VGM & ASSOCIATESHealthcare MSO
Full Menu Search

Corporate Transparency Act – Reporting Requirements for Certain Businesses in 2024

Published in Government Relations on January 23, 2024

Certain U.S. business types, including corporations and LLCs, are now required to submit reports regarding their ownership. Failure to submit these reports can result in both financial penalties and/or prison time. While this new reporting requirement is not specific to the DMEPOS industry, we know that several of our members’ companies will be subject to these new reporting requirements due to size and corporate structure, and we want to make sure those companies are aware of these new requirements and can take the necessary steps to avoid the monetary and criminal penalties associated with non-compliance.

The Corporate Transparency Act, enacted in 2021, held provisions that require certain business types to begin submitting reports in 2024 regarding the people who own, or directly/indirectly, control their business. These reports are called BOI (Beneficial Ownership Information) reports and will be submitted to an entity called FinCEN (Financial Crimes Enforcement Network). The reporting requirements begin in 2024 for some companies and 2025 for others. Failure to submit these reports if you are required to do so, or submitting false information within the reports, can result in 1) fines of up to $10,000 or a fine of $500 per day for each day of non-compliance, and 2) criminal penalties of up to two years in prison.

WHO IS REQUIRED TO REPORT?

U.S.-based corporations, limited liability companies (LLCs), and any other entities created by the filing of a document with a secretary of state or any similar office in the United States are required to submit BOI reports to FinCEN. There are, however, currently 23 specific exceptions regarding who has to submit reports, and those exceptions are outlined in section 1.2 of FinCEN’s published compliance guide found here. For example, one of the exemptions is for companies that have 20 U.S.-based employees and gross receipts totaling more than $5 million.

There will be no cost to businesses to submit these reports. They can be submitted electronically on FinCEN’s website.

WHEN ARE REPORTS REQUIRED TO BE SUBMITTED?

If your business is subject to the reporting requirements, the date your first report is due depends on when your company was created and registered to conduct business:

  • If your business was created or registered before Jan. 1, 2024, the deadline to submit your first report is Jan. 1, 2025.
  • If your business was created during calendar year 2024, you will have 90 days from whichever of the two dates comes first:
    • The date your company receives actual notice that its creation/registration is effective.
    • The date on which the Secretary of State, or similar office, first provides public notice of when the company was created or registered.
  • If your business was created after Jan. 1, 2025, you will have 30 days from whichever of the two dates comes first:
    • The date your company receives actual notice that its creation/registration is effective.
    • The date on which the Secretary of State, or similar office, first provides public notice of when the company was created or registered.

Below are some helpful resources to help you better understand these new requirements and whether your business is subject to them.

While this is not a DME industry-specific requirement, we know it will impact some of our members, and we want to make sure anyone who is subject to these requirements is aware of them and compliant with them. If you have any questions, please reach out to the VGM Government Payer Relations Experts at 800-642-6065.

TAGS

  1. vgm government

Get Connected

Stay up-to-date on the latest resources and news provided by VGM & Associates.

Sign Up for Email

From Our Experts

CMS Announces Registration and Bid Window Dates for Round 2028 of the DMEPOS Competitive Bidding Program thumbnail CMS Announces Registration and Bid Window Dates for Round 2028 of the DMEPOS Competitive Bidding Program Yesterday, CMS announced the Round 2028 bidding details with registration opening December 1, 2026, and the bid window opening January 5, 2027. The new Round 2028 timeline is as follows... Congratulations to CAMPS On This Important Legislative Victory thumbnail Congratulations to CAMPS On This Important Legislative Victory The signing of AB 1794 is another reminder of the critical role state associations play in shaping healthcare policy, removing barriers to patient care, and ensuring providers have a seat at the table when important decisions are made. Legislative successes like this do not happen by accident. They are the result of engaged members, strong advocacy efforts, and collaboration with policymakers to address real-world challenges facing providers and the patients they serve. S.247, Choices for Increased Mobility Act of 2025, Passes U.S. Senate thumbnail S.247, Choices for Increased Mobility Act of 2025, Passes U.S. Senate S.247, Choices for Increased Mobility Act of 2025 has passed in the Senate through unanimous consent. It now heads to the President to be signed into law. Introduced in the Senate by Sen. Tammy Duckworth (D-IL), The Choices for Increased Mobility Act of 2025 would... August Recess Recap: Building Relationships, Advancing Advocacy thumbnail August Recess Recap: Building Relationships, Advancing Advocacy As Congress worked through the August recess, the VGM Government Relations team remained actively engaged in securing meetings and building relationships with legislators, candidates, and key congressional staff across the country. This summer, the team made a strategic decision to focus getting a strong balance between Republican and Democratic offices, recognizing the importance of broadening support for DMEPOS priorities and ensuring policymakers from both parties understand the challenges.. Introducing Patient Voices: Access to HME Matters thumbnail Introducing Patient Voices: Access to HME Matters The VGM Government Relations team is excited to announce Patient Voices: Access to HME Matters, a new way for patients, providers, vendors, caregivers, and industry partners to share their experiences with home medical equipment. Every story matters. AAHomecare Survey Results of RID Program thumbnail AAHomecare Survey Results of RID Program Thank you to AAHomecare for initiating this important survey demonstrating the significant risks to the DMEPOS industry should Remote Item Delivery Competitive Bid Program (RID CBP) Round 2028 move forward as is. VGM Group is proud to support the survey efforts to maximize provider participation. See below for the survey summary and analysis. Competitive Bidding Update: NPEast and NPWest Updating Licensure Requirement Information for Competitive Bidding Product Categories thumbnail Competitive Bidding Update: NPEast and NPWest Updating Licensure Requirement Information for Competitive Bidding Product Categories Per the Remote Item Delivery Competitive Bidding Program (RID CBP) Round 2028 requirements, bidders must meet all business and product category licensure requirements across every state, the District of Columbia, and the U.S. territories to be eligible to be a contract winner. New CMS Nationwide Probationary Prior Authorization Requirement for Newly Enrolled Suppliers of Certain DMEPOS Items thumbnail New CMS Nationwide Probationary Prior Authorization Requirement for Newly Enrolled Suppliers of Certain DMEPOS Items On Sept. 2, 2026, CMS introduced the Probationary Prior Authorization (PPA) program that will place newly enrolled DMEPOS Suppliers and those undergoing 100% change in ownership on a one-year probationary period. Effective Oct. 15, impacted suppliers will be required to submit a prior authorization request for specific HCPCS codes.

Give your business an advantage over the competition.

Become a Member