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

Client Alert
December 3, 2025

The Ohio Department of Medicaid (ODM) has proposed amending Ohio Administrative Code Rule 5160-1-60 related to covered Medicaid reimbursements for physicians. At a hearing held November 14, 2025, ODM received no comments on its proposed changes. Beginning on January 1, 2026, ODM is proposing an increase to rates for prenatal care, childbirth, and infant care and provider visits.

The following services are proposed to have increased max payments or will be covered for the first time:

  • H1000 TH* Prenatal care: at risk assessment ea addl (NEW)
  • H1001 Prenatal care: antepartum management
  • H1002 Prenatal care: care coordination
  • H1003 Prenatal care: individual education
  • S9452 Prenatal nutrition classes, non-physician
  • S9436 Childbirth prep/Lamaze classes, non-physician
  • S9437 Childbirth refresher classes, non-physician
  • S9444 Baby parenting classes, non-physician
  • S6127 Brief emotional/behave assmt
  • 99202 TH* Pre-natal office/outpatient visit, new
  • 99211 TH* Pre-natal office/outpatient visit, est
  • 99212 TH* Pre-natal Office/outpatient visit, est
  • 99213 TH* Pre-natal office/outpatient visit, est
  • 99381 Preventive visit, new, infant
  • 99382 Preventive visit, new, 1-4 yrs old
  • 99391 Preventive visit, estab, infant
  • 99392 Preventive visit, estab, 1-4 yrs old

To learn more about the proposed changes and updated Medicaid payment reimbursements, please contact BMD Healthcare Member Daphne Kackloudis at dlkackloudis@bmdllc.com or Attorney Jordan Burdick at jaburdick@bmdllc.com.

Ohio Department of MedicaidHealth Law
Client Alert

Corporate Transparency Act to be Re-evaluated

February 28, 2025Recent federal rulings have impacted the enforceability of the Corporate Transparency Act (CTA), which took effect on January 1, 2024. While reporting requirements were briefly reinstated, FinCEN has now paused enforcement and is reevaluating the CTA. Businesses are no longer required to submit reports until further guidance is issued. For updates and legal counsel, contact BMD Member Blake Gerney.Client Alert

Ohio Recovery Housing Operators Beware: House Bill 58 Seeks to Make Major Changes

February 26, 2025Ohio House Bill 58 proposes significant changes to recovery housing oversight, granting ADAMH Boards authority to inspect and investigate recovery residences. The bill also introduces a Certificate of Need (CON) program, requiring state approval for major facility changes. OMHAS will assess applications based on cost, quality, accessibility, and financial feasibility. The bill also establishes a recovery housing residence fund to support inspections. For more information, contact BMD attorneys Daphne Kackloudis or Jordan Burdick.Client Alert

January 2025 Notice of Proposed Rulemaking Brings Notable Changes to HIPAA Security Rule

February 25, 2025In January 2025, the U.S. Department of Health and Human Services proposed amendments to the HIPAA Security Rule, aiming to enhance cybersecurity for covered entities (CEs) and business associates (BAs). Key changes include mandatory compliance audits, workforce training, vulnerability scans, and risk assessments. Comments on the proposed rule are due by March 7, 2025.Client Alert

Corporate Transparency Act Effective Again

February 20, 2025The federal judiciary has issued multiple rulings on the enforceability of the Corporate Transparency Act (CTA), which took effect on January 1, 2024. Previously, enforcement was halted nationwide due to litigation in Smith v. U.S. Department of the Treasury. However, on February 18th, the court lifted the stay, reinstating the CTA’s reporting requirements. Non-exempt entities now have until March 21, 2025, to comply. Businesses should act promptly to avoid civil penalties of $591 per day and potential criminal liability.Client Alert

Status Update: Physician Noncompete Agreements in Ohio

February 11, 2025Noncompete agreements remain enforceable in Ohio if they meet specific legal requirements. While the AMA and FTC have challenged these restrictions, courts continue to uphold reasonable noncompete provisions for physicians. Recent cases, like MetroHealth System v. Khandelwal, highlight how courts may modify overly restrictive agreements to balance employer interests with patient care. With ongoing legal challenges to the FTC’s proposed ban, Ohio physicians should consult a healthcare attorney before signing or challenging a noncompete agreement.
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