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I Went to Bed and the Rules Changed: the Corporate Transparency Act is Back on Hold

Client Alert
December 27, 2024

Yesterday we told you that the Fifth Circuit had reinstated the Corporate Transparency Act’s filing requirements, overturning the prior injunction [read the article here].

Now the Court has reversed course, overturned its decision from 3 days ago, and reinstated the nationwide injunction.

The United States Court of Appeals for the Fifth Circuit ordered on December 26, 2024 that in an effort to “preserve the constitutional status quo” while it considered the Federal Government’s appeal, it vacated the prior order for a stay of the nationwide injunction pending appeal entered on December 23, 2024, and reinstated the preliminary injunction enjoining enforcement of the CTA and its corresponding Reporting Rule.

What to do now?

As of this morning, the FinCEN website had not been updated to reflect the December 26, 2024 order. With all of the back-and-forth orders and updates, a measure of caution should be applied: proceed as-if the law could change in a matter of days. That is, if you have not complied with the CTA and its corresponding Reporting Rule, have all of your information ready in case the preliminary injunction is lifted again.

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 and 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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