Resources

Client Alerts, News Articles, Blog Posts, & Multimedia

Everything you need to know about BMD and the industry.

Effective December 12, 2024: Key Updates to Ohio Medicaid Rules for CPC and CMC Programs

Client Alert
December 12, 2024

The Ohio Department of Medicaid (ODM) has amended Ohio Administrative Code rules related to the Comprehensive Primary Care (CPC) and Comprehensive Maternal Care (CMC) programs. The rules become effective December 12, 2024.

OAC 5160-19-01
Under the amended rule, a certified nurse midwife (CNM) is now an eligible provider that can participate in primary care activities or services in the CPC program. Previously, only certified nurse practitioners (CNPs) and clinical nurse specialists (CNS’) were permitted to participate. Additionally, upon annual enrollment, the CPC entity is expected to attest that it will provide 24/7 and same-day access to a PCP to the attributed Medicaid individual's medical record. Previously, the CPC entity had to provide record access within 24 hours of the initial request.

Now, under the amended rule, the CPC entity must ensure all staff who provide direct care or otherwise interact with attributed Medicaid individuals complete cultural competency training, as deemed acceptable by ODM, within 6 months of program enrollment. Previously, all staff had to complete the training within 12 months of enrollment.

The CPC entity must also ensure that new staff who provide direct care or otherwise interact with attributed Medicaid individuals complete cultural competency training within 30 days of their start date. Previously, new staff had 90 days from their start date to complete the training.

The amended rule added “well visits for members who are 15 to 30 months of age” to the list of clinical quality metrics the CPC entity must meet. The amended rule also added “well visits for members who are 15 to 30 months of age” and “oral evaluation/dental services” to the list of clinical quality metrics the CPC entity treating kids must meet.

OAC 5160-19-02
Under the amended rule, a CPC entity must continue to meet efficiency and clinical quality metrics and, if any of these metrics are not met in a program year, a warning will be issued. After two consecutive program years of a metric not being met, entity participation and payment will be terminated. Previously, this rule said that participation and payment will be terminated after two “warnings” instead of two “program years”.

OAC 5160-19-03
This CMC amended rule specifically changes “Medicaid eligible individuals” to “women” throughout. Under the community integration section, the rule adds new language requiring the CMC entity to “allow patients to have a doula of their choice at any pregnancy related service or appointment. Patients that procure or request the assistance of a doula as part of their prenatal, birth, or postpartum care will be supported by the practice in receiving doula services, including by providing a written recommendation for doula services to patients upon request.” The amended rule also adds “maternal behavioral health screenings (i.e., depression, anxiety, substance use disorder, etc.)” to the list of clinical quality metrics the CPC entity must meet.

If you have any questions about these rule changes or how they may impact your practice, please don’t hesitate to contact Member Daphne Kackloudis at dlkackloudis@bmdllc.com or Attorney Jordan Burdick at jaburdick@bmdllc.com for guidance.

Ohio Department of MedicaidHealth LawHealthcare
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.Client Alert

Immigration Orders and Their Economic Impact on Small Business: Insights from Attorney and Former Immigration Judge Rob Ratliff

January 30, 2025President Trump's recent executive orders, targeting immigration policies, could significantly impact small businesses in Ohio, particularly those owned by undocumented immigrants. With stricter visa vetting, halted refugee admissions, and potential deportations, these businesses face uncertainty, workforce disruption, and closures. Ohio's immigrant-owned businesses, especially in food services and transportation, contribute billions to the state economy, and any disruption could result in economic ripple effects.Client Alert

Corporate Transparency Act Ruling from the U.S. Supreme Court

January 24, 2025The U.S. Supreme Court recently ruled on the enforceability of the Corporate Transparency Act (CTA), lifting an injunction previously imposed by the Fifth Circuit. However, a separate nationwide injunction remains in effect, meaning businesses are still not required to comply with the CTA’s reporting requirements. FinCEN continues to accept voluntary reporting while enforcement remains paused.Client Alert

Lead Paint Contamination and Resources for Ohio Landlords

January 20, 2025Children are exposed to lead-based paint, which was used in most homes until it was banned in the US in 1978 and “can severely damage the brain and central nervous system causing coma, convulsions and even death.” Property owners and landlords should educate themselves on regulations and resources to mitigate their own liability.
Older posts