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CLIENT ALERT: Medicare Providers having multiple locations should verify and revalidate their address information to avoid claim denials

Client Alert

MLN Matters SE19007 “Activation of Systematic Validation Edits for OPPS Providers with Multiple Service Locations” notifies providers that Medicare is now requiring the exact match of all addresses for practice locations that are listed on provider claim submissions to Medicare. (See attached)

Medicare began auditing in July 2018 for purposes of reinforcing Chapter 1, Section 170 of the Medicare Claims Processing Manual “Payments on the MPFS for Providers with Multiple Service Locations.”  The exact address match will be in full and effect once the July 2019 quarterly release is implemented.

Claims that do not have an exact address match will be returned to the provider.  Providers can make corrections to their service facility address for a claim submitted in the DDE MAP 171F screen for DDE submitters.

It is recommended that providers review their Medicare enrollment record and billing practices to ensure compliance with the exact address match requirement.  Medicare recommends that all providers update their billing records to match Medicare enrollment records.  Providers should verify and submit changes through the CMS-855A or CMS-855B application through the Provider Enrollment, Chain, and Ownership System (PECOS) as soon as possible.  Changes and updates to an address or the addition of a new location typically take Medicare 30–60 days to process.

If you would like copies of the regulations, need legal assistance with updating your Medicare enrollment information, or have any questions concerning these matters, please contact Amanda Waesch at 330-253-9185 or via email at alwaesch@bmdllc.com.


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.

Your Golden Chance for H-1B Lottery Registration - March 2026

USCIS H-1B registration opens March 4–19, 2026. U.S.-based employees on valid nonimmigrant status are exempt from the $100,000 fee for change of status petitions. The new weighted lottery favors higher-skilled and higher-paid employees, improving odds for advanced degree holders and Wage Level 3 or 4 workers.