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In healthcare, coding compliance isn’t just about accuracy—the true why behind it is to protect integrity, revenue, and trust. When hospitals and health systems need to develop an internal coding compliance audit plan, it’s important to focus on education, building a culture of accountability, and accuracy. Starting with the why will help staff understand the importance of proactive auditing. It’s far better to identify issues internally than to discover them during an external review. 

Assess your coding compliance process

After connecting staff and leaders to the “why” of proactive coding audits, assess current processes by asking: 

  • Where are the gaps?

  • Are coders supported with regular education?  

  • What topics have been covered?  

  • Is the education provided by an accredited source? 

  • When are the audits conducted (monthly, quarterly, yearly)? 

  • Are the audits conducted internally or from a vendor? 

  • Has a clear baseline been established to make it easier to design an effective, realistic plan? 

Key ingredients for a good audit plan 

Every good audit plan should define the what, how, who, and why: 

  • What services will be audited and why? 

  • How often will audits be conducted and what triggers expanded audits?  

  • How will results be communicated with staff? 

  • Who is responsible for implementing corrective action plans? 

  • Why is this audit being conducted? (Is it based on payer denials or has an internal issue been identified?) 

Corrective action plans and oversight

While conducting audits and reporting findings is essential, it is equally imperative to implement documented, corrective action plans to ensure that any identified deficiencies are properly addressed and resolved. Throughout this process, establishing a strong partnership with the revenue cycle team can be invaluable, especially for managing rebilling, processing refunds, or addressing charge master discrepancies.  

This collaborative approach helps drive meaningful improvements and supports the overall integrity of the organization’s compliance efforts. Once corrective action plans are in place, ongoing monitoring is crucial to verify their effectiveness and to ensure that identified issues do not recur. Continuous oversight not only validates the success of corrective actions but also reinforces a culture of sustained compliance and accountability. 

Strengthen your organization with an audit plan

In the Health Care Compliance Association’s® 2025 Healthcare Industry Compliance Staffing & Budget Benchmarking Survey, more than half of publicly traded healthcare organizations reported annual compliance budgets of $1 million or more—reflecting the investment being made in compliance functions, which typically includes audits, monitoring, etc. This seems like a hefty budget, but the key here is scalability. Healthcare organizations across the care continuum, regardless of size or tax status, should focus on developing a reasonable, risk-focused plan. 

Remember, an audit plan isn’t a one-time project. It’s an ongoing process that evolves with regulatory and payer policy changes, new technology implementations, and organizational growth. Even more important than adapting to these changes is fostering a non-punitive culture. The goal isn’t to assign blame; it’s to strengthen accuracy, compliance, and confidence across the organization. 

BerryDunn can help

BerryDunn’s healthcare compliance team includes experts in coding, auditing, clinical documentation improvement, and revenue integrity. We can assess or develop your organization’s coding compliance audit plan, perform regular audits, and provide coder or provider education. Reach out to learn more about our team and services.  

Article
How to build a strong healthcare coding compliance audit plan

The affordable housing landscape in the United States is on the cusp of significant change with the introduction of the Renewing Opportunity in the American Dream (ROAD) to Housing Act of 2025. For nonprofit organizations operating in the affordable housing sector, this proposed legislation brings both new opportunities and important considerations. Here’s what you need to know. 

What is the ROAD to Housing Act? 

The ROAD to Housing Act is a comprehensive bill designed to increase the supply of affordable housing across America. It addresses barriers to housing development, modernizes regulatory frameworks, and introduces new funding and incentive programs. The Act is broad, touching everything from financial literacy to manufactured housing, disaster recovery, and homelessness reduction. 

Key provisions affecting nonprofits 

Expanding housing supply and streamlining development: 

  • Rental Assistance Demonstration (RAD) expansion: The Act extends and enhances the RAD program, allowing more public housing units to convert to long-term, project-based Section 8 contracts. This is a major opportunity for nonprofits to participate in preservation and redevelopment projects with more stable funding streams. 

  • Incentives for building in opportunity zones: HUD may give priority to grant applicants serving Opportunity Zones, potentially increasing funding access for nonprofits working in these areas. 

  • Whole-Home Repairs Act: Grants will be available to nonprofits and local governments to repair and rehabilitate homes for low- and moderate-income homeowners and small landlords, with a focus on accessibility, safety, and energy efficiency. 

Regulatory reform and local zoning: 

  • Housing Supply Frameworks Act: The Act directs HUD to develop best practices and guidelines for state and local zoning reforms, encouraging the reduction of barriers such as restrictive zoning, parking minimums, and lengthy permitting processes. Nonprofits may find it easier to develop affordable housing as localities adopt these reforms. 

  • Streamlined environmental reviews: The Act simplifies environmental review requirements for certain HUD-funded activities, which could reduce project timelines and administrative burdens for nonprofit developers. 

Manufactured and modular housing: 

  • Modernization and parity: The Act updates definitions and standards for manufactured and modular homes, aiming to expand their use as affordable housing solutions. Nonprofits may see new opportunities to develop or manage these types of housing, especially in rural or high-cost areas. 

Funding and grant programs: 

  • Innovation Fund: Competitive grants will reward localities that demonstrate measurable increases in housing supply, with eligible uses including infrastructure, planning, and direct housing development. Nonprofits may partner with local governments to access these funds. 

  • Community Investment and Prosperity Act: Expands the ability of community development financial institutions (CDFIs) and nonprofits to support affordable housing and community revitalization. 

Homelessness and supportive services: 

  • Reducing Homelessness Through Program Reform: The Act streamlines and enhances funding for homelessness prevention, rapid rehousing, and supportive services, with a focus on coordination between housing and healthcare providers. Nonprofits specializing in these services may benefit from increased flexibility and resources. 

Opportunities for the affordable housing industry and nonprofits 

  • Increased funding and flexibility: More grant programs and streamlined regulations mean nonprofits can access new resources and deliver projects more efficiently. 

  • Partnerships and collaboration: The Act encourages partnerships between nonprofits, local governments, and private developers, especially in Opportunity Zones and through RAD conversions. 

  • Focus on preservation: Emphasis on repairing and preserving existing affordable housing stock aligns with the missions of many nonprofits. 

Challenges for the affordable housing industry and nonprofits 

  • Compliance and reporting: With new funding streams come new compliance requirements, especially around performance measurement, reporting, and public accountability. 

  • Capacity building: Nonprofits may need to invest in staff training and systems to take advantage of new programs, particularly those involving modular/manufactured housing or complex financing. 

  • Local adoption of reforms: Many benefits depend on state and local governments adopting HUD’s recommended zoning and permitting reforms. Advocacy may be needed to ensure these changes are implemented at the local level. 

What should nonprofits do now? 

  • Stay informed: Monitor the progress of the ROAD to Housing Act and related HUD guidance. 

  • Assess readiness: Evaluate your organization’s capacity to participate in new grant programs or RAD conversions. 

  • Engage locally: Work with local governments to advocate for zoning and permitting reforms that will unlock new development opportunities. 

  • Build partnerships: Explore collaborations with other nonprofits, CDFIs, and public agencies to maximize impact. 

The importance of the ROAD to Housing Act 

The ROAD to Housing Act represents a significant federal commitment to expanding affordable housing and supporting the organizations that make it possible. Nonprofits in the affordable housing sector should prepare to leverage new opportunities, adapt to evolving compliance requirements, and continue their vital work in building stronger, more inclusive communities. 

BerryDunn can help 

We understand that affordable housing organizations are unique and dynamic organizations with specific challenges and opportunities. Our commitment to specialization provides our clients with a team of specialists who understand the complex accounting, regulatory, and tax issues of affordable housing organizations. We have experience with affordable housing agencies subject to audits under both FASB and GASB, as well as the various tax credits available, HUD compliance, annual Real Estate Assessment Center (REAC) submissions, and other compliance matters. Learn more about our team and services. Reach out to discuss how your organization can prepare for the upcoming changes. 

Article
ROAD to Housing Act: What affordable housing nonprofits need to know

Read this if you are a CEO, CFO, or COO at a Federally Qualified Health Center (FQHC). 

This article is the second in a three-part series to help FQHCs understand how site- and program-specific accounting is essential to sustainability. Next up: Gaining operational insights on programs and sites from your data.

Site- and program-specific accounting can be a lifeline to FQHCs struggling with sustainability by providing a more granular look into operations. This approach allows an FQHC to gain key insights into the performance of its programs and sites and use those insights to make data-driven decisions to improve operations. To implement this method, an FQHC must set up its general ledger (GL), payroll, and Electronic Health Record (EHR) systems to report at the appropriate level of detail so that data flows cleanly into its accounting system. 

Step 1: Restructuring your general ledger 

The first step is to fine-tune the GL. This requires defining all programs and sites in the GL and creating processes for identifying expenses so that you can begin to record them accordingly. Programs and sites need to be set up to include a general administrative program, along with a mechanism to ensure those administrative costs are coded into that cost center. It’s imperative to establish a consistent allocation method for applying those overhead costs to the respective programs and sites. This will give you the gross margin for each program and site. Overhead costs, which are generally fixed, must also be factored in to give a view of your bottom-line profitability. 

Having this level of insight into programs and sites gives FQHCs a clearer view to determine strengths, weaknesses, and opportunities for maximizing efficiencies and operational effectiveness. This data helps an FQHC model what is possible and make informed operational decisions. 

Step 2: Modifying your payroll data 

Next, an FQHC must adjust its payroll system setup. Payroll data is typically exported to generate journal entries for recording in the GL or is uploaded directly to the GL. The same principles for identifying programs and sites apply to payroll. While the GL is the easiest route to refining payroll setup, an entity may not be able to define sites due to limitations on the number of labor distribution elements in its payroll system. Another option is to export payroll data into Excel and use lookup tables that denote an employee’s role (i.e., medical provider, dental provider, behavioral health provider) and location, so that their salaries can be assigned to the appropriate program and site. Using the Excel spreadsheet, an FQHC can generate a journal entry by site and program and then upload it to the GL. This is often the easiest and most effective method.  

If an entity has a payroll system that can be defined at this level of site- and account-specific detail, that is another possible route. However, this approach requires significant upfront and ongoing resource commitment, and many smaller entities do not have the bandwidth to dedicate staff and time to configure and maintain the system, which often makes it impractical. 

Step 3: Setting up your EHR 

The third step is to record patient service revenue by program and by site. This requires structural adjustments within the EHR system to clearly define programs and sites. Once set up, EHR reports can be exported to generate revenue entries that are uploaded to the GL. Expenses can be viewed by program and site, indicating profitability and providing visibility into the ROI of providers. Looking at patient revenue less direct expenses serves as a good measurement tool.  

How much data is enough? 

With processes in place and systems modified appropriately, an entity can start measuring profitability with a greater level of detail. When generating financial statements for the month, additional income statements by program and site should also be produced, which makes viewing data monthly a good starting point.  

A month’s worth of data helps an entity uncover if one site or program is excelling, or others are underperforming or have higher costs. A closer look can reveal how success in one program might be replicated in others, or how a high-performing site could be masking the failure of another site. Site- and program-specific accounting supplies the data needed to support key decisions related to programs and sites.  

About BerryDunn 

Faced with rapid changes in an increasingly competitive environment, community health centers rely on our seasoned professionals to refine business strategies, streamline operations, and introduce proven best practices to enhance performance while managing costs. Our team works with a comprehensive range of community health providers, including FQHCs, FQHC Look-Alikes (LALs), and Rural Health Clinics (RHCs). Learn more about our team and the services we provide. 

Article
Three steps to modify accounting for FQHC sustainability

November 25, 2025 updateOn November 25, 2025, the FDIC finalized its regulatory threshold updates rule. As mentioned in an FDIC press release, “the changes set forth in the final rule provide a more durable framework preserving certain regulatory thresholds in real terms, thereby avoiding unintended and undesirable consequences.” Although effective January 1, 2026, the final rule provides immediate burden relief to insured depository institutions that are currently subject to part 363 requirements but will no longer be subject to such requirements under the updated thresholds in effect as of January 1, 2026.

Originally published on August 29, 2025

The FDIC has proposed raising several key regulatory thresholds, including those that determine which institutions must comply with Part 363’s audit and internal control requirements. The primary driver behind these proposed changes is the growth experienced by institutions since the original thresholds were set decades ago. Due to inflation, the proposal aims to cover a similar number of institutions as when the thresholds were originally set. For example, the proposed increase to $5 billion for the Internal Control over Financial Reporting (ICFR) threshold, as described below, would still cover approximately 75% of institutions today.  

In addition to increasing these thresholds, the proposal also recommends that the thresholds be automatically adjusted based on some inflationary factors going forward. While the changes are designed to ease compliance burdens for smaller institutions, they also come with a cautionary tale—they would reduce regulatory requirements, but not the risk. 

What the FDIC proposal means 

Under the proposal

  • Approximately 800 institutions may find themselves newly exempt from Part 363 compliance due to changes in 24 regulatory asset thresholds. The following items are the most likely to be relevant for community banks:

    • Banks under $1 billion in total assets would no longer be required to: 

      • Create a separate audit committee as part of the institution’s board of directors

      • File annual reports 

    • Banks under $5 billion would no longer need to: 

      • Include management assessments or auditor attestations on ICFR 

      • Require the audit committee directors to be independent from management 

      • Require the audit committee directors to include members with banking or related financial management expertise, have access to its own outside counsel, or exclude large customers of the institution 

    • Audit committee independence criteria would increase from $100,000 to a $120,000 compensation threshold. This threshold would not be indexed against inflation as it is meant to align with the listing standards of national securities exchanges. 

  • Parts 303, 335, 340, 347, and 380 would also have changes if this proposal is enacted: 

  • Part 303 – de minimis thresholds: 

  • Increased from $1,000 to $1,225 and from $2,500 to $3,500 for certain criminal offenses 

  • Part 335 – Insider loan disclosures: 

  • Raised the threshold from $5 million to $10 million 

  • Parts 340 & 380 – Asset sales restrictions: 

  • Raised the “substantial loss” threshold from $50,000 to $100,000, which could allow an increase in potential bidders who are eligible to purchase failed institution assets 

  • Part 347 – International banking: 

  • Raised limits for foreign underwriting and dealing from $60M to $120M and from $30M to $60M. This is less likely to have an impact unless you have foreign operations. 

Why ICFR still matters for community banks 

Even without a federal mandate, effective ICFR offers tangible benefits: 

  1. Fraud prevention: Segregation of duties, account reconciliations, and control monitoring are critical to detecting and preventing fraud—especially in lean staffing environments. 

  1. Operational efficiency and reducing material misstatements: ICFR can help identify process inefficiencies and reduce errors. It can also help with training, as processes tend to be more clearly documented when they are being tested on an ongoing basis. 

  1. Regulatory confidence: Examiners still expect clear documentation of key controls and risk assessments—even if an ICFR opinion is no longer required. 

  1. Merger and acquisition readiness: Strong internal controls enhance bank value in due diligence settings, especially in today’s consolidation-driven environment. 

  1. Board-level accountability: Internal controls provide visibility into operational risk that supports informed governance and oversight. 

  1. Preparing for the next threshold: Many hours have been spent getting your documentation ready for audits, including creating, updating, and monitoring your internal controls. Walking away from the effort already put forth would mean a significant amount of time and resources to re-establish your documentation and controls as you prepare for the next threshold. Keeping your current internal practices in place with annual updates and regular monitoring will help make that next transition as smooth as possible. 

What we recommend 

For banks that would be newly exempt under the FDIC’s proposed changes, we suggest a right-sized, risk-based approach

  • Maintain documentation of your key accounting controls and processes, including reconciliations, journal entries, and credit loss provisioning. This documentation should be updated at least annually by control owners. 

  • Conduct periodic walkthroughs of high-risk processes (e.g., wire transfers, loan approvals) to identify gaps, inefficiencies, and areas of documentation that need to be updated. 

  • Leverage internal or outsourced testing of controls. The frequency of this testing will likely be dependent on your institution’s risk assessment of each operational area. 

  • Educate your board on how ICFR practices support accountability, even without formal reporting requirements. 

  • Create a compliance checklist related to threshold changes to stay up-to-date with compliance requirements going forward: 

  • Indexing monitoring plan 

  • Establish a process to track inflation-based threshold changes: 

  • Every 2 years, or 

  • More frequently if the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) rises above 8%. Thresholds will not be reduced in deflationary periods. 

  • Assign responsibility for monitoring CPI-W and updating compliance scope 

  • Governance and board oversight 

  • Reassess audit committee composition and independence under new thresholds 

  • Review director compensation against the $120,000 independence threshold 

  • Document any changes to board and/or audit committee structure or oversight responsibilities 

  • Audit planning adjustments 

  • Revise audit scope and frequency based on updated regulatory requirements 

  • Coordinate with external auditors to align expectations and engagement terms 

  • Adjust risk assessments to reflect changes in compliance burden and oversight 

  • Reporting and documentation 

  • Ensure proper documentation of decisions not to file Section 19 applications due to new thresholds 

  • Maintain records of threshold applicability reviews and indexing updates 

  • Prepare for potential regulatory inquiries regarding compliance scope changes 

  • Stakeholder communication 

  • Brief the board on regulatory changes, compliance impacts, and audit committee implications 

  • Provide training or guidance to relevant teams (e.g., HR, compliance, finance) 

Final thoughts 

We understand the burden of ICFR compliance—and for many small banks, the relief reduces their already heavy regulatory burden. However, a move to step away from a well-established control environment has the potential to create downstream issues you might not see until it’s too late. 

Strong internal controls are not just a box to check for regulators and auditors—they're a tool for protecting your institution, your people, and your reputation. Regulators, investors, and auditors still care about the strength of your bank’s control environment—whether or not it's required by regulation. 

Maintaining strong internal controls remains a best practice—and a strategic imperative. Both are essential to your bank’s resilience, integrity, and long-term success. 

Let’s talk 

If your bank is approaching a new threshold or deciding whether to scale back ICFR documentation, we’d love to help you build a right-sized internal control approach that matches your risk profile. Reach out to our team with questions. 

Article
FDIC Proposal: How community banks can adopt a right-sized risk-based approach

Liquidity is the lifeline of any nonprofit organization. Strong liquidity ensures uninterrupted programs, financial stability, and the flexibility to respond to unexpected challenges. This article shares practical steps to monitor and manage liquidity effectively, including setting clear policies, tracking cash flow, using key financial ratios, managing reserves, and leveraging technology. By following these best practices, organizations can maintain resilience, build trust with stakeholders, and stay focused on their mission—even during uncertain times. 

What is liquidity and why it matters 

Liquidity refers to your ability to pay the bills on time, every time. For nonprofits, strong liquidity means uninterrupted programs, happy staff, and the flexibility to handle unexpected challenges. Weak liquidity? That’s like running a marathon without water stations. It’s not pretty. 

Building a solid foundation 

Start with a clear liquidity policy. Define minimum and target levels. Many organizations aim for at least three months of operating expenses. Spell out who monitors compliance and what happens if thresholds aren’t met. A written policy avoids panic and promotes accountability. 

Next, keep an eye on cash flow. A rolling forecast is your financial weather report. Update it monthly—or weekly during uncertainty—to project inflows like grants and donations and outflows like payroll and rent. Comparing actual results to forecasts helps you spot gaps early and act before they become crises. 

Know your numbers 

Ratios tell the story. The current ratio (current assets divided by current liabilities) shows if you can cover short-term obligations; aim for above 1.0. The operating reserve ratio (unrestricted net assets divided by annual expenses) measures your ability to weather revenue shortfalls. Tracking these trends over time helps you plan. 

Operating reserves are your safety net. Target three to six months of expenses and keep funds accessible. Require board approval for use because rainy-day money shouldn’t fund sunny-day shopping. 

Stay on top of receivables and payables 

Stay up to date with accounts receivable billing and collections, and make sure to collect pledges promptly. Manage your accounts payable smartly. Work to align payments with cash inflows and negotiate terms when needed. These habits prevent liquidity bottlenecks and keep relationships strong. 

Understand restrictions and communicate 

Restricted funds aren’t for general expenses, so track them carefully to avoid compliance headaches. Review donor agreements regularly—because “oops” isn’t a strategy. And don’t keep liquidity conversations behind closed doors. Share updates with your board and key stakeholders. Transparency builds trust and can even spark extra support when times are tight. 

Use technology to your advantage 

Modern financial tools can automate forecasts, flag risks, and provide real-time dashboards. Cloud-based systems make oversight easier and reduce manual errors, giving leadership the data they need to make smart decisions. 

When liquidity gets tight 

Act fast: accelerate receivables, negotiate with vendors, cut discretionary spending, and explore bridge financing or emergency grants. Planning ahead beats scrambling later. 

Monitoring liquidity isn’t about fear; it’s about freedom. Freedom to seize opportunities, weather storms, and keep your mission strong. With these practices, your organization can stay resilient and focused on impact. 

BerryDunn can help 

Our nonprofit experts bring a clear understanding of nonprofit funding, in-depth knowledge of complex compliance requirements, and the industry-specific knowledge necessary for accurate, complete financial reporting. That knowledge informs our work—and enhances your performance by addressing your most important operational challenges. Our team applies industry best practices to help move your organization forward. We provide strategic, financial, and operational support tailored to your mission. Learn more about our team and services.  

Article
Best practices for monitoring liquidity in a nonprofit

The Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) 2025-08 in November 2025 to address stakeholder concerns regarding the accounting for acquired financial assets under current US GAAP. This update specifically amends the guidance for purchased loans, aiming to improve comparability, consistency, and decision usefulness in financial reporting.

Key differences from current US GAAP  

Under existing US GAAP (Topic 326), acquired financial assets are classified as either:  

  • Purchased Credit Deteriorated (PCD) assets: Accounted for using the “gross-up approach,” which recognizes an allowance for expected credit losses (ACL) at acquisition, offset by a gross-up adjustment to the purchase price.
  • Non-PCD assets: Recognized at fair value with an ACL charged to credit loss expense, which is seen as double counting expected credit losses.  

ASU 2025-08 expands the use of the gross-up approach to a broader population of acquired loans, specifically “purchased seasoned loans.” These are defined as loans (excluding credit cards) acquired without significant credit deterioration and deemed “seasoned”—either obtained in a business combination or purchased at least 90 days after origination, provided the acquirer was not involved in the origination.  

This change eliminates much of the complexity and subjectivity in distinguishing between PCD and non-PCD assets and reduces the risk of double counting expected credit losses that are already reflected in fair value measurements determined at the time of acquiring the financial assets. 

Effective date for ASU 2025-08 

ASU 2025-08 is effective for all entities for annual reporting periods beginning after December 15, 2026, and interim periods within those annual periods. Early adoption is allowed.  

Transition methods 

The amendments must be applied prospectively to loans acquired on or after the initial application date. Early adoption is permitted for interim or annual reporting periods in which financial statements have not yet been issued or made available for issuance. If adopted in an interim period, the amendments should be applied as of the beginning of that interim period or the annual period that includes it.  

Rationale and benefits 

The FASB’s post-implementation review revealed that the dual approach for PCD and non-PCD assets under current US GAAP created unnecessary complexity, reduced comparability, and did not accurately reflect the economics of acquired financial assets. The gross-up approach, now expanded to purchased seasoned loans, better aligns accounting with the economic reality that the fair value of acquired assets already incorporates expected credit losses. This method:  

  • Enhances comparability and consistency across entities.  
  • Reduces complexity and subjectivity in acquisition accounting.  
  • Minimizes the “double count” of expected credit losses, improving the usefulness of financial information for investors and other stakeholders.  
  • Is expected to reduce costs and operational burdens associated with the previous model. 

Journal entry examples 

The following journal entries are meant to display the differences in accounting for acquired loans as a result of ASU 2025-08. Thus, this is a simplified example. Acquisition accounting, particularly for business combinations, tends to be much more complex. Stay tuned for additional resources on acquisition accounting. 

Before ASU 2025-08 (current US GAAP)  
 

A. Purchased Credit Deteriorated (PCD) loan (gross-up approach)  

At acquisition: 

  • Record the loan at purchase price (fair value).  
  • Recognize an ACL.  
  • Increase the fair value by the ACL.   

Journal Entry: 

Dr. Loan Receivable                                          $1,000,000 
          Cr. Cash                                                                        $950,000 
          Cr. Allowance for Credit Losses                                    $  50,000 

(Assume purchase price is $950,000 and ACL is $50,000) 

B. Non-PCD loan (day-one expense approach)

At acquisition: 

  • Record the loan at purchase price (fair value).  
  • Recognize an ACL with a charge to credit loss expense.  

Journal Entry: 

Dr. Loan Receivable                                    $950,000 
Dr. Credit Loss Expense                              $  50,000 
             Cr. Cash                                                                      $950,000
             Cr. Allowance for Credit Losses                                  $  50,000 

(Here, the ACL is recognized as an expense, not as a gross-up to the loan balance.)   

After ASU 2025-08 (for purchased seasoned loans) 
 

All purchased seasoned loans (excluding credit cards) are accounted for using the gross-up approach, regardless of credit deterioration. 

At acquisition: 

  • Record the loan at purchase price (fair value).  
  • Recognize an ACL.  
  • Increase the fair value by the ACL.    

Journal Entry: 

Dr. Loan Receivable                                           $1,000,000 
                 Cr. Cash                                                                  $950,000 
                 Cr. Allowance for Credit Losses                              $  50,000   

(Same as the PCD approach but now applied to a broader population of acquired loans.)  

Improvement in accounting for acquired loans


In summary, ASU 2025-08 represents a significant improvement in the accounting for acquired loans, providing more meaningful and decision-useful financial reporting while streamlining the application of credit loss standards. Although not seen as a cost-burdensome ASU to adopt, as most information needed to adopt the ASU should be readily available, the ASU does introduce a new concept, namely, purchased seasoned loans. Thus, those impacted by the ASU should start assessing its impact now, especially given early adoption may be seen as favorable since the ASU is expected to reduce complexity compared to current US GAAP.  

As always, your BerryDunn team is here to help. Learn more about our team and services, and reach out with questions on the ASU or acquisition accounting. 

Article
How purchased seasoned loans & ASU 2025-08 impact acquisition accounting

On November 5, 2025, the US Supreme Court heard arguments in Learning Resources, Inc. v. Trump, a case that challenges President Trump’s authority to impose tariffs under the International Emergency Economic Powers Act (IEEPA). If the presidential power to impose tariffs is ruled unconstitutional, importers could qualify for duty refunds and must act fast. A decision is anticipated in late 2025 or early 2026. 

Background 

Under IEEPA, the President may act to address any unusual or extraordinary foreign threat that endangers national security, foreign policy, or the economy in the US. This authority applies only if the President declares a national emergency. Trump declared such an emergency on April 2, 2025, citing the trade deficit and illegal immigration. Since February 2025, the Administration has imposed significant tariffs under IEEPA, including: 

  • 10% minimum tariff on most imports 
  • 50% tariff on copper, steel, and aluminum 
  • 20 – 40% tariffs on most goods from Brazil, India, Canada, Mexico, and China 

President Trump’s use of IEEPA to impose tariffs has raised constitutional concerns. Challengers to this authority argue that IEEPA does not authorize the imposition of tariffs and that only Congress may regulate foreign commerce. 

Key actions for importers 

If the Court finds the presidential power to impose tariffs unconstitutional, importers may be eligible for refunds of duties already paid. However, refund eligibility will depend on timely administrative actions. To prepare, importers should: 

1. Review import activity 
     Identify entries that were subject to IEEPA tariffs. 

2. File administrative protests
    
Submit CBP Form 19 protests within 180 days of each entry’s liquidation. 

3. Prepare for possible litigation 
     If protests are denied, consider filing suit with the US Court of International Trade. 

How BerryDunn can help

Our dedicated audit, tax, and consulting professionals understand the impact of tariffs and can assist with developing strategies for refunds as they become available. Learn more about our team and services.  

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Supreme Court reviews presidential tariff authority: Insights for importers

Read this if you are a CEO, CFO, controller, or finance team leader in the manufacturing industry. 

In a time when operational efficiency and sustainability are more critical than ever, small- and medium-sized manufacturers (SMMs) face a unique challenge—how to modernize without breaking the bank. Fortunately, the US Department of Energy (DOE) offers a solution through its Industrial Assessment Centers (IACs) Program—an initiative that combines expert guidance with financial support to help manufacturers thrive. 

What are IACs? 

IACs are university-based teams that provide free, in-depth energy assessments to eligible manufacturers. These assessments are conducted by engineering faculty and students, typically over a one- or two-day site visit, and include: 

  • Engineering measurements 

  • Detailed process analysis 

  • Specific recommendations with cost, performance, and payback estimates  

After the assessment, companies receive a report with recommendations from the assessment team. 

DOE energy-saving implementation grants 

The DOE’s IAC Implementation Grants Program (also known as the Industrial Training and Assessment Center Implementation Grant Program) offers up to $300,000 per qualified recommendation to help SMMs implement energy-saving projects. These grants cover up to 50% of implementation costs. 

Who qualifies for IAC services and grants? 

Manufacturers must meet eligibility criteria to receive IAC services and grants, including:  

  • Annual revenue: Under $100 million 

  • Energy bills: Annual energy bills between $100,000 and $3,500,000 

  • Workforce: Fewer than 500 employees at the assessed plant site 

  • Ownership: Must have majority domestic ownership and control  
     

BerryDunn can help uncover federal grant opportunities 

At BerryDunn, we help clients uncover opportunities that foster growth. The IAC Program is one such opportunity, especially for companies unfamiliar with federal energy initiatives. The program operates on a rolling basis with relevant deadlines outlined on its website. Whether you're looking to modernize operations or simply improve margins, this program offers a compelling path forward.  

BerryDunn’s team of manufacturing industry professionals offers clients access to global industry knowledge and tailored, practical solutions that address complex operational, investment, risk management, and compliance challenges. We work collaboratively with each client, engaging in close communication to understand current practices and build actionable strategies for short- and long-term success. Learn more about our services and team.  

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Unlocking efficiency: How DOE grants can transform your operations

H.R. 1, previously titled the “One Big Beautiful Bill Act”, represents one of the most comprehensive federal policy changes in recent decades. It touches healthcare, taxes, and social programs, shifting financing and administrative responsibilities across federal, state, and local governments. The Congressional Budget Office (CBO) estimates it will reduce federal Medicaid spending by roughly $0.9 to 1 trillion over ten years and lead to about 16 million fewer people with coverage, split between Medicaid (~7.8 million) and the Affordable Care Act (ACA) Marketplaces (~8.2 million) over the same period. This overview summarizes H.R. 1’s key provisions and their implications for states, consumers, providers, and payers.

Medicaid: Financing and administrative changes

Work requirements. Most adults ages 19–64 must now document at least 80 hours per month of work or a qualifying activity to maintain Medicaid coverage. Individuals who do not verify compliance lose eligibility for both Medicaid and ACA Marketplace premium tax credits. Exemptions apply for pregnant people, caregivers, and those recently released from incarceration, among others. Research shows most adults on Medicaid already work or qualify for an exemption; KFF estimates that in 2023, 64% were employed and over 90% were either working or exempt.

Faster renewals and more verification. Expansion adults must now renew eligibility every six months, and states are required to conduct additional verification and interstate data-matching. These steps are intended to strengthen program integrity by improving the accuracy of eligibility determinations and reducing improper payments. They may also add administrative complexity and raise the risk of coverage loss for eligible individuals—particularly those with unstable housing, limited internet access, or language barriers.

Provider taxes. The federal “safe harbor” cap on provider taxes will decrease from 6% to 3.5%. States have historically relied on these taxes to generate federal matching funds—accounting for about 17% of non-federal Medicaid financing in 2018, or 28% when including local contributions (MACPAC). The lower cap may prompt states to reassess Medicaid financing strategies and weigh trade-offs in how programs are structured.

State Directed Payments (SDPs) and rural care. Beginning in FY 2028, SDP limits will be tied to Medicare rates, reducing states’ flexibility to supplement managed care payments. With roughly $110 billion in annual SDP spending, largely financed through provider taxes and intergovernmental transfers, this change could constrain a key tool states use to support provider networks in underserved areas. Federal Medicaid spending in rural communities is projected to decline by $155 billion over ten years. A new $50 billion Rural Health Transformation Program aims to offset some of these reductions, with impacts dependent upon state capacity and program decisions.

ACA Marketplaces: Subsidies and enrollment

Stricter verification. Consumers must now fully verify income, immigration status, residency, and family size before receiving premium tax credits (PTCs) or cost-sharing reductions (CSRs). Roughly one in five HealthCare.gov enrollments occur through “passive” renewal; ending automatic re-enrollment for individuals with incomplete verification may increase the risk of coverage disruptions.

Full repayment of excess subsidies. Consumers will no longer have caps on how much excess premium tax credit (PTC) they must repay at tax filing. Some immigration categories will lose eligibility for subsidies, and people enrolling outside a qualifying life event will not qualify for financial assistance. Together, these changes may reduce enrollment continuity and raise financial exposure for households with variable income.

Enhanced subsidies expire. The enhanced premium tax credits (PTCs) introduced under the American Rescue Plan Act and extended through 2025 by the Inflation Reduction Act will expire. Beginning in 2026, subsidies will revert to pre-2021 levels, increasing required premium contributions across income groups. These enhancements had boosted Marketplace enrollment by lowering premiums and eliminating the “subsidy cliff” for many middle-income and older adults.

Analyses by KFF and the Urban Institute project that, without an extension, average consumer-paid premiums could more than double in 2026 and coverage could decline by approximately 4.8 million people. Their expiration has become a central issue in ongoing Congressional negotiations during the federal government shutdown. If no deal is reached, higher premiums and reduced enrollment are likely outcomes.

Ending “silver loading.” Insurers have historically increased silver-tier premiums to offset the cost of providing cost-sharing reductions (CSRs), which raised the benchmark used to calculate premium tax credits (PTCs). H.R. 1 ends this practice. Silver premiums would likely decline along with the benchmark—reducing subsidies across all plan tiers. Brookings estimates that current silver benchmarks are about 28% higher because of silver loading; removing it could lower subsidies by a similar amount. While unsubsidized silver-plan enrollees may see lower gross premiums, many subsidized consumers—particularly those in bronze, gold, or platinum plans—could face higher net premiums and greater sensitivity to income fluctuations.

Coordination gets harder. Medicaid and the ACA marketplaces act as complementary coverage systems, with many individuals moving between them as incomes change. Tighter Medicaid eligibility rules and shorter redetermination cycles may increase these transitions. At the same time, reduced Marketplace subsidies and stricter enrollment criteria may limit affordable coverage options for those losing Medicaid—leading to higher churn, uncompensated care, and pressure on risk pools. These dynamics could create coordination challenges for states and insurers as they manage eligibility transitions and enrollment stability.

Medicare: Payments and innovation models

Eligibility and payments. H.R. 1 narrows Medicare eligibility rules, delays implementation of the 2023 Medicare Savings Program enrollment rule until 2034, and links physician payment updates to the Medicare Economic Index, slowing projected growth after 2027. The law also ends enhanced payments for Advanced Alternative Payment Models (APMs), extends orphan-drug exemptions from federal price negotiation, and postpones new federal nursing home staffing standards until 2034. Changes may affect payment stability and innovation pathways—potentially increasing attribution volatility, complicating risk adjustment, and adding operational and financial complexity for organizations participating in value-based or alternative payment models.

Outlook and implications

H.R. 1 marks a broad realignment of federal health policy, tightening eligibility standards, expanding verification and reporting requirements, and revising financing structures across Medicaid, the ACA Marketplaces, and Medicare. Overall, the legislation redistributes financial responsibilities among federal, state, and local entities and is expected to reshape healthcare coverage, financing, and innovation over the next decade.

Better policy through better information

BerryDunn’s healthcare policy and economics team provides the insights government agencies, healthcare policy research groups, and other organizations need to improve healthcare accessibility and affordability. We have the expertise to inform intelligent, impactful decisions related to healthcare payment reform and cost transparency, to the effect of government mandates on population health and insurance costs, and to market competition. We also have a comprehensive understanding of economic and quality issues in behavioral healthcare—including substance abuse disorder treatment—and of mental health coverage parity. Learn more about our team and services. 

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H.R. 1: What state agencies, providers, and payers need to know