Inpatient rehab facility marketing: claims guide

An inpatient rehabilitation facility, or IRF, is a hospital or a hospital unit built around intensive therapy after a stroke, a brain or spinal cord injury, an amputation, a major joint or cardiac surgery, or another serious illness. Patients do not shop for it the way they shop for a dentist. The decision is made in a few days, in a hospital room, by a patient and a family who have just been told that the hospital stay is ending, with a case manager, a physician and a therapist in the conversation. Marketing for an IRF works when it gives each of those people accurate information fast, and it fails when it promises an admission, an outcome or a coverage decision that nobody at the facility can promise.

Two related topics have their own guides and are not repeated here. Skilled nursing facilities, their admission promises and their Care Compare star ratings are covered in our nursing home marketing guide. Follow up by a physician practice after a patient goes home, including the timing rules for that service, is in our transitional care management outreach guide. This guide covers what is specific to an IRF: the Medicare criteria that decide who can be admitted, how to compare acute rehabilitation with other settings without overstating the difference, quality data on Care Compare, hospital referral sources and patient stories.

This is general information, not legal or medical advice. Whether a patient needs and qualifies for inpatient rehabilitation is decided by clinicians, the payer and the facility’s own screening, and scope of practice for non-physician practitioners is set state by state. Sources cited were checked on October 30, 2026: the Medicare Benefit Policy Manual, chapter 1, section 110 (Rev. 10892, issued August 6, 2021), 42 CFR 412.622 and 412.29, 42 CFR 482.43, the Medicare.gov page on inpatient rehabilitation care, the CMS IRF Quality Reporting Program page (last modified March 10, 2026) and IRF Quality Public Reporting page (last modified September 28, 2026), Medicare Care Compare, 15 U.S.C. 45 and 52, the FTC Health Products Compliance Guidance (December 2022), 42 U.S.C. 1320a-7b(b), 16 CFR 255.2 and 255.5, and 45 CFR 164.508. Have a health care attorney review your marketing before it runs.

Start with how Medicare describes inpatient rehabilitation

Patients and families who search for inpatient rehab after a hospital stay will find the Medicare.gov page on inpatient rehabilitation care. It says inpatient rehabilitation “can help if you’re recovering from a serious surgery, illness, or injury and need an intensive rehabilitation therapy program, physician supervision, and coordinated care from your doctors and other health care providers (including therapists).” It says Medicare Part A covers medically necessary care in an inpatient rehabilitation facility or unit, and Part B covers doctors’ services during the stay.

The same page lists what the covered stay includes:

Rehabilitation services, including physical therapy, occupational therapy and speech-language pathology.
A semi-private room, meals and nursing services.
Prescription drugs and other hospital services and supplies.

It also lists what Medicare does not cover, including private duty nursing, a private room unless medically necessary, and personal items. On eligibility, it says the patient’s health care provider “must certify that you have a medical condition requiring intensive rehabilitation, continued medical supervision, and coordinated care from your providers.” Costs are set out for each benefit period by day ranges, with a deductible, daily coinsurance from day 61 and lifetime reserve days after day 90, and the page explains when a patient transferred from an acute care hospital does not pay a second deductible.

Your pages should use the same words and point to the same source. Write “Medicare Part A covers medically necessary inpatient rehabilitation for eligible patients” and link the Medicare.gov page, rather than “Medicare pays for your stay” or “no cost to you”. A patient with a Medicare Advantage plan, a commercial plan or Medicaid has different rules, so a coverage line should invite the family to ask your admissions team to check their plan before admission.

Admission criteria are a screening decision, not an offer

Section 110 of chapter 1 of the Medicare Benefit Policy Manual sets out when CMS considers IRF care reasonable and necessary. It says the IRF benefit “is designed to provide intensive rehabilitation therapy in a resource intensive inpatient hospital environment for patients who, due to the complexity of their nursing, medical management, and rehabilitation needs, require and can reasonably be expected to benefit from an inpatient stay and an interdisciplinary team approach to the delivery of rehabilitation care.” Section 110.2 lists the criteria the medical record has to support at the time of admission:

The patient requires active and ongoing therapy from multiple disciplines, one of which is physical or occupational therapy.
The patient generally requires an intensive rehabilitation therapy program, as defined in section 110.2.2.
The patient can reasonably be expected to actively participate in, and benefit significantly from, that program, with measurable improvement of practical value within a prescribed period of time.
The patient requires supervision by a rehabilitation physician, with face-to-face visits at least 3 days per week.
The patient requires an intensive and coordinated interdisciplinary approach to rehabilitation.

The manual also says the decision has to rest on “an assessment of each beneficiary’s individual care needs”, and section 110.1.1 describes a preadmission screening by licensed or certified clinicians within the 48 hours before admission. It adds that a patient who has not completed the full course of treatment in the referring hospital is expected to stay there until they can take part in the program, and that the IRF benefit is not appropriate for a patient who has finished hospital treatment but does not require intensive rehabilitation.

For marketing, that rules out admission promises. “We accept every stroke patient”, “admission within 24 hours, no matter what” and “skip the nursing home and come straight to us” all describe a decision that belongs to the screening and the record, not to the ad. What you can say is how the process works: who does the preadmission screening, how a hospital or family starts a referral, how fast your team responds to a referral during and after business hours if you have a written standard for it, and what happens when a patient does not meet the criteria. A page that explains a “not yet” or a “not here” in plain words, and names the other settings Medicare describes, protects the facility and helps the family.

The 13 conditions listed in 42 CFR 412.29(b)(2) are a facility classification rule, and the manual says the medical necessity criteria apply whether or not the patient is treated for one of those conditions. Do not present that list on a website as a list of patients who qualify.

Acute rehab versus a nursing home: comparison claims

Families are told that the choice is between “acute rehab” and a skilled nursing facility, and they search for that comparison. It is a fair topic, and an IRF can explain it, but a comparison is a claim. Under 15 U.S.C. 45 and 52, health claims in advertising have to be truthful and not misleading, and the FTC Health Products Compliance Guidance says the advertiser needs competent and reliable scientific evidence for each reasonable interpretation of the claim, including claims made by implication.

There is a sourced way to describe the difference. The manual itself describes what sets the IRF setting apart: the interdisciplinary approach, the intensity of therapy, and close physician involvement, each introduced in sections 110.2.1, 110.2.2 and 110.2.4 as “a primary distinction between the IRF environment and other rehabilitation settings.” On intensity, it says the program “generally consists of at least 3 hours of therapy per day at least 5 days per week”, that it can instead be shown by at least 15 hours within a 7 consecutive day period in well-documented cases, and that CMS does not intend the measure to be used as a “rule of thumb”. It also says the intensity “must never exceed the patient’s level of need or tolerance, or compromise the patient’s safety.”

So an IRF can write, with the source linked, that Medicare criteria for inpatient rehabilitation call for an intensive program generally described as at least 3 hours of therapy a day, 5 days a week, with rehabilitation physician visits at least 3 days a week. It cannot turn that into “3 hours of therapy every day, no exceptions”, and it cannot turn the structure into an outcome. These claims need their own evidence before they run:

“Patients recover faster here than in a nursing home.”
“Go home sooner” or “walk out on your own”.
“Better outcomes than skilled nursing” or “the best rehab in [City]”.
“Lower readmissions” or any comparison with a named facility type.

A published study comparing settings does not by itself support a claim about your facility; the FTC guidance looks at whether the evidence matches the claim, the population and the setting. If you cannot support an outcome comparison, describe the program and let the family compare it with what they hear from other providers.

Care Compare and your quality data

The CMS IRF Quality Reporting Program page says the program creates quality reporting requirements mandated by section 3004(b) of the Affordable Care Act, and that “CMS must make quality data available to the public through the compare tool on Medicare.gov.” The IRF Quality Public Reporting page lists the measures used, such as the discharge self-care and mobility scores, discharge to community, potentially preventable readmissions, pressure ulcers and falls with major injury, and explains that an IRF can preview its results for 30 days before public display and request a CMS review during that window.

The hospital rule gives that data a role in the referral. Under 42 CFR 482.43(c)(8), a hospital must assist patients, families or representatives in selecting a post-acute care provider “by using and sharing data that includes, but is not limited to, HHA, SNF, IRF, or LTCH data on quality measures and data on resource use measures”, relevant to the patient’s goals of care and treatment preferences. Your Care Compare profile is in that conversation whether you mention it or not.

How to use quality data in marketing:

Quote a measure by its CMS name, give the value as Care Compare shows it, and state the reporting period and the date you checked it.
Link the Care Compare listing so a case manager or family can check it.
Update or remove the figure when Care Compare refreshes.
Do not pick one favorable measure and present it as overall quality, and do not write “top rated” or “the best” without a source that says so.
Do not compare your figure with a named competitor’s unless the comparison is complete and current.

Measures that come from your own records, such as a figure from a registry or an internal outcomes report, are claims too. Before one appears in an ad, counsel should confirm what it measures, which patients it includes, and whether a reasonable reader would take it to mean more than it does.

After discharge, a patient may continue care with a physiatrist in an outpatient practice. Our guide to physiatry practice marketing covers outpatient pages, non-surgical claims and referral partners.

Hospital case managers, physicians and liaisons

Referrals to an IRF come through hospital case managers, discharge planners, hospitalists, surgeons and therapists. 42 CFR 482.43(d) requires the hospital to include in the discharge plan a list of Medicare-participating IRFs available to the patient in the geographic area the patient requests, to inform the patient of their “freedom to choose among participating Medicare providers and suppliers of post-discharge services”, and to respect the patient’s goals of care and preferences when possible. The rule also says the hospital “must not specify or otherwise limit the qualified providers or suppliers that are available to the patient.” Our nursing home marketing guide covers how that rule shapes outreach to discharge planners.

For an IRF, the practical result is that outreach should help the hospital team give the patient a real choice. A clinical liaison can explain your program, your admission process and the conditions your team treats, and can carry back what the hospital needs. A liaison should not ask a case manager to steer patients, and nothing of value should be tied to referrals. The federal anti-kickback statute, 42 U.S.C. 1320a-7b(b), reaches anyone who knowingly and willfully offers or pays remuneration to induce referrals of items or services payable by a federal health care program. Meals, gifts, paid speaking roles and marketing payments to referral sources raise that statute, and our guide to patient and physician referrals covers it and its safe harbors in more detail.

Physician relationships, such as a medical director role, need the same review, because they involve payment to a person who can refer. That review belongs to counsel, before the arrangement and before any marketing names the physician.

What families need on your website

A family comparing options under time pressure needs the same few answers from every facility. A useful IRF website puts them on one page that a case manager can send by text:

What inpatient rehabilitation is, in the words of the Medicare.gov page, with the link.
How a referral starts, who to call, and the hours your admissions team answers.
The disciplines on your team and what a day looks like, described as the program, not a promise.
How physician visits, team conferences and family training work, and when families can visit.
What Medicare covers and what it does not, linked, plus a line to ask about other plans.
What happens at discharge, including how your team works with home health, outpatient therapy and the patient’s own physician.

Write for a reader who is tired and worried. Short sentences, plain words, no medical abbreviations without an explanation, and a phone number that a person answers. Forms that ask about a diagnosis or a hospital stay collect health information, so they should not sit behind tracking tools that send data to an advertising platform.

Do not offer families anything of value to choose your facility. Our guide to marketing to Medicare patients explains the beneficiary inducement rules.

Patient stories, videos and graduation days

Rehab facilities have moving material: a patient’s first steps after a stroke, a family at a discharge celebration, a therapist’s account of a hard case. Each of those needs care before it is published.

Under 45 CFR 164.508, a HIPAA covered entity needs a valid written authorization before it uses protected health information for marketing, and a photo or video of a patient in therapy is health information. Under 16 CFR 255.2, an endorsement that conveys a result implies the result is representative, so a story about an unusual recovery needs clear disclosure of what patients can generally expect, which you need evidence to state. If a patient received anything of value for the story, including a waived charge or a gift, 16 CFR 255.5 requires that connection to be disclosed. Our guide to patient testimonials and before and after photos covers these rules in more depth.

A story can still be honest and useful. Tell what the program involved, what the patient worked on, and what they said in their own words, with the authorization on file, and avoid presenting one recovery as what the facility delivers.

Illustration: two ways to advertise an inpatient rehab facility

Illustration: an ad reads “Recover faster than in a nursing home. 3 hours of therapy every day, no exceptions. Medicare pays for your stay. Call now and we will get you admitted tomorrow.” Each sentence is a problem: an outcome comparison without evidence, a therapy promise that the manual says depends on the patient’s need and tolerance, a coverage promise, and an admission promise that bypasses the preadmission screening.

Illustration: the rewrite reads “[Facility name] is an inpatient rehabilitation hospital for adults recovering from serious illness, injury or surgery. Our program brings physical, occupational and speech therapy together with nursing care and rehabilitation physician supervision. Medicare Part A covers medically necessary inpatient rehabilitation for eligible patients; ask us to check your plan. Our admissions team reviews each referral to see if inpatient rehab is the right setting. Call [phone] or ask your hospital case manager.” It describes the program, links coverage to eligibility, and leaves the decision where it belongs.

Checklist before an inpatient rehab campaign goes live

Coverage wording matches the Medicare.gov page and links it, with a line about other plans.
No promise of admission, admission timing or a set amount of therapy.
Intensity described as Medicare criteria, with the manual linked, not as a promise.
No outcome or comparison claim without evidence that matches the claim and the setting.
Care Compare figures quoted by measure name, period and date checked, with the listing linked.
No superlatives without a source.
Liaison materials reviewed; nothing of value tied to referrals.
Written authorization on file for every patient photo, video and story, and material connections disclosed.
Intake forms kept away from advertising tracking tools.
Counsel review done and dated.

How we help

We build websites, local search, Google Ads and AI front desk tools for independent practices and health businesses. For an inpatient rehabilitation facility, that means program and admissions pages that use Medicare’s own words, search content written around the questions families and case managers ask, and referral and inquiry forms that keep health information away from tracking tools. We do not decide admission, medical necessity or whether a claim is substantiated; your clinicians and counsel do. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. We do not sell lead lists and we do not pay for referrals. For the wider rules, see our healthcare marketing rules hub.

Can we say patients get 3 hours of therapy a day?

You can say that Medicare criteria for inpatient rehabilitation describe an intensive program generally consisting of at least 3 hours of therapy per day at least 5 days per week, and link the Medicare Benefit Policy Manual. Do not promise it, because the manual says intensity must never exceed the patient’s need or tolerance.

Can we say we are better than a nursing home?

Only with competent and reliable evidence that supports that comparison for your patients and setting, under 15 U.S.C. 45 and 52 and the FTC Health Products Compliance Guidance. Describing what the IRF program involves is safer and still useful.

Can we tell families Medicare will cover the stay?

Not as a promise. Medicare.gov says Part A covers medically necessary inpatient rehabilitation for eligible patients whose provider certifies the need, and lists deductibles and coinsurance by benefit period. Coverage depends on the patient and the plan.

Can we use our Care Compare results in ads?

Yes, if you quote the measure by its CMS name, give the value and the reporting period as Care Compare shows them, date the figure, link the listing, and do not present one measure as overall quality.

Can our liaison take case managers to lunch?

Anything of value given to a referral source raises the federal anti-kickback statute, 42 U.S.C. 1320a-7b(b). Have counsel review any meal, gift or payment before it happens.

Can we post a video of a patient’s first steps?

With written authorization under 45 CFR 164.508 if you are a HIPAA covered entity, a disclosure of generally expected results under 16 CFR 255.2, and disclosure of anything of value the patient received under 16 CFR 255.5.

Sources

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Inpatient rehabilitation facility marketing: admission criteria, comparison claims and referral sources