In March 2026, the Department of Health and Human Services (HHS), through the Centers for Medicare & Medicaid Services (CMS), finalized a long-awaited rule establishing national standards for the electronic exchange of clinical documentation used in healthcare claims attachments. It aims to move the industry away from manual processes involving fax, mail, and portal uploads, and to speed up claims processing and reduce overall administrative burden. The rule adopts standards under HIPAA administrative simplification requirements and addresses longstanding inefficiencies with integrating clinical data and administrative information.

The final regulation:

• Adopts national standards for the electronic exchange of health care claim attachments for additional documentation used in conjunction with existing claims transactions.
• Adopts national standards for electronic signatures when used in connection with attachments for authenticated transmission, but does require the use of electronic signatures.
• Establishes national standards relying on transaction-based (X12) and document-based (CDA) approaches. See the appendix for technical references and details.
• Applies when HIPAA-covered entities (providers, plans, clearinghouses) conduct electronic transactions involving claims attachments in support of claims processing.
• Takes effect May 2026, with required compliance by May 26, 2028.

Practices should prepare, as needed, for operational changes. This involves coordinating and planning carefully with health IT vendors, payers, and services partners to update systems, train staff, and conduct testing to validate workflows and system performance. Ultimately, practices can submit attachments proactively with a claim or in response to a payer request using standardized electronic transactions rather than manual submission methods. Practices may experience a transition period involving both manual and electronic workflows near term that will depend, in part, on their own capabilities and on those of their trading partners. As CMS states in the rule, entities are required to comply only for transactions they conduct electronically.