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IMPORTANT PRF UPDATE! HRSA Allows Providers the Opportunity to Correct Missed Period 1 Reporting

Client Alert

Late Wednesday, April 6, HRSA announced that it was going to allow providers with extenuating circumstances that prevented them from preventing a completed Period 1 Report to submit a Request to Report Late Due to Extenuating Circumstances. More information on the process and links to the required forms can be found here.

Providers who failed to report in Period 1 and failed to return their Period 1 PRF payments should have received an email on Wednesday, April 6. If a provider did not receive an email, the provider should go onto the portal and ensure that all provider contact information is correct. All providers must be appropriately registered with the Portal in order to engage in this process.

Step 1:  Providers must first submit a Request to Report Late Due to Extenuating Circumstances. Requests must be submitted between Monday, April 11 to Friday, April 22 at 11:59pm ET. Extenuating circumstances include the following instances: 

  • Severe illness or death – a severe medical condition or death of a provider or key staff member responsible for reporting hindered the organization’s ability to complete the report during the Reporting Period.
  • Impacted by natural disaster – a natural disaster occurred during or in close proximity of the end of the Reporting Period damaging the organization’s records or information technology.
  • Lack of receipt of reporting communications – an incorrect email or mailing address on file with HRSA prevented the organization from receiving instructions prior to the Reporting Period deadline.
  • Failure to click “Submit” – the organization registered and prepared a report in the PRF Reporting Portal, but failed to take the final step to click “Submit” prior to deadline.
  • Internal miscommunication or error – internal miscommunication or error regarding the individual who was authorized and expected to submit the report on behalf of the organization and/or the registered point of contact in the PRF Reporting Portal.
  • Incomplete Targeted Distribution payments – the organization’s parent entity completed all General Distribution payments, but a Targeted Distribution(s) was not reported on by the subsidiary.

Step 2:  HRSA must approve your Request to Report Late Due to Extenuating Circumstances. Therefore, providers must ensure that their request is detailed as to the extenuating circumstance that prevented them from timely reporting. If a provider’s request is NOT approved, the provider must return the Period 1 funds.

Step 3:  Providers must wait for HRSA to approve the request. If the request is approved, providers will have 10 days from the date of the notification to submit a Period 1 report.

Step 4:  Providers that have already reported may NOT use this process to make edits or adjustments to their Period 1 report.

If you need assistance in completing the Request to Report Late Due to Extenuating Circumstances or finalizing your Period 1 Report, please contact Amanda L. Waesch at alwaesch@bmdllc.com or 330-253-9185 to set up a consultation. 


Federal Trade Commission Voids Non-Compete Agreements Nationwide

On April 23, 2024, the U.S. Federal Trade Commission (“FTC”) issued its Final Rule containing regulations impacting non-compete agreements across the country for all employees. The Final Rule implements some of the most impactful changes to employment law during this century. The Final Rule will take effect 120 days from its publication in the Federal Register, which we expect to occur within the next few weeks.

Department of Labor Finalizes Rule with Substantial Salary Increases for White-Collar Overtime Exemptions

On April 23, 2024, the U.S. Department of Labor (DOL) announced a final rule that will significantly impact overtime eligibility for white-collar employees under the Fair Labor Standards Act (FLSA). This rule implements a dramatic increase in the minimum salary level required for an employee to be exempt under the FLSA’s administrative, executive, and professional exemptions (the so-called “white collar exemptions”) as well as the FLSA’s highly compensated employee exemption.

Chemical Dependency Professionals Board Rule Changes: Part 2

New rule changes for Certification of Chemical Dependency Counselor Assistants (CDCA)

Board of Pharmacy Rule Changes

Board of Pharmacy made changes to rules effective on March 4, 2024

Counselor, Social Workers, and Marriage and Family Therapist (CSWMFT) Board Rule Changes

The Counselor, Social Workers, and Marriage and Family Therapist (CSWMFT) Board has proposed changes to the Ohio Administrative Code rules discussed below. The rules are scheduled for a public hearing on April 23, 2024, and public comments are due by this date. Please reach out to BMD Member Daphne Kackloudis for help preparing comments on these rules or for additional information.