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New Medicare Billing Rules: What MFTs, MHCs, and IOP Providers Need to Know

Client Alert
July 9, 2024

Starting January 1, 2024, Medicare began covering services provided to Medicare beneficiaries by marriage and family therapists, mental health counselors, and Intensive Outpatient Program (IOP) services. With this change, Medicare has become the primary payer for these services. 

To allow providers time to enroll in Medicare, the Ohio Department of Medicaid (ODM) and MyCare Ohio plans have continued to pay claims for these services for Medicaid enrollees with dual Medicare and Medicaid eligibility through June 30, 2024. Once providers are enrolled with Medicare, claims must be submitted to Medicare before the provider seeks cost-sharing reimbursement from Medicaid.

In compliance with these updates, ODM recently announced updates to its Medicare and Third-Party Liability Bypass List, effective July 1, 2024. The Bypass List, organized by procedure code, indicates which provider types may bypass Medicare and bill Medicaid directly. The list has been updated to reflect the small set of provider types now eligible to bypass Medicare.

Please contact BMD Healthcare Member Daphne Kackloudis at dlkackloudis@bmdllc.com or Attorney Jordan Burdick at jaburdick@bmdllc.com with any questions.

MedicareMedicaidOhio Department of MedicaidHealth LawDaphne KackloudisJordan Burdick
Client Alert

FTC Continues to Target Noncompetes

September 11, 2025The FTC is intensifying its focus on noncompete agreements in healthcare, urging employers to review contracts for compliance. While Ohio still generally enforces noncompetes, pending legislation could limit their use.Client Alert

Medicare Updates: Prior Authorizations and Physician Fee Schedule

September 8, 2025The Centers for Medicare & Medicaid Services (CMS) has announced two key updates effective January 1, 2026: a six-state prior authorization pilot program targeting high-risk services under the WISeR Model, and proposed revisions to the Physician Fee Schedule (PFS) that include increased payment rates, expanded telehealth coverage, and updated policies for chronic care, behavioral health, and rural providers.Client Alert

USCIS Policy Updates: Implications for Business Immigration

August 20, 2025In August 2025, USCIS issued three key policy updates enhancing vetting, good moral character (GMC) evaluations, and scrutiny of "anti-American" conduct in immigration adjudications. These policy memos will impact employers sponsoring foreign workers, including H-1B, L-1, EB visas, adjustments, and naturalization.Client Alert

Ohio Passes Antidiscrimination Provision for CRNA Reimbursement

August 14, 2025Ohio has passed House Bill 96, introducing a provider nondiscrimination provision that requires health plans to reimburse certified registered nurse anesthetists (CRNAs) at the same rate as physicians for the same services. The law aims to improve patient access to care by eliminating payment discrimination against CRNAs and will take effect on September 30, 2025.Client Alert

Ohio Board of Pharmacy | Administrative Code Rule Changes

July 16, 2025The Ohio Board of Pharmacy (“BOP”) recently posted notices of Ohio Administrative Code rule changes related to record keeping and the sale and distribution of certain ephedrine-containing products.
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