comprehensive Error Rate Testing (CERT) sample. An affirmation also does not transfer if the beneficiary changes agencies.
The MAC’s decision letter lists the reasons for a non-affirmation. When documentation errors are the problem and the patient otherwise appears to meet coverage criteria, the MAC will call the agency to provide individualized education and encourage a prompt resubmission. A claim submitted with a non-affirmed UTN will be denied, and ordinary claim appeal rights then apply. RCD does not include a separate appeal for the non-affirmed pre-claim decision itself.
A rejected request is one the MAC could not process because of incomplete or invalid information. It is not reviewed for medical necessity and is not counted as a non-affirmation.
For a rejected request, fix the error, include all original documentation again, and mark the request as initial if it was initial. Ask your MAC how resubmissions are counted toward your cycle results so you can plan around the 90% threshold.
Rejection triggers listed by CMS: a request sent to the wrong MAC; a beneficiary enrolled in Medicare Advantage or Medicaid; an invalid or missing MBI or beneficiary name; invalid or missing PTAN, NPI, or type of bill; no clinical documentation attached; and a UTN already held by another agency for the same episode.
Documentation gaps worth checking before you submit (drawn from the coverage criteria above, not from a statistic):
Health care is a vital aspect of maintaining overall well-being, encompassing a range of services from preventive care
(502) 203-1347