For orthopedics, this is a revision where unit prices held but the surrounding fees for continuing patients were cut.
Musculoskeletal rehabilitation fees are unchanged — 185 points for (I), 170 for (II), 85 for (III). But the comprehensive rehabilitation plan evaluation fee now steps down for second and subsequent billings, and most continuing outpatient rehabilitation patients fall into that category.
1. What changed
| Item | Change | Old → New | Impact |
|---|---|---|---|
| Musculoskeletal rehabilitation fee (H002) | Base points unchanged | (I) 185 / (II) 170 / (III) 85 pts (unchanged, verify) | Low |
| Comprehensive rehabilitation plan evaluation fee (H003-2) step-down | Split into first and subsequent billings, with subsequent billings reduced (monthly) | Fee 1: 300 pts → first 300 / subsequent 240; Fee 2: 240 → first 240 / subsequent 196 (verify) | High |
| Early rehabilitation add-on restructured | Billing window shortened to day 14, with a large increase within the first three days | 25 pts (30 days) → days 1–3 60 pts, days 4–14 25 pts (verify) | Medium |
| Acute rehabilitation add-on | Continues as an evaluation for severe patients within 14 days of onset | 50 pts/unit (unchanged, verify) | Low |
| Reduction for rehabilitation without mobilization (new) | Bed-side passive training only (contracture prevention and similar) billed at 90/100, up to 2 units per day | 90/100 of standard points (new, verify) | Medium (inpatient) |
| Rehabilitation data submission add-on | Evaluates data submission (monthly) | 50 pts (verify) | Low |
| Analgesic procedures (J119) | No significant change identified (unchanged). Existing rules — only the principal therapy where multiple are performed on the same day — continue | Manual, device, and compress all 35 pts (unchanged) | Low |
2. What it means for the practice
(1) For outpatient-rehab-centred clinics, the plan fee step-down bites. Most continuing patients now fall into "subsequent billing at 240 points." At 200 patients a month, that is roughly 12,000 points — about 120,000 yen a month, 1.44 million yen a year. Reassess whether plan preparation and multidisciplinary conferences still justify the workload, and audit back to June that your billing system correctly flags first versus subsequent billings.
(2) On the inpatient side, the keywords are early and mobilizing. The large increase for days 1–3 (25 → 60 points) comes paired with the 90% reduction for rehabilitation without mobilization. Whether you can restructure to start rehabilitation the day of or the day after surgery — including weekend staffing — separates gain from loss.
(3) Physical-modality-dependent models were again not rewarded. Analgesic procedures stay at 35 points. Obtaining rehabilitation fee tiers (I) and (II) and shifting toward musculoskeletal rehabilitation remains the base strategy.
3. Practical checklist
- Can your billing system distinguish first from subsequent billings of the plan evaluation fee?
- Have you audited claims since June for correct application of the reduced rate?
- Have you quantified the loss from the step-down on continuing patients?
- (Inpatient) Is staffing arranged to start rehabilitation on days 1–3 post-op?
- (Inpatient) Have you identified patients subject to the non-mobilizing 90% reduction and reflected it in billing?
- Have you filed for the rehabilitation data submission add-on?
4. Where an AI-native EMR fits — feature by feature
In 2026 this specialty is paid according to which billing it is, when it started, and whether mobilization occurred. Here is how Pottech's AI-native EMR helps, feature by feature.
Feature 1: Billing and claims management — resolve first versus subsequent mechanically
The automatic billing engine checks bundling, mutual exclusions, and frequency limits.
The plan fee step-down can only be billed correctly if you can determine, per patient, whether this is the first or a subsequent billing. Doing that by hand across several hundred continuing patients is not realistic. Bill at the first-billing rate by mistake and the claim is rejected; bill a first visit at the reduced rate and you lose money. Billing counts held in the system are the precondition.
Feature 2: Charting and orders — record start date and mobilization
AI generates SOAP notes from the consultation audio, and set orders enter tests and prescriptions in one action.
In inpatient rehabilitation, which day of admission it started separates 60 points from 25, and whether mobilization occurred determines the 90% reduction. Neither can be proven if it is not in the implementation record. Standardizing therapist record formats is unit-price defense, directly.
Feature 3: Management analytics dashboard — see the effective unit price after step-down
Visit volumes, revenue per patient, and monthly trends are aggregated and visualized automatically.
The plan fee step-down is the kind of change that quietly erodes unit prices. When "rehab patients are up but revenue isn't," you cannot act unless you can separate step-down effects from utilization effects. Monthly visibility into the first-versus-subsequent mix is the starting point.
Also review what applies to every specialty
Consultation fees, the inflation add-on, the wage increase evaluation fee, and the electronic clinical information coordination add-on are collected in "what applies to every specialty."
Sources (principal)
- MHLW, "About the FY2026 Fee Schedule Revision" https://www.mhlw.go.jp/stf/newpage_67729.html
- Credo Medical, "FY2026: revisions to the comprehensive rehabilitation plan evaluation fee" https://www.credo-m.co.jp/column/detail/hosyu/25659/
- Knowlety, "Musculoskeletal rehabilitation fee (FY2026 fee table)" https://knowlety.jp/ika/h002/
- Knowlety, "Comprehensive rehabilitation plan evaluation fee (FY2026 fee table)" https://knowlety.jp/ika/h003-2/
- PT-OT-ST.NET, "FY2026 fee revision information" https://www.pt-ot-st.net/contents4/medical-treatment-reiwa-8/