Switching NEMT billing companies: claims in flight, portal access, and getting your records back

Read the contract before you give notice

The contract decides most of what happens next, so read it before you tell the billing company you are leaving. Mark these terms:

• Notice. How many days’ written notice, to whom, and whether you can leave early for cause.
• Run-out. Whether the company must keep working claims it already sent after the end date, for how long, and at what price.
• Fees after the end date. Any charge on money that arrives after you leave, and any exit or data fee.
• Data return. What the company hands back, in what format, and how fast.
• Logins. Which payer, clearinghouse, and broker accounts the company opened, and in whose name.

One federal rule limits how a billing company that collects Medicaid payments in your name can be paid. When a business agent sends statements and receives payments in the provider’s name, 42 CFR 447.10(f) ties its pay to the cost of processing the billing. The pay may not be a percentage of the amount billed or collected, and it may not depend on the claim being paid. Keep that in mind if the final invoice includes a share of Medicaid money that came in after you left. The billing service guide covers contract terms in more detail.

Get your records back

The claim history is your company’s record, and the business associate agreement says how it comes back. Under 45 CFR 164.504(e), the agreement must require the company, at the end of the contract, to return or destroy all rider health information it still holds and keep no copies, if that is feasible. If it is not feasible, the agreement’s protections stay on that information and limit its further use.

Ask for return, not destruction. You will need these records for appeals, audits, and the new biller’s first weeks. Every Medicaid provider agreement also commits you to keep records that show the extent of your services and to hand them to the state, HHS, or the Medicaid Fraud Control Unit on request (42 CFR 431.107). Request:

• Claim history by payer, with dates of service, amounts, statuses, and each payer’s claim number
• Every electronic remittance and broker payment statement received
• The open denial and appeal list, with each deadline
• Payer letters, records requests, and audit correspondence
• Enrollment and credentialing paperwork the company filed for you
• A list of every account the company created in your name, with its login owner

HHS has addressed a company that holds data back. Its guidance says a business associate that blocks a provider’s access to health information to resolve a payment dispute is making an impermissible use under the Privacy Rule. At termination it must return the information as the agreement provides, in a format reasonable for keeping it accessible and usable.

Enrollments held under your NPI

A billing company usually sets up the electronic connections between your provider number and each payer. Each connection has to move to the new biller, and some take weeks.

Remittances and deposits

Every provider enrolls separately with each health plan it bills for electronic deposits (EFT) and electronic remittances (ERA). CMS guidance (GL-2022-04) says a provider may use the vendor of its choice to receive remittances, and that a health plan may not force a vendor on it. Those enrollments follow the national CORE 380 and 382 rules adopted at 45 CFR 162.1603.

In practice, check two things with each payer. First, the deposit account must be your company’s own account, which it should have been all along. Second, the remittance has to go to whoever posts payments now. If the old company’s clearinghouse receives your remittances, file a change so they reach the new biller. The EFT enrollment entry explains the deposit side.

Texas Medicaid

TMHP allows only one submitter ID to download a provider’s electronic remittance. Choosing “Change Enrollment” on the ERA agreement cancels the earlier setup, and TMHP tells providers to find out who currently receives it before changing anything. A PDF version of the remittance keeps going to the provider’s TexMedConnect account either way.

A new billing company that is not yet a TMHP trading partner files the trading partner application and agreement, which can take up to 30 days to process. Its submitter ID works only in the test system until it sends five error-free batches of 50 transactions for each transaction type and TMHP approves it for production. Two dates matter this year. TMHP will shut off submitter accounts not accessed since November 30, 2025 on December 1, 2026. It will also require every submitter to file a new EDI Trading Partner Agreement online by May 15, 2027, with the form available from December 1, 2026, and will deactivate submitters that miss the date.

New York Medicaid

In New York, a billing agency enrolls in the Medicaid program as a service bureau (category of service 0080, with a $750 application fee) and gets its own ETIN, the electronic transmitter number. To let it bill for you, you sign a notarized certification statement linking your provider number to its ETIN.

To cut off the old company, file eMedNY’s Request to Disaffiliate/Delete an ETIN. An owner listed on your enrollment must sign it. Then check your default ETIN, which controls where remittances go for paper claims, state adjustments and voids, and Medicare crossovers. Each provider number has one default, and eMedNY allows up to 14 business days to process a change. Certifications renew every year, and a lapsed ETIN can push remittances back to paper.

Broker and plan portals

Ask each broker and health plan to remove the old company’s user accounts and to set up the new biller the way it allows. Change any password the old company knew. Do the same with your clearinghouse if the account is in your name. If it is in the old company’s name, the new biller will usually need its own account and new enrollments with each payer.

Claims in flight on the cutoff date

Every claim needs exactly one owner during the switch. Pick a cutoff date and write it down: claims sent before it belong to the old company, and claims sent after belong to the new biller. Then freeze the old company’s submission access on that date.

Before the cutoff, get a run-out report of every open claim with its payer claim number. The number matters because a corrected claim is a replacement, not a new claim. On the paper form, item 22 takes frequency code 7 for a replacement or 8 for a void, along with the original reference number (NUCC instruction manual, version 13.0). Resending a claim the payer already has usually denies as an exact duplicate, reason code 18.

Payments for old claims keep arriving after the cutoff. Decide who posts them and who works their denials, and make sure the remittance routing change happens before the first one lands.

Look back 90 days for trips nobody billed

A switch is when completed trips slip through. Pull every completed trip from the last 90 days and match it against the claims list by rider and date of service. Look for three gaps:

1. Trips with no claim at all.
2. Claims rejected before they reached the payer’s system and never resent. A rejection is not a denial, and it may not count as filed.
3. Denials nobody worked.

Ninety days is a working window, not a rule. Each payer sets its own timely filing limit. Under MTM’s standard agreement, a claim filed later than 90 days after the ride is not paid, unless MTM’s client contract sets a longer window. TMHP publishes a calendar of its 95-day and 120-day deadlines. For state Medicaid itself, the federal outer limit is 12 months from the date of service. Bill the oldest trips first, and confirm status in each payer’s system before resending, using the claim status guide.

Settle the final invoice

Check the last invoice line by line against the contract. Watch for charges on claims sent after the cutoff, for claims the company never sent, and for percentage fees on Medicaid money. Pay the undisputed part on time, and dispute the rest in writing with the contract section you rely on.

The lookback may turn up overpayments, such as duplicate payments or trips paid at the wrong rate. Those are yours to return, whoever sent the claim. Federal law generally gives a provider 60 days from identifying an overpayment to report and return it; the 60-day rule guide explains the clock.

A transition calendar

Plan on about two months. TMHP alone allows up to 30 days to process a new trading partner’s forms, and testing comes after that.

1. About 60 days out. Read the contract, list every payer and enrollment, sign the new biller’s business associate agreement, and start any trading partner or service bureau filings.
2. About 30 days out. Give written notice, request the full data return, and agree on the cutoff date and run-out terms in writing.
3. Cutoff week. Move remittance routing, remove the old company’s logins, freeze its submissions, and receive the run-out report.
4. First 30 days after. Run the 90-day lookback, work the open denials, settle the final invoice, and get written confirmation of what records the old company returned and whether it kept any.

Keeping your own copy of every trip

A switch is easier when the trip records never lived only in the billing company’s system. HealthRide keeps each finished ride’s GPS-recorded miles, timestamps, signatures, and recorded no-show waits in your own account. A new biller can start from a trip log you export as a CSV or PDF from reports, and invoices and payments for private and facility work stay in one ledger you control.