Transcript
[Transcript] Episode 507: BOI Registration Requirement Reinstated: Update
Evan Dumas
You’re listening to Group Practice Tech, a podcast by Person Centered Tech, where we help mental health group practice owners ethically and effectively leverage tech to improve their practices. I’m your co-host, Evan Dumas.
Liath Dalton
And I’m Liath Dalton, and we are Person Centered Tech.
Liath Dalton
This episode is brought to you by Therapy Notes. Therapy Notes is a robust online practice management and electronic health record system to support you in growing your thriving practice. Therapy Notes is a complete practice management system with all the functionality you need to manage client records, meet with clients remotely, create rich documentation, schedule appointments and bill insurance all right at your fingertips. To get two free months of Therapy Notes as a new Therapy Notes user go to therapynotes.com and use promo code PCT.
Evan Dumas
Hello and welcome to Episode 507: BOI Registration Requirement Reinstated: Update.
Liath Dalton
Indeed. So you might be thinking, you were just talking about this BOI or Beneficial Ownership Information reporting requirement, and how it had been stayed by court action, and we’re in a current environment of deregulation, kind of, as the operating context when it comes to laws and regulations at the moment. But in a surprising turn of events which surprised not just us, but the National Law Review and folks at JD Supra, which is another excellent legal news source that we utilize a lot. They were surprised at this shift as well. But what does it mean?
Liath Dalton
It means that the reporting requirement has been reinstated. And that’s because of a February 18 court decision, and so the report reporting requirements are, once again back in effect.
Evan Dumas
Yeah.
Liath Dalton
So in less than a month, is it possible that there will be yet another court case that takes it back into a limbo state, and this reporting requirement doesn’t actually go into effect on the 21st of March, potentially.
Liath Dalton
But at this point, Evan, what is our guidance?
Liath Dalton
They are extending the reporting deadline, because initially it would have been in effect the beginning of the year. They’re kind of giving a 30 calendar day grace period, meaning that the new reporting deadline requirement with that extension is basically March 21.
Evan Dumas
Just take care of it. It takes 10 minutes. Like, this way, if we do another update podcast saying, Oh no, don’t worry about it. If you’ve already done it, you don’t have to worry about it. So just get it out of the way.
Evan Dumas
Mhm, yeah.
Liath Dalton
Exactly. It’s free. It should take 10 minutes or less, and then you don’t need to add this to the things that you are tracking in terms of requirements and changing regulation and how that impacts your practice.
Liath Dalton
Because, in part, there are other regulatory changes that are more consequential and going to require potentially more effort and action on your part, so in the interest of being able to judiciously allocate your precious resources of time and energy and attention and all of that, and preserve bandwidth as much as possible, just go ahead and file it. So we’ll include in the show notes the link to the guide for filing.
Liath Dalton
And then a really important note is, again, emphasizing it is free. It is not overly complicated by any means. So if we see another flurry of the sort of scam offers and trying to create urgency and fear and get you to either pay them to do it for you, or just be not the legitimate site, right, through FinCEN for the registration beware of those. Go directly through FinCEN.
Evan Dumas
Exactly.
Liath Dalton
So that’s our short little PSA of, oh, there’s a thing. It requires some small action, but once you take that action, it’ll be done, and you don’t have to worry about it at all. And can can move on to other more important things.
Liath Dalton
One of which we’ll be talking about in next week’s episode, which is related to some of the telehealth flexibilities under Medicare and changes to those that are currently due to take effect on March 31.
Liath Dalton
Not to worry. It doesn’t mean that telehealth is no longer going to be covered for behavioral and mental health care, just some pieces related to the in person evaluation requirements, and those potentially being reinstated, which they currently are set to to do. So, it doesn’t mean that telehealth coverage is going away. It doesn’t mean that we’re reverting to the old originating site requirements that really limited it, just the in person piece is what’s impactful.
Liath Dalton
So we’ll get into all the details of that. So those of you that are Medicare practices, or that’s a component of your practice and you’re doing telehealth, we’ve got you covered, and we’ll get into all the details of that.
Liath Dalton
All right, folks, thanks for joining us. Take good care, and we’ll talk to you next week.
Evan Dumas
Yeah, talk to you next week, everybody.
Liath Dalton
This has been Group Practice Tech. You can find us at personcenteredtech.com. For more podcast episodes, you can go to personcenteredtech.com/podcast, or click podcast on the menu bar.


Your Hosts:
PCT’s Director Liath Dalton
Senior Consultant Evan Dumas
Welcome solo and group practice owners! We are Liath Dalton and Evan Dumas, your co-hosts of Group Practice Tech.
In our latest episode, we have an update for you on the BOI registration requirements for business owners.
We discuss:
- The recent court decision which reinstated the requirement, and when it goes into effect
- What our current guidance is on this requirement (and why)
- Where to file
- Upcoming regulatory changes that will be more consequential for group practice owners, including changes to Medicare

Therapy Notes proudly sponsors Group Practice Tech!
TherapyNotes is a behavioral health EMR/EHR that helps you securely manage records, book appointments, write notes, bill, and more. We recommend it for use by mental health professionals. Learn more about TherapyNotes and use code “PCT” to get two months of free software.
*Please note that this offer only applies to brand-new TherapyNotes customers
Resources for Listeners
Resources & further information
Resources:
PCT Resources:
- PCT’s Comprehensive HIPAA Security Compliance Program (discounted) bundles:
- For Group Practices
- For Solo Practitioners
- PCT’s HIPAA Risk Analysis & Risk Mitigation Planning service for mental health group practices — care for your practice using our supportive, shame-free risk analysis and mitigation planning service. You’ll have your Risk Analysis done within 2 hours, performed by a PCT consultant, using a tool built specifically for mental health group practice, and a mitigation checklist to help you reduce your risks.
- Group Practice Care Premium
- weekly (live & recorded) direct support & consultation service, Group Practice Office Hours — including monthly session with therapist attorney Eric Ström, JD PhD LMHC
- + assignable staff HIPAA Security Awareness: Bring Your Own Device training + access to Device Security Center with step-by-step device-specific tutorials & registration forms for securing and documenting all personally owned & practice-provided devices (for *all* team members at no per-person cost)
- + assignable staff HIPAA Security Awareness: Remote Workspaces training for all team members + access to Remote Workspace Center with step-by-step tutorials & registration forms for securing and documenting Remote Workspaces (for *all* team members at no per-person cost) + more
Group Practices
Get more information about how PCT can help you reach HIPAA compliance while optimizing and streamlining your practice.
Solo Practitioners
Get more information about how PCT can help you reach HIPAA compliance while optimizing and streamlining your practice.