Volume 24.04
In 2021, Congress enacted the bipartisan Corporate Transparency Act to curb illicit finance. This law requires many companies doing business in the United States to report information about who owns or controls them.
Effective January 1, 2024, many companies in the United States must report information about their beneficial owners – the individuals who own or control the company to the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury.
If your agency is operating as a corporation, limited liability company (“LLC”), or was otherwise created by filing a document with the Secretary of State, or any similar office, and has less than twenty full-time employees, you may be subject to the filing requirements.
Entities required to report must disclose beneficial owners. These are individuals who, directly or indirectly exercise substantial control or owners of at least twenty-five percent (25%) of the direct or indirect ownership interests in the reporting entity. The reporting rules are like reporting rules applicable to the Medicare enrollment process. Civil and/or criminal penalties may be imposed for failure to file or willingly report inaccurate data. Additional information is available at Small Entity Compliance Guide | FinCEN.gov
Tax-exempt agencies are generally exempt from the filing requirements.
If you have any questions regarding the applicability of these reporting requirements, please contact us at contact@healthgroup.com. If you are attending the upcoming NAHC Financial Management Conference in Las Vegas, visit us at Booth 217. While at the NAHC meeting, don’t forget to enter the drawing for a Yeti Cooler. You don’t have to pack it to take home, we will have it shipped directly to you.
HOME HEALTH RULE PUBLISHED
On June 26, 2024, the Centers for Medicare and Medicaid Services (“CMS”) issued the Proposed Rule regarding home health services payment rates for 2024. The proposed rule is available at 2024-14254.pdf (federalregister.gov).
The Proposed Rule proposes a net decrease in home health payments resulting in a reduction in Medicare payments of $280 million in 2025.
According to NAHC President, Bill Dombi, “The 2025 proposed version of Medicare home health payment rates shows the ongoing and predictable rate reductions impacting home health agencies since the beginning of the new payment model in 2020. That decline is solely due to a fatally flawed budget neutrality methodology that CMS employed to arrive at the rate adjustments.”
As is common, the Proposed Rule also includes various non-payment related provisions.
NAHC-NHPCO ALLIANCE
July 1, 2024, is the official first day of the NAHC-NHPCO Alliance. The two organizations, according to released information, will continue to operate separately in some areas through the end of 2024; however, they are now governed by a single body, the Transition Board. Although it is early, we expect to hear more about the efforts underway at the NAHC Financial Management Conference in Las Vegas. Registrations are still being accepted for the July 21-23, 2024, program at https://s23.a2zinc.net/