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Ohio Recovery Housing Overhaul: New Standards and Certification Requirements Reshape Sober Living Spaces

Client Alert

For years, the State of Ohio lacked uniformity over the operation of “recovery houses” — sometimes referred to as “sober living” spaces, “halfway houses,” and so on. Ohio law broadly defines these as residences “for individuals recovering from alcohol use disorder or drug addiction that provide an alcohol-free and drug-free living environment, peer support, assistance with obtaining alcohol and drug addiction services, and other recovery assistance for alcohol use disorder and drug addiction.” See R.C. 5199.01(A)(17). 

Operators could, for example, voluntarily obtain certification through the Ohio-certifying body or, alternatively, elect to run their recovery residence(s) with no oversight and/or certification — in turn, creating a statewide system of residential recovery spaces that provided inconsistent functions and standards. That system, however, is in the midst of a complete overhaul. 

Now, “recovery houses” (and all other similarly named residential recovery spaces) have statutory standards to satisfy pre-operation — a process which is a considerable undertaking. 

One new measure requires all existing recovery housing residences, as well as those intending to operate in the future, to register with the Ohio Department of Mental Health & Addiction Services (OHMHAS). Under Ohio law, existing operators were required to register on or before October 3, 2023; however, the form remains open for late filings and updates as necessary. Newly established recovery housing residences have a grace period of thirty (30) days from the start of their operation (i.e., the date on which the first resident occupies the residence) to complete the OHMHAS registration form. 

In addition to the OHMHAS registration requirement, effective January 1, 2025, the State of Ohio will begin enforcing new requirements which bar individuals and/or entities from operating, advertising, or even representing any residence as a “recovery housing residence, sober living home, or any other alcohol and drug free housing for persons recovering from alcohol use disorder” or substance use disorder without taking the appropriate certification steps through, without limitation, Ohio Recovery Housing or Oxford House, Inc. See R.C. 5119.39.

Certification is a substantial process — requiring, among other things, policies and procedures governing residents’ rights and responsibilities; a resident agreement and legally compliant leasing arrangement; and completion of, and compliance with, a checklist of pre-operation deliverables. 

The range of requirements as applied to the individual circumstances of each recovery housing operator can make identifying priorities and achieving compliance incredibly complex. For more information or for assistance navigating and completing the recovery housing registration and/or certification processes, please contact Monica Andress at (330) 253-9153 or mbandress@bmdllc.com.


CMS and Ohio Ramp Up Fraud Enforcement in Home Health and Hospice

CMS 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.

MYTH BUSTER: Can a New Chiropractor Bill Under An Established Chiropractor’s NPI?

Many 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.

RNs and APRNs Take Note: Ohio Board of Nursing Mandates a New CE Reporting Period

Ohio’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.

Ohio Med Spas: Peptide Do's and Do Not's

Recent 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.

Substance Use Disorder Providers: 42 CFR Part 2 Now Enforceable

Updates to 42 CFR Part 2 are now enforceable, bringing significant changes to how substance use disorder (SUD) records are handled. The Final Rule aligns Part 2 more closely with HIPAA, introduces updated penalties, allows a single patient consent for treatment, payment, and operations, and adds new requirements for Notices of Privacy Practices. It also creates a formal definition of SUD counseling notes and imposes strict consent requirements for their use and disclosure. Providers should review and update policies to ensure compliance.