A Medicare rehabilitation agency is one of three types of organization CMS recognizes as a provider of outpatient physical therapy and speech-language pathology (OPT/OSP) services, certified under the conditions of participation in 42 CFR Part 485, Subpart H. This page is for physical therapy and speech-language rehabilitation organizations choosing and implementing that federal pathway. Integral Healthcare Solutions (IHS) drafts your rehabilitation agency's procedures and survey evidence; your licensed therapists approve the clinical content.

Last reviewed: October 2026.

What is a Medicare rehabilitation agency?

CMS's Outpatient Rehabilitation Providers page states: “There are three types of organizations that may qualify as OPT/OSP providers”: a rehabilitation agency, a clinic and a public health agency. The governing text for all three is 42 CFR Part 485, Subpart H, “Conditions of Participation for Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services” (§§ 485.701 to 485.729), read as current in the eCFR on September 30, 2026. CMS names State Operations Manual Appendix E as the surveyor guidance.

Under 42 CFR 485.703, a rehabilitation agency is an agency that “(1) Provides an integrated interdisciplinary rehabilitation program designed to upgrade the physical functioning of handicapped disabled individuals by bringing specialized rehabilitation staff together to perform as a team; and (2) Provides at least physical therapy or speech-language pathology services.”

Not every condition applies to every provider type. CMS's page states: “42 CFR 485.709, Administrative Management, is not applicable to public health agencies, and 42 CFR 485.717, Rehabilitation Program, is not applicable to clinics or public health agencies.” A rehabilitation agency is subject to both.

Two other provisions shape daily operations:

• Plan of care. “For each patient there is a written plan of care established by the physician or by the physical therapist or speech-language pathologist who furnishes the services” (42 CFR 485.711(b)(1)).
• Program evaluation. “A sample of active and closed clinical records is reviewed quarterly by the appropriate health professionals to ensure that established policies are followed in providing services” (485.729(a)), and “An evaluation is conducted annually of statistical data such as number of different patients treated, number of patient visits, condition on admission and discharge, ...” (485.729(b)).

Who needs it and what triggers it

The pathway applies to an organization that wants to furnish outpatient physical therapy or speech-language pathology to Medicare patients as a certified provider. The usual triggers are:

• Selecting the provider category. The organization has to decide, with counsel, whether it is a rehabilitation agency, a clinic, a public health agency or a different category altogether, because the conditions that apply differ by type.
• Preparing for the initial State survey. CMS's page states: “During the course of the State survey, it verifies that the services that the provider proposes to offer are actually being provided.” In IHS's reading (October 2026), that means the services, records and plans of care need to be in operation before the survey.
• Adding an extension location. Under 42 CFR 485.703, “The extension location is part of the rehabilitation agency.” CMS Transmittal 11574 addresses adding an extension site through a Form CMS-855A change of information filing.
• Program evaluation gaps, such as missing quarterly record reviews or annual statistical evaluations required by 485.729.

How IHS helps

IHS starts by having you confirm your provider category with counsel, then works from the conditions to your evidence. The process:

1. A gap assessment against 42 CFR Part 485, Subpart H, with questionnaires on services, referrals and supervision.
2. Document and evidence mapping: a crosswalk from each condition to the policy or record that shows it is met, assembled into an evidence index.
3. Drafting operating procedures and the clinical policies, for your therapists to review and approve.
4. A mock survey against the conditions that apply to your provider type.
5. Readiness support, including drafted correspondence for your organization to review and send. IHS drafts; your organization submits.

Your organization supplies its service list, therapist credentials, sample records, current policies, and therapist approval of clinical content.

The limit: the choice between a rehabilitation agency and a comprehensive outpatient rehabilitation facility (CORF) stays with you and your counsel. Physical-plant items need your facilities staff. For accreditation work, see accreditation consulting; other compliance services are listed under compliance services.

What to have ready

Each item ties to 42 CFR Part 485, Subpart H (eCFR, current as of September 30, 2026), CMS's Outpatient Rehabilitation Providers page (last modified August 17, 2026) or CMS Transmittal 11574 (August 25, 2022).

• Your counsel's conclusion on provider type: rehabilitation agency, clinic or public health agency (CMS page; 485.703).
• Your service list, showing at least physical therapy or speech-language pathology (485.703).
• A description of how your interdisciplinary team works together as a rehabilitation program (485.703; 485.717 for rehabilitation agencies).
• Administrative management documents (485.709, which applies unless you are a public health agency).
• Evidence that the services you propose are already being provided, since the State survey verifies this (CMS page).
• Sample patient records with a written plan of care established by the physician or the treating physical therapist or speech-language pathologist (485.711(b)(1)).
• Your procedure and records for quarterly review of active and closed clinical records (485.729(a)).
• Your annual evaluation of statistical data, such as patients treated, visits, and condition on admission and discharge (485.729(b)).
• A list of extension locations and the related CMS-855A filings (485.703; Transmittal 11574).
• Your application fee or a hardship exception request for the initial enrollment (42 CFR 424.514(a); see the cost section).

Bring what you have to the introductory call; IHS uses it to scope the gap assessment.

How it compares

The categories differ in what they must provide. The table summarizes the federal text quoted on this page; it does not rank them.

Which category fits depends on your services, your physicians' role and your locations. That decision belongs to your organization and its counsel.

What it costs

CMS publishes no certification fee specific to OPT/OSP providers on the pages we reviewed; we found none on the Outpatient Rehabilitation Providers page or in Subpart H. The published federal fee is the provider enrollment application fee. The Federal Register notice of December 3, 2025 (2025-21877) announces “a $750.00 calendar year (CY) 2026 application fee for institutional providers that are initially enrolling in the Medicare or Medicaid program or the Children's Health Insurance Program (CHIP); revalidating their Medicare, Medicaid, or CHIP enrollment; or adding a new Medicare practice location.” The notice defines an institutional provider to include any provider or supplier that submits a CMS-855A, and CMS Transmittal 11574 gives “Processing Instructions for OPT/OSP Initial Form CMS-855A Applications.” Under 42 CFR 424.514(a), an institutional provider submitting an initial application must submit the application fee, a hardship exception request, or both. IHS's reading (October 2026): an initial OPT/OSP enrollment pays the CY 2026 fee unless a hardship exception is granted. Verify current fees with CMS. IHS scopes each engagement after a free introductory call.

What this is not

• It is not legal advice. The provider-category decision and enrollment questions go to your counsel.
• It is not a guarantee of certification or of any survey result.
• It is not clinical care design. IHS does not submit anything to CMS or the State survey agency on your behalf; IHS drafts and your organization submits.

Frequently asked questions

What is a Medicare rehabilitation agency for outpatient physical therapy and speech-language pathology?

Under 42 CFR 485.703, a rehabilitation agency provides an integrated interdisciplinary rehabilitation program that brings specialized rehabilitation staff together to perform as a team, and provides at least physical therapy or speech-language pathology services. It is certified under the conditions of participation in 42 CFR Part 485, Subpart H.

What is the difference between a rehabilitation agency, a clinic and a public health agency as OPT/OSP providers?

CMS lists these as the three types of organizations that may qualify as OPT/OSP providers. A clinic requires a group of three or more physicians practicing medicine together. CMS states that the Administrative Management condition at 485.709 does not apply to public health agencies, and the Rehabilitation Program condition at 485.717 does not apply to clinics or public health agencies.

Rehabilitation agency versus CORF versus private practice therapist: which should we choose?

That choice belongs to your organization and its counsel. A CORF under 42 CFR Part 485, Subpart B must provide, at a minimum, physicians' services, physical therapy and social or psychological services at a single fixed location, while a rehabilitation agency must provide at least physical therapy or speech-language pathology. This page does not cover enrollment as a therapist in private practice.

Who can establish the plan of care in a rehabilitation agency?

Under 42 CFR 485.711(b)(1), each patient has a written plan of care established by the physician or by the physical therapist or speech-language pathologist who furnishes the services. Your clinical records should show who established each plan.

What is an extension location and does it need its own certification?

Under 42 CFR 485.703, the extension location is part of the rehabilitation agency. CMS Transmittal 11574 addresses adding an extension site through a Form CMS-855A change of information filing. Confirm the current filing steps with your counsel before opening a site.

What does the State survey check for a new rehabilitation agency?

CMS states that during the course of the State survey, it verifies that the services the provider proposes to offer are actually being provided. CMS names State Operations Manual Appendix E as the surveyor guidance for these providers.

What program evaluation does Subpart H require?

Under 42 CFR 485.729(a), a sample of active and closed clinical records is reviewed quarterly by the appropriate health professionals to ensure that established policies are followed. Under 485.729(b), an evaluation is conducted annually of statistical data such as the number of different patients treated, the number of visits, and condition on admission and discharge.

Does a rehabilitation agency need occupational therapy?

The definition in 42 CFR 485.703 requires at least physical therapy or speech-language pathology services and does not name occupational therapy among them. Read the full text of Subpart H for any other service requirements that apply to your organization.

How long does initial certification take?

CMS does not publish a processing timeline on the pages we reviewed. Because the State survey verifies that proposed services are already being provided, plan for the program to be operating before the survey.