Switching home health EHRs without breaking billing (2026)

• One system bills each 30-day period. Decide for every open period which system sends the final claim.
• The Notice of Admission (NOA) is due within 5 calendar days of the start of care. File it late and that period's payment drops by 1/30th for each day from the start of care until it is filed [2].
• For assessments with target dates on or after April 1, 2026, OASIS can no longer be keyed into the legacy iQIES screen; it must be uploaded in the correct format [3].
• Keep clinical records for five years after discharge, longer if your state says so [1].

How do we switch mid-contract?

• Notice period. How far ahead you must tell the vendor you're leaving. Miss it and the contract may renew for another term.
• Auto-renewal. Whether the contract renews on its own, and for how long.
• Early exit. Any fee for leaving before the term ends, and whether it shrinks as the term runs down.
• Data return. The format and timing of your data when you leave, and what keeping read access costs.

• Start with one product. Some vendors run one piece, such as intake or an AI scribe, alongside the EHR you have. Enzo's EHR page says: "If you can't leave your current EHR yet, see what Enzo can do in one part of your agency," then "make the full move when you're ready" [4].
• Start the move early. Sign now and set go-live for when your contract ends. At Enzo, patient records, episode history and clinical data move from your prior EHR before go-live [4]. Ask any vendor when billing for the new system starts, so you are not paying two vendors for months.

What has to be ready before cutover day?

1. Claims connection. The new system's clearinghouse set up, and your agency enrolled to send claims to your Medicare contractor through it. Enrollment has lead time; ask both vendors how long.
2. Every other payer. Medicaid, Medicare Advantage and commercial plans, each with its own submitter setup and portal logins.
3. Authorizations. Open Medicare Advantage and Medicaid authorizations carried into the new system, so no visit goes out without one.
4. OASIS submission. A real assessment sent from the new system and accepted [3].
5. Your receivables. Who posts payments and works denials for claims sent from the old system, and for how long.

When should we switch?

1. Open periods. List every patient with a 30-day period open on cutover day. Decide, patient by patient, which system sends that period's final claim.
2. New admissions. From cutover day, admit in the new system only. The NOA clock starts at the start of care [2]. The NOA is filed once per admission, so ask your Medicare contractor to confirm that patients already admitted need nothing new at cutover.
3. Assessments due that week. Any start of care, recertification or discharge OASIS due that week goes from the new system [3].

What do we keep from the old system?

• Clinical records, for five years after discharge [1], for record requests and audits long after you stop charting there.
• Billing history. Claims, remittances and denials for periods billed in the old system.
• A readable copy, not only an export. Ask what read access costs after the contract ends, and for how long.
• A full export of your data. Ask your current vendor for it in writing, and what it costs. If its EHR has a certified export capability, a fee for using that export to switch systems falls outside the federal fee exception and can count as information blocking [5]. Ask your vendor whether its EHR holds that certification.

Five things to put in the new contract

1. A go-live date with a remedy. What you get if it slips.
2. The data scope, in writing. What moves, what doesn't, and who checks it before cutover.
3. Claims and OASIS tested before go-live. A claim accepted by your contractor and an assessment accepted by CMS.
4. Billing support through the first full cycle. Someone on your claims until the first periods billed in the new system are paid.
5. When billing starts. At signature, at go-live, or later.

Frequently asked questions

Sources

1. 42 CFR 484.110(c)(1), Clinical records, retention. ecfr.gov/current/title-42/chapter-IV/subchapter-G/part-484/subpart-C/section-484.110 (read Nov 2, 2026)
2. CMS, MLN Matters MM12256, Notice of Admission; 42 CFR 484.205(j). cms.gov/files/document/mm12256.pdf (read Oct 30, 2026); law.cornell.edu/cfr/text/42/484.205 (read Nov 2, 2026)
3. CMS QTSO, OASIS iQIES software discontinuation. qtso.cms.gov/news-and-updates/oasis-iqies-software-discontinuation (read Nov 2, 2026)
4. Enzo, EHR. enzo.health/ehr (read Nov 4, 2026)
5. 45 CFR 171.302(b)(3), Fees exception, and 171.102, Definitions. ecfr.gov/current/title-45/subtitle-A/subchapter-D/part-171 (read Nov 2, 2026)

Keep reading

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