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

Client Alert
July 1, 2025

On May 20, 2025, House Bill (HB) 281 was introduced in the Public Safety Committee. HB 281 seeks to require licensed hospitals regulated by the Ohio Department of Health (ODH) (per O.R.C. 3722) and licensed psychiatric hospitals regulated by the Ohio Department of Mental Health and Addiction Services (OMHAS) (per O.R.C. 5119) to permit law enforcement to enter hospital facilities and enforce immigration laws.

Law enforcement includes any agent or officer of the U.S. Department of Homeland Security (DHS), any other federal law enforcement officer, or any state or local law enforcement officer who is assisting a federal officer or agent of DHS (federal agents). When enforcing federal immigration laws, law enforcement would be permitted to (1) arrest any individual, including patients or family members present pursuant to a lawful judicial or administrative warrant; (2) interview any individual, including patients or family members present; (3) collect information or evidence, potentially including personal information or citizenship documentation; and (4) request hospital employees to provide any information or evidence that the hospital possesses to the extent permitted by federal or state law. If law enforcement is denied access to the hospital, the agent can file a report with the hospital’s respective Ohio licensing agency (ODH or OMHAS), which can cause the hospital to lose state funding and its status as a Medicaid provider.

Moving forward, HB 281 requires hospitals to adopt a written policy to establish standards and procedures to comply with law enforcement’s requests for information. Hospitals will need to think about how they want to structure their policies and procedures to comply with state law and also protect patients. HB 281 will dramatically impact hospitals’ ability to protect immigrant patients. One practical impact of HB 281 will be fewer patients, especially immigrant patients without legal status, seeking life-saving healthcare services at Ohio hospitals. Additionally, hospitals will be required to routinely deal with law enforcement while simultaneously providing care to patients.

To learn more about HB 281 and how the bill could impact your hospital, please contact BMD Healthcare Member Daphne Kackloudis at dlkackloudis@bmdllc.com or Attorney Jordan Burdick at jaburdick@bmdllc.com.

HealthcareHospital LawImmigrationDaphne KackloudisJordan Burdick
Client Alert

New Florida Law: Patient Overpayments Must Be Refunded Within 30 Days

December 22, 2025Effective January 1, 2026, Florida Senate Bill 1808 requires health care facilities and practitioners to refund patient overpayments within 30 days after an overpayment is identified. The law applies to overpayments tied to claims submitted to government programs or private insurers and introduces fines and disciplinary consequences for noncompliance. Providers should review billing and payment practices now to prepare for the new requirements.Client Alert

USCIS Policy Change Impacting Work Authorization: Advisory for Employers and Human Resources

December 8, 2025USCIS has issued a policy memorandum pausing immigration benefit processing for individuals from 19 high-risk countries and requiring a re-review of certain previously approved cases. This change may affect work authorization, employment verification, and workforce stability. Employers and HR teams should review impacted employees and update compliance procedures.Client Alert

CMS Releases CY 2026 Medicare Physician Fee Schedule Final Rule with Key Payment and Telehealth Updates

December 4, 2025CMS issued the CY 2026 Medicare Physician Fee Schedule Final Rule on October 31, 2025, with changes effective January 1, 2026. The Final Rule includes increases to the conversion factor, a new efficiency adjustment, updates to practice expense methodology, permanent telehealth policy changes, revised payment for skin substitutes, expanded rules for Part B drugs and biologicals, enhanced policies for Rural Health Clinics and Federally Qualified Health Centers, and new care management and behavioral health services.Client Alert

Ohio Department of Medicaid Updates: Key Changes to Physician Reimbursement Rates in Early Parenthood

December 3, 2025The Ohio Department of Medicaid has proposed amending Ohio Administrative Code Rule related to covered Medicaid reimbursements for physicians. Beginning on January 1, 2026, they are proposing an increase to rates for prenatal care, childbirth, and infant care and provider visits.Client Alert

Name, Image, and Likeness Agreements in Healthcare

November 14, 2025For 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.
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