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EVV Requirements for Ohio Medicaid Postponed to January 2025

Client Alert

Recently, the Ohio Department of Medicaid (ODM) announced that it is pushing back the effective date of changes to the Electronic Visit Verification (EVV) claims adjudication process to January 1, 2025. Previously, the EVV requirements were set to go into effect on October 1, 2024.

The ODM initiated its EVV program in 2018 to comply with the Federal 21st Century Cures Act, which required all state Medicaid programs to implement an EVV system to verify personal care services by January 1, 2020, and home health services, by January 1, 2023. 

EVV is an electronic system for providers to capture patient visit data and to more accurately bill ODM for home visits. In Ohio, EVV is specifically required for providers who participate in the following ODM programs:

  1. Ohio Home Care Waiver
  2. MyCare Ohio Waiver
  3. PASSPORT Waiver
  4. Individual Options Waiver
  5. SELF Waiver

The EVV system requires home health providers to enter five important data elements during eligible visits: 

  1. Who receives the service
  2. Who provides the service
  3. What service is provided
  4. Where the service is provided
  5. The date and time the service begins and ends.

Providers have three ways to capture the visit data: via a mobile app; dedicated phone line (i.e., telephony); or manual entry on a computer into the system. However, ODM only permits manual visit entry when a device app or telephony is not available or appropriate for the member’s needs.

If you have any questions regarding the EVV system and/or requirements, please contact BMD Healthcare Member Daphne Kackloudis at dlkackloudis@bmdllc.com  or Attorney Jordan Burdick at jaburdick@bmdllc.com.


Name, Image, and Likeness Agreements in Healthcare

For example, some healthcare providers have begun to utilize "Name, Image, and Likeness" agreements to promote the brand they have created through their healthcare practice.  We have seen the most healthcare NIL activity with longevity and wellness providers, as well as orthopedics.

Compounding GLP-1 Drugs - Recent Updates

Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.

Top Compliance Risks for Ohio Med-Spas in 2025

The Ohio Board of Pharmacy has increased inspections of med-spas holding Terminal Distributor of Dangerous Drugs (TDDD) licenses, with many facing enforcement actions in 2025. Common issues include purchasing from unlicensed distributors, improper drug storage, inadequate recordkeeping, and insufficient prescriber oversight. Understanding these risks and maintaining compliance can help protect your practice from penalties and license suspension.

Pre and Postnuptial Agreements | Necessary, Maybe, What Happened to Forever?

Both Florida and Ohio now allow clients to enter into a prenuptial or postnuptial agreement prior to marriage or after marriage (Ohio previously did not allow postnuptial agreements). Both documents have statutory guidelines that must be followed in terms of execution and financial disclosure.

DHS Ends All Employment Authorization Auto-Extensions

Effective October 30, 2025, DHS ends all automatic work authorization renewals. The 540-day extension applies only to renewals filed before this date, and there is no grace period for expired EADs filed on or after October 30. Employers must audit EADs, train staff, ensure I-9 compliance, and plan for work authorization gaps. Penalties for noncompliance can be severe.