New Federal Rule: Electronic Claims Attachments and What It Means for Us

 

Effective: May 26, 2026
Compliance Deadline: May 26, 2028


What’s Changing

The federal government has finalized a rule requiring standardized electronic submission of “claims attachments.” The clinical documentation that supports billing (nursing notes, doctor’s notes, therapy evals, daily notes, progress notes, discharge summaries, etc.).

  • Fax, mail, and manual uploads will be phased out
  • Documentation must be sent using standard electronic formats and transactions


Why This Matters to Us

This rule directly impacts how documentation supports claims and how quickly facilities get paid.

  • Documentation will be requested and transmitted electronically
  • Payers will review information faster and more consistently
  • Incomplete or delayed documentation will be more visible and more likely to be denied

 

To successfully comply with these changes, there are four key areas we need to focus on:

  1. Documentation Timeliness

  • Payers can request documentation electronically and expect a rapid response
  • Delays in documentation equal billing delays or denials

Focus Area:

Assure you are reviewing documentation timeliness expectations (i.e., documentation completed same day or within defined facility timelines).

 

  1. Documentation Quality

Standardized formats make it easier for payers to scrutinize documentation more closely:

    • Identify missing elements
    • Apply consistent audits

Focus Areas:

  • Medical necessity is clearly documented across the medical record (nursing notes, doctor’s notes, MDS, therapy notes)
  • Functional outcomes are consistently documented

 

  1. Electronic Signatures

  • All documentation must include secure, authenticated e-signatures

Focus Areas:

  • Timely signatures and co-signatures
  • No backlog of unsigned documentation

 

  1. Workflow Discipline

Manual “we’ll send it later” processes will no longer work.

Focus Areas:

  • Daily documentation expectations are set and understood by the IDT
  • Clear ownership for completion, corrections, and timeline
  • Rapid response to documentation requests – the team knows their piece of the puzzle and the timeframe in which it is expected to be done. Members of the team have a designated backup champion for when they are not at work.


Your Power Points

  1. Fax Is Going Away
  • By 2028, faxed documentation will not meet federal requirements
  • Facilities must support fully electronic workflows
  1. System Readiness Is Essential

Facilities must ensure their systems can:

  • Generate compliant documentation formats
  • Integrate with therapy and billing vendors
  • Support electronic attachment workflows
  1. Vendor Alignment Is Critical

This rule requires coordination between:

  • Therapy
  • Facility EMR
  • Billing partner
  • Clearinghouse

A gap in any area can delay claims.

  1. Faster Requests = Faster Expectations
  • Payers can request documentation electronically
  • Facilities must be ready to respond quickly

Delays in documentation completion can and will directly impact reimbursement.

 

Recommended Workflow Review Areas:

  • Delayed or incomplete documentation – Run audits to ensure documentation timeliness.
  • Unsigned or improperly signed notes – Assure a good process is in place so that documentation is signed as required.
  • Lack of system integration between vendors – Integration between therapy and nursing EMRs can assure more timely access to documentation. If you are already integrated, ensure your integration is operating as intended. If you are discussing integration, reach out to your Regional Director if you have any questions.
  • Inconsistent documentation practices across buildings – If you are a multi-site organization, ensure workflow consistencies across your buildings. This aligns expectations and creates an easier audit process.


How HTS is Supporting You

HTS is actively evaluating system readiness and integration requirements as both PCC and Matrix have or are currently undergoing integration modernization.

HTS maintains a dedicated integration lead who drives alignment between systems and rapidly identifies and resolves integration issues between the nursing EMR and therapy EMR.

HTS has already done the following:

  • Reinforced documentation timeliness expectations with teams
  • Audited for signature compliance
  • Provided routine standardized documentation quality assurances across buildings

 

Next Step for HTS Partner Facilities:

  • Engage your EMR, billing vendor, and clearinghouse on readiness
  • Assess current reliance on fax/manual processes
  • Partner with your HTS Regional Director to streamline workflows

 

This is not just a billing change, it is a documentation, workflow, and technology shift that will impact reimbursement speed, compliance, and audit risk. Organizations that prepare early will see faster payments and fewer denials.


Written By:

Sheena Mattingly, M.S., CCC-SLP, RAC-CT

Executive Vice President of Quality & Compliance

Healthcare Therapy Services, Inc.