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Corporate Transparency Act Reporting Deadline: December 31

Client Alert

The Corporate Transparency Act (“CTA”), which became effective January 1, 2024, imposes strict reporting guidelines on small business owners throughout the country. The deadline for non-exempt businesses to submit reporting is December 31, 2024.

The civil penalty for failing to file reporting required under the CTA if $591 per day, up to a total of $10,000. Also note 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.

If you are the beneficial owner of an entity formed pursuant to a filing with a state secretary of state’s office (i.e., an LLC or a corporation), your entity must report. There are a few exemptions to this reporting requirement. If an entity meets an exemption, it does not need to presently report.  However, if an exemption ever becomes inapplicable to the entity, the entity then has 30 days to report. 

Completed reports are not public record; reporting is maintained by the financial crimes wing of the Department of the Treasury in a database that’s only accessible by state and federal law enforcement.

To avoid facing a potential steep fine to kick of your 2025 fiscal year, or to better understand whether your entity needs to report, please do not hesitate to contact BMD Attorney Jacob R. Davis (jrdavis@bmdllc.com).

For a more detailed overview on the CTA, click here.


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

CMS 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.

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

CMS 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.

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

Many 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.

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

Ohio’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.

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

Recent 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.