
Freestanding inpatient rehab hospitals earned a 25.0% Medicare margin in fiscal 2024. Rehab units inside hospitals earned 4.1%. Medicare's advisory commission has recommended cutting payment rates two years running (MedPAC, March 2026).
Strong margins. Uncertain policy.
For owners of rehab real estate, the question is how much of that profit is durable.
What the Sector Looks Like
In fiscal 2024, fee-for-service Medicare and its beneficiaries spent $11.0 billion on about 435,000 stays in about 1,170 IRFs, and fee-for-service beneficiaries accounted for about 51% of all IRF stays. Fee-for-service stays grew about 8% from 2023, stays per beneficiary about 10%, and aggregate occupancy reached 71%, up from 69% (MedPAC, March 2026).
The growth is in freestanding hospitals. Their number rose from 302 in 2019 to 392 in 2024, while hospital-based units fell from 817 to 777, and freestanding IRFs handled 64% of fee-for-service stays in 2024. For-profit IRFs grew from 431 to 552 and handled 68% of stays (MedPAC, March 2026).
Jeff Axley, Managing Principal, Ridgeline Capital Partners, places IRFs with single-tenant net-lease development and has pointed out that "a lot of the development in healthcare is not in medical office buildings. It's like the post-acute, like IRFs and micro hospitals and ASCs."
Are freestanding rehab hospitals more profitable than hospital units?
MedPAC puts the IRF fee-for-service Medicare margin at 17.1% in fiscal 2024, up from 14.8% in 2023, and projects about 18% for fiscal 2026. The average hides the split: 25.0% for freestanding IRFs and 4.1% for hospital-based units (MedPAC, March 2026).
Across all payers, freestanding IRFs earned a total margin of about 12% in fiscal 2024. For-profit freestanding facilities earned about 14%, and nonprofit freestanding facilities about 4% (MedPAC, March 2026).
For a landlord, operator margin is the cushion behind rent coverage.
CMS Versus MedPAC
CMS's FY 2027 final rule, effective October 1, 2026, raises IRF payments 2.3%: a 3.2% market basket increase less 0.9 points for productivity, worth an estimated $340 million (CMS, July 2026). The standard conversion factor rises from $19,371 to $19,868 (HFMA, August 2026). The rule requires therapy to begin within 36 hours of admission and the first interdisciplinary team meeting by day four.
MedPAC voted 17-0 to recommend that Congress cut the IRF base payment rate by 7% for FY 2027, the same recommendation it made for FY 2026 (MedPAC, March 2026). The American Hospital Association urged current-law updates instead (AHA, January 2026).
Oversight is rising. Texas joined Medicare's IRF Review Choice Demonstration in March 2026, covering 24 Encompass Health hospitals in the state. Alabama, Pennsylvania and California are the other states in the demonstration (Encompass Health, August 2026).
Where are inpatient rehab operators building new hospitals?
Stroke and orthopedic recovery drive IRF volume. More than 795,000 people in the U.S. have a stroke each year (CDC, October 2024). Stroke makes up 13% of stays at freestanding for-profit IRFs and 20% at hospital-based nonprofit units, and lower-extremity fractures 12% to 16% (MedPAC, March 2026). Vizient projects that post-acute care volume will grow 31% from 2026 to 2036 (Vizient projection, via AHA, August 2026).
State law decides where operators build. Texas has no certificate-of-need (CON) requirement (CBRE, June 2026). Florida ended CON review for specialty hospitals, including rehabilitation hospitals, on July 1, 2021 (Arnall Golden Gregory, June 2021). Georgia still requires a CON for comprehensive inpatient rehabilitation, and its October 2025 review cycle opened one projected adult bed, in Planning Area 2 (Georgia Department of Community Health, October 2025).
Encompass Health ran 176 IRFs in 39 states and Puerto Rico at mid-2026, with 18 projects under development, and has announced 50-bed hospitals in San Antonio, in Haslet in the Dallas-Fort Worth area, and in Wesley Chapel and Apollo Beach near Tampa (Encompass Health, August 2026). Its 40-bed Loganville, Georgia hospital opened in June 2026 (Encompass Health, June 2026). The company guides to 6 to 10 new hospitals a year (company projection).
The Risk
The biggest risk in IRF real estate is a payment cut. MedPAC has recommended a 7% cut to the base rate two years running, against the 2.3% increase CMS finalized for FY 2027, a 9.3-point gap between the regulator and its adviser (Ridgeline calculation). If Congress adopts the recommendation, operator margins fall and rent coverage falls with them.
A single-tenant building has one source of rent. An operator that loses margin to a payment cut, or to claims review under the Review Choice Demonstration, puts the building's entire cash flow at risk.
MARKET SIGNALS
The freestanding margin gap. Freestanding IRFs earned a 25.0% Medicare margin in fiscal 2024, against 4.1% for hospital-based units (MedPAC, March 2026).
Regulator versus adviser. CMS finalized a 2.3% payment increase for FY 2027, while MedPAC recommended a 7% cut (CMS, July 2026; MedPAC, March 2026).
Freestanding supply is growing. Freestanding IRFs rose from 302 in 2019 to 392 in 2024, while hospital-based units fell from 817 to 777 (MedPAC, March 2026).
WHAT WE'RE WATCHING
North Carolina repealed certificate-of-need review for inpatient rehabilitation effective October 1, 2026, and Encompass Health has identified 15 priority markets in the state.
Frequently Asked Questions
How big is the inpatient rehabilitation facility (IRF) market?
In fiscal 2024, fee-for-service Medicare and its beneficiaries spent $11.0 billion on about 435,000 stays in about 1,170 inpatient rehabilitation facilities (IRFs) (MedPAC, March 2026). Fee-for-service beneficiaries accounted for about 51% of all IRF stays, and aggregate occupancy reached 71%, up from 69% (MedPAC, March 2026).
How much is Medicare raising inpatient rehab payments for FY 2027?
The Centers for Medicare & Medicaid Services (CMS) FY 2027 final rule raises IRF payments 2.3%, effective October 1, 2026: a 3.2% market basket increase less 0.9 points for productivity, worth an estimated $340 million (CMS, July 2026). The standard conversion factor rises from $19,371 to $19,868 (HFMA, August 2026).
What did MedPAC recommend for inpatient rehab payment rates?
The Medicare Payment Advisory Commission (MedPAC) voted 17-0 to recommend that Congress cut the IRF base payment rate by 7% for FY 2027, the same recommendation it made for FY 2026 (MedPAC, March 2026). That is a 9.3-point gap from the 2.3% increase CMS finalized (Ridgeline calculation). If Congress adopts it, operator margins and rent coverage fall.
Do Texas, Florida and Georgia require a certificate of need for rehab hospitals?
Texas and Florida do not, and Georgia does. Texas has no certificate-of-need (CON) requirement (CBRE, June 2026). Florida ended CON review for specialty hospitals, including rehabilitation hospitals, on July 1, 2021 (Arnall Golden Gregory, June 2021). Georgia still requires a CON for comprehensive inpatient rehabilitation (Georgia Department of Community Health, October 2025).
Related reading
Inpatient rehab earns strong margins today, but Medicare sets the price. We underwrite the real estate on the assumption that payment rates can fall, not on the margins operators earn this year.
Feel free to reach me if you have any questions.
Best,
Jeff Axley
Managing Principal
Ridgeline Capital Partners, LLC
(214)236-2734
3860 W. Northwest Hwy, Suite 340, Dallas, TX 75220
Sources
MedPAC, "March 2026 Report to the Congress, Ch. 9: Inpatient rehabilitation facility services," 2026-03-12. https://www.medpac.gov/wp-content/uploads/2026/03/Mar26_Ch9_MedPAC_Report_To_Congress_SEC.pdf
CMS, "FY 2027 Inpatient Rehabilitation Facilities (IRF) Prospective Payment System (PPS) Final Rule (CMS-1845-F)," fact sheet, 2026-07-30. https://www.cms.gov/newsroom/fact-sheets/fy-2027-inpatient-rehabilitation-facilities-irf-prospective-payment-system-pps-final-rule-cms-1845-f
HFMA, "FY 2027 Inpatient Rehabilitation Facility PPS Final Rule Summary," August 2026. https://www.hfma.org/payment-reimbursement-and-managed-care/fy-2027-inpatient-rehabilitation-facility-pps-final-rule-summary/
AHA, "AHA Comments on MedPAC Payment Update Recommendations," 2026-01-09. https://www.aha.org/lettercomment/2026-01-09-aha-comments-medpac-payment-update-recommendations
CDC, "Stroke Facts," last updated 2024-10-24. https://www.cdc.gov/stroke/data-research/facts-stats/index.html
AHA Center for Health Innovation, "6 Key Projections: How Healthcare Demand Will Shift Over the Next 10 Years," 2026-08-04. https://www.aha.org/aha-center-health-innovation-market-scan/2026-08-04-6-key-projections-how-healthcare-demand-will-shift-over-next-10-years
CBRE, "Sun Belt Population Growth Drives Demand for Outpatient Healthcare Real Estate," 2026-06-29. https://www.cbre.com/insights/briefs/sun-belt-population-growth-drives-demand-for-outpatient-healthcare-real-estate
Arnall Golden Gregory, "No Need for Certificate of Need: Florida Eliminates Certificate of Need Review for Specialty Hospitals," 2021-06-22. https://agg.com/news-insights/publications/no-need-for-certificate-of-need-florida-eliminates-certificate-of-need-review-for-specialty-hospitals
Georgia Department of Community Health, "Certificate of Need Batching Review Cycle Notification for Comprehensive Inpatient Physical Rehabilitation Services," 2025-10-01. https://dch.georgia.gov/document/document/inpatientrehabbatchingnoticeoct12025/download
Encompass Health, "Q2 2026 Earnings Slides," 2026-08-05. https://s203.q4cdn.com/714480614/files/doc_financials/2026/q2/EHC-Q2-2026-Earnings-Slides_FINAL.pdf
Encompass Health, Q2 2026 earnings release (8-K Ex. 99.1), 2026-08-05. https://www.sec.gov/Archives/edgar/data/0000785161/000078516126000183/ehcearningsrelease63026.htm
Encompass Health, "Eastside Rehabilitation Hospital now open in Georgia," 2026-06-09. https://s203.q4cdn.com/714480614/files/doc_news/Eastside-Rehabilitation-Hospital-now-open-in-Georgia-2026.pdf
MarketBeat, "Encompass Health Q2 Earnings Call Highlights," 2026-08-08. https://www.marketbeat.com/instant-alerts/encompass-health-q2-earnings-call-highlights-2026-08-08/
For informational purposes only. Not an offer to sell or a solicitation of an offer to buy any security; any offer is made only through confidential offering documents. Projections are not guarantees of future results.

