Resources

Client Alerts, News Articles, Blog Posts, & Multimedia

Everything you need to know about BMD and the industry.

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

Client Alert

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.


Key Healthcare Provisions in Ohio’s 2026–2027 Budget

Ohio’s newly enacted biennial budget (HB 96) for FY 2026–2027 brings sweeping changes for healthcare providers across the state. The law includes new Medicaid eligibility requirements, reporting mandates, funding directives, and social policy provisions. Several vetoes by Governor DeWine also affect healthcare-related initiatives.

Providers Beware: Court Sides with Insurers in No Surprises Act Arbitration

On June 12, 2025, the Fifth Circuit ruled in favor of Aetna and Kaiser in two lawsuits brought by air ambulance providers challenging how insurers calculated payments under the No Surprises Act’s Independent Dispute Resolution process. The court held that unless there is clear evidence of fraud or serious misconduct, IDR decisions will stand, reinforcing the finality of the arbitration process.

Introducing HB 281: Enforcement of Federal Immigration Laws in Ohio Hospitals

House Bill 281, introduced on May 20, 2025, would require Ohio hospitals to allow law enforcement, including federal immigration agents, to enter facilities and enforce immigration laws. The bill mandates that hospitals comply with information requests and adopt formal policies, raising significant concerns about patient privacy and access to care for immigrant communities.

Parental Consent May Soon Be Required for Minor Mental Health Services in Ohio

HB 172 proposes repealing a provision in Ohio law that allows minors age 14 and older to consent to limited outpatient mental health services without parental involvement. The bill would require parental consent for all such care and remove related language from other sections of the Ohio Revised Code.

Community Behavioral Health Providers - Supervisor Pricing Changes Begin July 1 [Corrected Date]

Effective June 16, community behavioral health providers wishing to receive reimbursement at the supervisor rate must add the HP or HT Modifier to fee-for-service (FFS) claims. Find out about the new guidelines.