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Corporate Transparency Act to be Re-evaluated

Client Alert

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 February 20th, we alerted business owners that the reporting required by the CTA was reinstated, as all nationwide federal injunctions had been lifted. However, on February 27th, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a press release providing that no enforcement actions will be taken against businesses that fail to submit reporting.

The press release provides that FinCEN will be reevaluating the CTA and will provide new guidance and clarity “as quickly as possible.”  Public comment will be solicited by FinCEN during this reevaluation.

Given FinCEN’s new position on the CTA, businesses no longer have any obligation to submit reporting.  A reevaluation of reporting obligations will also be warranted by business owners in the event FinCEN does publish a new final reporting rule, as the impetus for change was a reduction of the regulatory burden on businesses while prioritizing reporting only for those entities that pose the most significant risks.

For further guidance on the changing landscape of CTA reporting, business owners should reach out to their BMD legal advisors or contact BMD Member Blake Gerney at brgerney@bmdllc.com.


Ohio Legalizes Recreational Marijuana; What’s Next for Ohio Employers?

Recent Changes to the No Surprises Act’s Federal IDR Process

Proposed changes to the No Surprises Act’s independent dispute resolution (IDR) process were recently issued by the Department of Health and Human Services, Department of Labor, Department of Treasury, and the Office of Personnel Management. The October 27, 2023, proposed rule overhauls the current Federal IDR process in an effort to create efficiencies and reduce delays relating to eligibility determinations and address feedback from interested parties and certified IDR entities.

What Inpatient Behavioral Health Providers Need to Know About ODM's New Draft Rule for Reimbursements

Ohio Department of Medicaid (ODM) recently released a draft rule that will transform how inpatient behavioral health services are reimbursed for some hospitals. ODM will migrate inpatient payments for behavioral health and substance use disorder services (BH/SUD) provided by freestanding psychiatric hospitals (FSPs) from the APR-DRG payment methodology to a per diem payment methodology derived from the APR-DRG system.

BMD Named to the 2024 U.S. News – Best Lawyers® “Best Law Firms”

Brennan Manna & Diamond (BMD) is recognized among the leading law firms in the nation according to the 2024 Edition of U.S. News – Best Lawyers®  "Best Law Firms." The firm has ranked in in 13 practice areas and has earned “National Tier 1” rankings in Health Care Law and Litigation-Trusts & Estates.

Friendly Physician Models: The Basics Through 5 Frequently Asked Questions

During the past several years, many health law practices have noticed a dramatic increase in the number of telehealth businesses and private equity backed health care providers. Both of these trends often rely heavily on corporate structures commonly referred to as “friendly physician,” “captive PC” or “MSO” models. Although friendly physician models are used by non-physician health care providers (e.g., physical therapists, psychologists, and dentists), this article focuses on physicians and how the model is used in connection with the provision of professional medical services.