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Corporate Transparency Act: Business Owners Must Act Now

Client Alert

The Corporate Transparency Act (CTA) has been in effect since January 1, 2024. It is vital for reporting companies to file their beneficial ownership information (BOI) report before the year ends. Reporting companies formed prior to January 1, 2024, have less than six (6) months left to file. It is important to act now in order to avoid facing steep penalties for failing to comply with the CTA. Business owners should identify whether their company must report and if so, which individuals within the business entity are required to disclose the personal information designated under the CTA.

The CTA requires reporting companies to file a BOI report. Reporting companies must provide information regarding their entity, beneficial owners, and in some cases, the professional advisor(s) that helped form the entity. Reporting companies must submit the information to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). Domestic reporting companies include corporations, LLPs, LLCs, and other similar entities that were formed through a filing with the secretary of state or similar office under the law of a state. Foreign reporting companies are those formed under the law of another country and are registered to do business in any U.S. state through filing with a secretary of state or any similar office under the law of a state.

Under the CTA, reporting companies that were formed prior to January 1, 2024, have one (1) year to comply and file their beneficial ownership information report. Reporting companies formed in 2024, must file their report within ninety (90) days of their formation. Reporting companies formed on or after January 1, 2025, will have only thirty (30) days to file their report following their formation.

The purpose of the CTA is to safeguard the U.S. financial system from fraud, money laundering, and other illegal activities. There has been a concern in recent years that the U.S. has become a jurisdiction of choice for bad actors to create shell companies that hide the ultimate beneficiaries. Through the CTA, a national registry will be created that will allow the U.S. to obtain all relevant ownership information regarding reporting companies. The registry will enable the U.S. to crack down on illegal activity such as tax fraud, money laundering, terrorist financing, and more.

There are harsh penalties for reporting companies that fail to file a timely report to FinCEN. Civil and criminal penalties may result in fines up to $10,000, imprisonment for up to two (2) years, or both. Any person who (i) willfully provides or attempts to provide false/fraudulent information, or (ii) fails to report and/or update a report previously made, may be subject to the aforementioned penalties.

For more information about the CTA or how to comply, please contact BMD Member Blake Gerney at brgerney@bmdllc.com.


CMS Requires Providers to Use an Updated Advance Beneficiary Notice (ABN) Form by May 12, 2026

CMS has released an updated Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, that all providers and suppliers must begin using by May 12, 2026. The revised form includes clearer language and formatting updates intended to improve patient understanding and compliance.

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.