Legislation and Public Policy

On January 16, the U.S. Drug Enforcement Administration (DEA) announced three new telemedicine rules that extend prescribing flexibilities for controlled substances, following the expiration of temporary flexibilities granted during the COVID-19 pandemic. The new rules, which include both final and proposed regulations, aim to balance patient access with safeguards against misuse.

The rules apply only…

The Financial Crimes Enforcement Network (FinCEN) announced on Friday, January 24, that reporting companies are not currently required to file beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). Despite the recent decision by the Supreme Court of the United States (“SCOTUS”) to overturn the nationwide injunction of the CTA in connection with Texas…

The American Relief Act, 2025, signed into law on December 21, included a short-term extension of certain telehealth waivers that went into effect in the early days of the COVID-19 Public Health Emergency. These waivers, for telehealth services provided to Medicare beneficiaries, had been set to expire on December 31, but have now been…

In a new twist to the ongoing legal battle over the Corporate Transparency Act (CTA), the Fifth Circuit Court of Appeals has reinstated a nationwide injunction blocking its enforcement. The December 26 decision reverses a ruling issued just three days earlier that had briefly allowed the law to proceed, leaving businesses grappling with renewed uncertainty.…

On December 23, the Fifth Circuit Court of Appeals lifted the stay on the Corporate Transparency Act (CTA), reinstating its enforcement nationwide. The CTA requires certain non-exempt entities to report the identities of their beneficial owners to the U.S. Treasury Department in order to combat financial crimes such as money laundering and terrorism financing. But…

On November 20, 2024, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released the “Nursing Facility ICPG,” an industry-specific compliance program guidance for nursing facilities. 

Background

The Nursing Facility ICPG serves as a voluntary, nonbinding tool to assist facilities in reducing risks related to fraud, waste, and abuse, while…

The Law

The Corporate Transparency Act (the CTA), a law enacted by Congress requiring certain business entities to disclose beneficial ownership information (a BOI Report) to FinCEN, went into effect on January 1, 2024, and obligates reporting companies formed before January 1, 2024, to file BOI Reports on or before January 1, 2025.

The Challenge…

By January 1, 2025, millions of existing businesses must have filed certain information with the Financial Crimes Enforcement Network (FinCEN) to remain in compliance with the Corporate Transparency Act (CTA). As this deadline approaches, concern is growing among lawmakers. During a House Financial Services Committee hearing, committee members highlighted that many businesses have “no idea”…