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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
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Governor Mike DeWine and The Ohio State University Introduce the SOAR Study on Ohio Mental Illness

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CHANGING TIDES: Summary and Effects of Burnett et. al. v. National Ass’n of Realtors, et. al.

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Employee or Independent Contractor? New Guidance Issued by the Department of Labor

January 10, 2024On January 9, 2024, the U.S. Department of Labor (DOL) issued its long-awaited final rule — effective March 11, 2024 — revising its prior interpretation of worker classifications under the federal Fair Labor Standards Act (FLSA). The new final rule rescinds the standard previously established in 2021, in turn, shifting the analysis of whether a worker is an employee (versus an independent contractor) of a business from a more streamlined “economic reality” test to a more complex “totality of the circumstances” standard.
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