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CLIENT ALERT: Medicare Providers having multiple locations should verify and revalidate their address information to avoid claim denials

Client Alert

MLN Matters SE19007 “Activation of Systematic Validation Edits for OPPS Providers with Multiple Service Locations” notifies providers that Medicare is now requiring the exact match of all addresses for practice locations that are listed on provider claim submissions to Medicare. (See attached)

Medicare began auditing in July 2018 for purposes of reinforcing Chapter 1, Section 170 of the Medicare Claims Processing Manual “Payments on the MPFS for Providers with Multiple Service Locations.”  The exact address match will be in full and effect once the July 2019 quarterly release is implemented.

Claims that do not have an exact address match will be returned to the provider.  Providers can make corrections to their service facility address for a claim submitted in the DDE MAP 171F screen for DDE submitters.

It is recommended that providers review their Medicare enrollment record and billing practices to ensure compliance with the exact address match requirement.  Medicare recommends that all providers update their billing records to match Medicare enrollment records.  Providers should verify and submit changes through the CMS-855A or CMS-855B application through the Provider Enrollment, Chain, and Ownership System (PECOS) as soon as possible.  Changes and updates to an address or the addition of a new location typically take Medicare 30–60 days to process.

If you would like copies of the regulations, need legal assistance with updating your Medicare enrollment information, or have any questions concerning these matters, please contact Amanda Waesch at 330-253-9185 or via email at alwaesch@bmdllc.com.


Substance Use Disorder Providers: 42 CFR Part 2 Now Enforceable

Updates to 42 CFR Part 2 are now enforceable, bringing significant changes to how substance use disorder (SUD) records are handled. The Final Rule aligns Part 2 more closely with HIPAA, introduces updated penalties, allows a single patient consent for treatment, payment, and operations, and adds new requirements for Notices of Privacy Practices. It also creates a formal definition of SUD counseling notes and imposes strict consent requirements for their use and disclosure. Providers should review and update policies to ensure compliance.

AAA Introduces AI-Assisted Arbitrator for Certain Disputes

The American Arbitration Association has introduced an AI-assisted arbitration platform designed to streamline certain document-based disputes. While a human arbitrator still makes the final decision, the technology can improve efficiency, reduce costs, and accelerate case resolution. Companies should weigh these benefits against considerations such as transparency, risk, and contractual requirements before adopting AI-assisted arbitration.

Quiet Hours Texts and TCPA Claims: Consent Remains King as Courts Divide on Text Messages

Businesses face increasing TCPA lawsuits over off-hours marketing texts, but recent court decisions highlight strong defenses. Clear consumer consent and updated terms and conditions can defeat many claims, while a growing number of courts are finding that text messages are not “telephone calls” under the statute. Proactive compliance measures, including clickwrap agreements and forum-selection clauses, are critical to reducing risk.

New Ohio Reporting Requirements for Non-Residential Contractors

Ohio’s E-Verify Workforce Integrity Act, effective March 19, 2026, requires all nonresidential construction companies, subcontractors, and labor brokers to use E-Verify to confirm employee work eligibility on projects across the state. The law applies regardless of company size and carries financial penalties and potential restrictions on future state contracts for noncompliance. Some uncertainty remains around requirements for existing employees, making early compliance planning important.

DOT Non-Domiciled CDL Rule

A new rule from the Federal Motor Carrier Safety Administration (FMCSA) will significantly narrow eligibility for non-domiciled Commercial Driver’s Licenses (CDLs) beginning March 16, 2026. The rule limits eligibility to holders of H-2A, H-2B, and E-2 visas and eliminates Employment Authorization Documents (EADs) as qualifying proof of work authorization. As a result, many lawfully present and work-authorized immigrants, including refugees, asylees, DACA recipients, and Temporary Protected Status holders, will no longer be able to obtain or renew a non-domiciled CDL. The change is expected to affect roughly 194,000 drivers nationwide and has prompted multiple legal challenges, including a pending emergency stay request before the United States Court of Appeals for the District of Columbia Circuit.