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

Client Alert

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.


Corporate Transparency Act Overhauled: U.S. Entities No Longer Required to Report

The Department of Treasury has issued an interim final rule significantly altering the Corporate Transparency Act (CTA). As of March 21, 2025, all U.S.-created entities and their beneficial owners are exempt from reporting requirements. Only non-U.S. entities registered to do business in the U.S. must still report, but they are not required to disclose U.S. citizen owners. Business owners should stay informed on these changes and consult legal counsel for compliance guidance.

ODM to Implement Medicaid Work Requirements: What Providers and Medicaid Expansion Recipients Need to Know

The Ohio Department of Medicaid (ODM) has submitted a waiver to impose work requirements for Medicaid expansion recipients. If approved, the new eligibility criteria will take effect on January 1, 2026. A federal public comment period is open until April 7, 2025.

Ohio Appellate Court Rules in Favor of Gender-Affirming Care

On March 18, 2025, the 10th District Court of Appeals in Franklin County ruled that Ohio’s House Bill (HB) 68, which restricts puberty blockers and hormone therapy for minors seeking gender-affirming care, violates the Health Care Freedom Amendment and is therefore unenforceable. The court found that the law unlawfully interferes with parental rights and medical decision-making. The case, Moe v. Yost, has been remanded, and Ohio Attorney General Dave Yost intends to appeal.

HHS Revokes Public Comment Requirement on Certain Policy Changes

The U.S. Department of Health and Human Services (HHS) has revoked the Richardson Waiver, eliminating the requirement for public notice and comment on certain policy changes. This decision allows HHS to implement new policies more quickly, potentially affecting healthcare funding rules like Medicaid work requirements. While it speeds up policymaking, it also reduces opportunities for stakeholder input, raising concerns over transparency and unintended consequences for healthcare providers, states, and patients.

Don't Get Caught Dazed and Confused: Another Florida Court Weighs in on Employer Obligations to Accommodate Medical Marijuana Use

A Florida trial court ruled in Giambrone v. Hillsborough County that employers may need to accommodate off-duty medical marijuana use under the Florida Civil Rights Act (FCRA). This contrasts with prior rulings and raises new compliance challenges for employers. With the case on appeal, now is the time to review workplace drug policies.