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Corporate Transparency Act Effective Again

Client Alert
February 20, 2025

Over the past several months, the federal judiciary has provided numerous rulings on the enforceability of the Corporate Transparency Act (CTA), which became effective January 1, 2024. For a more detailed overview on the CTA, click here.

On January 24th, we alerted business owners that enforcement of the CTA was barred nationwide pursuant to federal litigation in Texas (Smith v. U.S. Department of the Treasury, Case No. 6:24-cv-336-JDK). However, on February 18th, the Court in Smith lifted its previous stay which prevented enforcement of the CTA.

Due to this updated ruling, the CTA’s reporting requirements are back in effect nationwide. Non-exempt entities now have until March 21, 2025 to submit required reporting. 

Entities that have not completed reporting should re-engage compliance efforts immediately to meet this updated deadline. The civil penalty for failing to file reporting required under the CTA is $591 per day, up to a total of $10,000. Note also that criminal penalties are authorized for any person who willfully (i) provides or attempts to provide false/fraudulent information, or (ii) fails to report and/or update a report previously made.

For guidance on complying with these updated requirements, business owners should reach out to their BMD legal advisors or contact BMD Member Blake Gerney at brgerney@bmdllc.com.

Corporate Transparency ActBusiness & Corporate LawBlake R. GerneyMichael SneeringerNathan AltstadtJacob R. Davis
Client Alert

Medicare Updates on Skin Substitutes: LCDs Withdrawn, Payment Changes Take Effect

January 23, 2026Medicare’s planned Final Local Coverage Determinations (LCDs) for skin substitutes were withdrawn in late December 2025, meaning previous coverage rules remain in effect. The 2026 Medicare Physician Fee Schedule introduces a single payment rate of approximately $127.14 for these products. Providers should review implications for diabetic foot and venous leg ulcer treatments.Client Alert

Understanding the Seven Core Elements of an Effective Healthcare Compliance Program

January 22, 2026The Affordable Care Act requires healthcare providers participating in Medicare, Medicaid, and CHIP to maintain an effective compliance program. Guidance from the Department of Health and Human Services and the Office of Inspector General outlines seven core elements that form the foundation of these programs, from written policies and compliance oversight to auditing, training, and corrective action. This alert highlights each element and explains how practices can tailor compliance programs to their size and risk profile while meeting federal expectations.Client Alert

Preventing a Board Investigation

January 21, 2026Healthcare professionals in Ohio are subject to licensing board investigations that can lead to disciplinary action. Staying compliant with regulations, documenting carefully, and operating within your professional scope can help prevent issues. If contacted by a board, working with an attorney is critical to protect your license and rights.Client Alert

Ohio Board of Nursing Proposes Rule Changes for Nurses

January 14, 2026On Monday, January 12, 2026, the Ohio Board of Nursing (“BON”) released a package of proposed changes to the Ohio Administrative Code. There are two proposed changes to continuing education requirements that Ohio nurses should be watching.Client Alert

New Florida Law: Patient Overpayments Must Be Refunded Within 30 Days

December 22, 2025Effective January 1, 2026, Florida Senate Bill 1808 requires health care facilities and practitioners to refund patient overpayments within 30 days after an overpayment is identified. The law applies to overpayments tied to claims submitted to government programs or private insurers and introduces fines and disciplinary consequences for noncompliance. Providers should review billing and payment practices now to prepare for the new requirements.
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