The Corporate Transparency Act – A Series of the Latest Updates for Reporting Companies

The effective date of the Corporate Transparency Act and its corresponding rules promulgated by FinCEN was January 1, 2024.  In January 2023, we published an article that discussed the intent and importance of the CTA (available here).  The CTA may be a landmark piece of legislation that reshapes how certain entities report and disclose information…

The Eliminating Kickbacks in Recovery Act – Enforcement Trends & Effects on Employment Arrangements

The Eliminating Kickbacks in Recovery Act (“EKRA”) was enacted in 2018 in an effort to address fraud occurring in substance use disorder (“SUD”) treatment.  EKRA prohibits paying, receiving, or soliciting remuneration in return for patient referrals to laboratories, recovery homes, and clinical treatment facilities.[1]  Under EKRA, clinical treatment facilities are defined broadly to include, “a…

Emergency Rulemaking Expands AHCCCS’ Exclusion Authority

AHCCCS has broad authority to exclude participating providers from its program.  For example, AHCCCS may terminate a provider’s AHCCCS participation agreement if the provider fails to comply with their provider participation agreement, or with federal and state laws, rules, or regulations.  AHCCCS must also suspend payments pending an investigation of a “credible allegation of fraud”…

Are You Ready for June 27? New Federal Law Requires 8-Hour Training in Opioid Abuse Treatment

The Medication Access and Training Expansion (“MATE”) Act was signed into law on December 29, 2022. The Act applies to all “qualified practitioners” anticipating initial or renewal DEA registration on or after June 27, 2023.  A qualified practitioner is someone licensed under state law to prescribe controlled substances (excluding veterinarians). As part of the DEA…