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Ohio’s Managed Care Overhaul Delayed – New Implementation Timeline

Client Alert

At the direction of Governor Mike DeWine, the Ohio Department of Medicaid (ODM) launched the Medicaid Managed Care Procurement process in 2019. ODM’s stated vision for the procurement was to focus on people and not just the business of managed care. This is the first structural change to Ohio’s managed care system since the Centers for Medicare & Medicaid Services' (CMS) approval of Ohio’s Medicaid program in 2005. Initially, all of the new managed care programs were supposed to be implemented starting on July 1, 2022. However, ODM Director Maureen Corcoran recently confirmed that this date will be pushed back for several managed care-related programs.

What Caused the Delay?

Like many plans over the past two years, ODM’s rollout of the Next Generation of Managed Care was delayed partially as a result of COVID-19. The federal government is not expected to renew the public health emergency status beyond mid-July, which will trigger the required eligibility redetermination of millions of Medicaid beneficiaries. Until then, Medicaid is barred from removing anyone from the program while receiving enhanced federal matching funds provided in response to the pandemic. In order to minimize disruption for all Medicaid beneficiaries, the phased approach to introducing the new managed care system will allow time for the public health emergency to end and the new managed care plan coverage to begin. Additionally, ODM states that the staggered start will also promote continuity of care, limit confusion, and provide adequate time for provider testing and training.

The New Plan

Originally, ODM was supposed to roll out seven new managed care plans, centralized credentialing, a single pharmacy benefit manager, and a new managed care plan for multi-system youth called OhioRISE on July 1, 2022. For the reasons named above, ODM is now instituting a staggered start. Here is the new implementation schedule:

  • Stage 1, July 1, 2022 – OhioRISE: OhioRISE will provide care coordination and specialized services to help children and youth with behavioral health needs who receive care across multiple systems. The program builds on the launch of a statewide network of community-based care management entities; the design and implementation of the Child and Adolescent Needs and Strengths assessment tool; and the completion of extensive community and provider training sessions for more than 1,650 participants.
  • Stage 2, October 2022 – Centralized Provider Credentialing & Single Pharmacy Benefit Manager: Centralized Provider Credentialing (CPC) will provide a single place for provider credentialing rather than forcing providers to be credentialed with each individual managed care plan. Medicaid will implement CPC through the Ohio Medicaid Enterprise System (OMES) Provider Network Management (PNM) module, which aims to reduce administrative burdens on providers and will largely replace the current MITS system. Additionally, in Stage 2, the Single Pharmacy Benefit Manager (SPBM) will begin providing pharmacy services across all managed care plans and members.
  • Stage 3, 4th quarter of 2022 – Next Generation Managed Care Plans: ODM will finish the three-phase implementation with the opening of all seven Next Generation Managed Care Plans to provide healthcare coverage under the new program. ODM will also complete the OMES implementation by launching the Fiscal Intermediary (FI), which seeks to simplify and streamline the provider process for submitting claims and prior authorizations.

Incumbent plans will still continue to operate as usual, including UnitedHealthcare Community Plan of Ohio, Molina Healthcare of Ohio, CareSource Ohio and Buckeye Community Health Plan. New plans include Humana Health Plan of Ohio, AmeriHealth Caritas of Ohio and Anthem Blue Cross and Blue Shield. Patients will have the opportunity to stay with their current plan or switch to a new one.

If you have any questions about any of the new Medicaid programs and how they may impact your practice, please reach out to your local BMD Healthcare Attorney or Ashley Watson at abwatson@bmdllc.com.


New Ohio Reporting Requirements for Non-Residential Contractors

Ohio’s E-Verify Workforce Integrity Act, effective March 19, 2026, requires all nonresidential construction companies, subcontractors, and labor brokers to use E-Verify to confirm employee work eligibility on projects across the state. The law applies regardless of company size and carries financial penalties and potential restrictions on future state contracts for noncompliance. Some uncertainty remains around requirements for existing employees, making early compliance planning important.

DOT Non-Domiciled CDL Rule

A new rule from the Federal Motor Carrier Safety Administration (FMCSA) will significantly narrow eligibility for non-domiciled Commercial Driver’s Licenses (CDLs) beginning March 16, 2026. The rule limits eligibility to holders of H-2A, H-2B, and E-2 visas and eliminates Employment Authorization Documents (EADs) as qualifying proof of work authorization. As a result, many lawfully present and work-authorized immigrants, including refugees, asylees, DACA recipients, and Temporary Protected Status holders, will no longer be able to obtain or renew a non-domiciled CDL. The change is expected to affect roughly 194,000 drivers nationwide and has prompted multiple legal challenges, including a pending emergency stay request before the United States Court of Appeals for the District of Columbia Circuit.

FinCEN Residential Real Estate Reporting Rule Now in Effect

FinCEN’s new Residential Real Estate Reporting Rule, effective March 1, 2026, requires certain real estate transfers to be reported to combat financial crimes. Transfers of residential property to entities or trusts without financing may require a Real Estate Report.

Department of Education Proposes Redefinition of “Professional Degree,” Excluding Nursing and Limiting Graduate Loan Borrowing

The U.S. Department of Education has issued a Notice of Proposed Rulemaking that would redefine “professional degree” programs under the One Big Beautiful Bill Act. The proposal excludes nursing from the recognized list and would impose new borrowing limits for graduate students while eliminating the Grad PLUS program. Public comments are due by March 2, 2026.

First-of-Its-Kind Federal Ruling Finds Use of Consumer AI Tool May Destroy Attorney-Client Privilege

On February 10, 2026, Judge Jed Rakoff of the U.S. District Court for the Southern District of New York issued a first-of-its-kind ruling finding that documents generated by a criminal defendant using a consumer AI platform were not protected by attorney-client privilege after being shared with counsel. The court treated the AI tool as a third party, concluding that entering sensitive information into a publicly available platform may waive confidentiality. The ruling also suggests that the work product doctrine may not apply where AI-generated materials are created independently by a client rather than at counsel’s direction. The decision signals that parties should exercise caution when using consumer AI tools in connection with legal matters.