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Corporate Transparency Act Is Back in Effect: Are You Ready?

Client Alert
December 26, 2024

On December 5, 2024, the Federal Government was enjoined from enforcing the Corporate Transparency Act (CTA) in Texas Top Cop Shop, Inc., et al v. Garland et al, No. 4:2024 cv 00478 - Document 30 (E.D. Tex. 2024). At least for now, that prior ruling has been overturned and the filing requirements under the CTA are back in effect. 

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the Federal Government’s emergency motion for a stay of the nationwide injunction pending appeal. According to the Fifth Circuit, the Federal Government “met its burden” for it to issue a stay and reinstate the obligations under the CTA.

In addition to the widely circulated court opinion, the Financial Crimes Enforcement Network (FinCEN) website gives businesses the following guidelines:

  • First, reporting companies that were created or registered prior to January 1, 2024, now have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN (it was previously January 1, 2025).
  • Second, reporting companies created or registered on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN (it was previously 30 days from creation or registration).
  • Third, reporting companies created or registered on or after December 3, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN (it was previously 90 days from creation or registration).

What to do now?
Based on the Court ruling and update to the FinCEN website, reporting companies are required to comply with the law and file beneficial ownership reports as provided in FinCEN’s regulations, albeit with the updated deadlines described above.

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 LawBeneficial Ownership Information Reporting
Client Alert

CMS Requires Providers to Use an Updated Advance Beneficiary Notice (ABN) Form by May 12, 2026

May 22, 2026CMS has released an updated Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, that all providers and suppliers must begin using by May 12, 2026. The revised form includes clearer language and formatting updates intended to improve patient understanding and compliance.Client Alert

CMS and Ohio Ramp Up Fraud Enforcement in Home Health and Hospice

May 15, 2026CMS and Ohio have launched sweeping new fraud prevention initiatives targeting home health and hospice providers, signaling a period of heightened scrutiny for enrollment, billing, documentation, and EVV compliance. While aimed at combating fraud, these measures also create significant operational and due process risks for compliant agencies, making proactive compliance programs, auditing, and governance more important than ever.Client Alert

MYTH BUSTER: Can a New Chiropractor Bill Under An Established Chiropractor’s NPI?

May 14, 2026Many chiropractic practices mistakenly believe a newly hired chiropractor can bill under an established chiropractor’s NPI while waiting for credentialing approval. In most cases, this is not permitted. Claims should be submitted under the NPI of the chiropractor who actually rendered the service to avoid compliance risks, including potential False Claims Act exposure. This article outlines key billing rules, common exceptions, and practical compliance tips for chiropractic practices.Client Alert

RNs and APRNs Take Note: Ohio Board of Nursing Mandates a New CE Reporting Period

April 29, 2026Ohio’s Board of Nursing has updated the continuing education reporting period for RNs and APRNs. Beginning March 26, 2026, CE credits must be completed between July 1 and June 30 of odd-numbered years, replacing the previous November to October timeframe.Client Alert

Ohio Med Spas: Peptide Do's and Do Not's

April 29, 2026Recent guidance from the Ohio Board of Pharmacy outlines key compliance requirements for med spas using peptides. While some peptide drugs are FDA approved, others are not or cannot be compounded. Med spa operators should ensure they source medications from licensed suppliers, avoid non-approved or “research use only” products, and follow all compounding and storage regulations to maintain compliance and avoid enforcement actions.
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