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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
Client Alert

Counselor, Social Workers, and Marriage and Family Therapist (CSWMFT) Board Rule Changes

March 29, 2024The Counselor, Social Workers, and Marriage and Family Therapist (CSWMFT) Board has proposed changes to the Ohio Administrative Code rules discussed below. The rules are scheduled for a public hearing on April 23, 2024, and public comments are due by this date. Please reach out to BMD Member Daphne Kackloudis for help preparing comments on these rules or for additional information.Client Alert

Latest Batch of Ohio Chemical Dependency Professionals Board Rules: What Providers Should Know

March 25, 2024The Ohio Chemical Dependency Professionals Board recently released several new rules and proposed amendments to existing rules over the past few months. A hearing for the new rules was held on February 16, 2024, but the Board has not yet finalized them.Client Alert

Now in Effect: DOL Final Rule on Classification of Independent Contractors

March 21, 2024Effective March 11, 2024, the U.S. Department of Labor (DOL) has adopted a new standard for the classification of employees versus independent contractors — a much anticipated update since the DOL issued its Final Rule on January 9, 2024, as previously discussed by BMD.  In brief, the Fair Labor Standards Act (FLSA) creates significant protections for workers related to minimum wage, overtime pay, and record-keeping requirements. That said, such protection only exists for employees. This can incentivize entities to classify workers as independent contractors; however, misclassification is risky and can be costly.Client Alert

Florida's Recent Ruling on Arbitration Clauses

March 15, 2024Florida’s recent ruling on arbitration clauses provides a crucial distinction in determining whether such clauses are void as against public policy and providers may have the opportunity to include arbitration clauses in their patient consent forms. On March 6, 2024, Florida’s Fourth District Court of Appeals reversed and remanded Florida’s Fifteenth Circuit Court ruling of Piero Palacios v. Sharnice Lawson. The Court of Appeals ruled that the parties’ arbitration agreement did not contradict the Legislature’s intent of Florida’s Medical Malpractice Act (the “MMA”), but rather reflects the parties’ choice to arbitrate claims entirely outside of the MMA’s framework. Therefore, the Court found that the agreement was not void as against public policy.Client Alert

Corporate Transparency Act Update 3/14/24

March 14, 2024On March 1, 2024, a federal district court in the Northern District of Alabama concluded that the Corporate Transparency Act (“CTA”) exceeded Congressional powers and enjoined the Department of the Treasury from enforcing the CTA against the plaintiffs. National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.). On March 11, 2024, the U.S. Department of Justice appealed the district court’s decision to the Eleventh Circuit Court of Appeals.
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