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Who this article applies to: Compliance officers, revenue integrity directors, clinical documentation improvement specialists, clinical documentation and coding auditors, and healthcare providers at healthcare facilities or medical practices. 

It may feel at times like CPT® (Current Procedural Terminology) coding never changes—until it does. The American Medical Association (AMA) annually updates the CPT code set, with main revisions becoming effective January 1, 2027. These changes often require organizations to rethink documentation, coding, workflows, education, and auditing. CPT coding updates may be sporadic and unique, but early organizational preparation can minimize disruptions.

The impacts of CPT code changes may reverberate well beyond the coding department. Significant CPT revisions can affect the productivity, coding accuracy, denial rates, reimbursement patterns, compliance monitoring, Electronic Health Record (EHR) builds, payer contract assumptions, and audit findings of coding and revenue cycle teams. Even seemingly straightforward code changes can trigger extensive downstream impacts if documentation expectations, charge capture workflows, and system configurations are misaligned. Organizations should therefore approach major CPT updates as cross-functional operational changes, rather than as isolated coding updates, and prepare early. 

One CPT change, organization-wide impact 

The upcoming 2027 obstetric coding changes provide an excellent example of the broad impact code changes can have across an organization. Beginning January 1, 2027, maternity care reporting will undergo one of its most significant changes in decades, bringing an end to the long-used global obstetric package model. The resulting increase in Evaluation and Management (E/M) service reporting will require complete and accurate documentation to support code selection.

This shift to increased E/M coding for obstetric services reinforces an important lesson that is applicable to other service lines. Major CPT revisions, such as for obstetrics, rarely involve code changes alone. In the obstetrical example, use of increased E/M coding will require documentation improvements and EHR template revision, workflow redesign, provider education, and ongoing auditing to ensure compliance with the resulting changes.

Preparation will be especially important for these code sets because many patients receiving antepartum services in 2026 may continue their maternity care into 2027, when the new reporting structure takes effect. Organizations will need to consider how visits, documentation, charge capture, payer requirements, and patient encounters that cross the implementation date will be managed. Without proactive planning, organizations put themselves at increased risk for a cascade of events beginning with incomplete documentation and inconsistent coding, leading to potential delayed claims, payer denials, and confusion among providers and revenue cycle teams. Developing clear guidance before the updated code implementation will help ensure continuity of care, accurate reporting, and a smoother operational transition. 

Six steps to prepare for CPT changes

1. Start planning early. Identify affected specialties, workflows, payer policies, and EHR implications to allow time for meaningful education and implementation of changes. 
2. Engage multiple departments. Build a multidisciplinary workgroup that includes coding, compliance, revenue cycle, clinical leaders, operational leaders, and information technology representatives. 
3. Focus on documentation, not just codes. New codes often introduce new documentation requirements that all clinical staff, coders, providers, and auditors should be aware of. Perform documentation gap assessments to identify where provider education may be needed before the effective date. 
4. Evaluate technology. Validate EHR templates, charge capture tools, coding edits, payer rules, reporting systems, and analytics dashboards prior to January 1. 
5. Monitor performance after implementation. Conduct focused post-implementation audits of documentation, coding accuracy, denial trends, and reimbursement patterns to identify improvement opportunities and provide feedback. Use findings to provide timely feedback and make necessary adjustments.  
6. Communicate consistently. Provide staff and colleagues with regular updates and clear guidance throughout the transition period. Having a clear point of contact gives everyone a reliable resource for questions throughout the transition. 

Plan now for upcoming CPT code changes 

Major CPT revisions rarely involve coding changes alone; rather, they prompt cascading operational changes. Successful implementations occur when coding, documentation, compliance, clinical operations, IT, and revenue cycle teams begin planning well before the effective date. Organizations that start now will be best positioned to maintain compliance, support accurate reimbursement, and minimize operational disruption when the next major CPT update arrives. Now is the time to begin. 

BerryDunn can help  

Our healthcare compliance team can help. We incorporate deep, hands-on knowledge with industry best practices to help your organization manage compliance and revenue integrity risks. Learn more about our healthcare compliance consulting team and services.

Who this applies to: Read this if you are a business owner who accepts credit card payments.

As credit card processing costs continue to rise, many businesses are looking for ways to recover these expenses without significantly affecting profitability. Surcharging, which allows a business to add a fee when a customer pays by credit card, is one option. Dual pricing, which gives customers a choice between a lower cash price and a higher card price, is a second option. Business owners must weigh each option carefully to determine what will best suit their needs.

Surcharging: What you need to know

Most states allow businesses to add a surcharge for credit card payments, provided they comply with card network rules and applicable disclosure requirements. However, surcharging is prohibited or significantly restricted in certain jurisdictions, including Connecticut, Massachusetts, Puerto Rico, and potentially Maine. Several other states, including California, Colorado, New York, Minnesota, New Jersey, Nevada, and Texas, have additional requirements or restrictions that businesses should review before implementing a surcharge. Because surcharge laws continue to evolve through legislation, regulation, and court decisions, businesses should confirm current state requirements before moving forward.

Regardless of state, several card network rules apply. Debit card transactions can never be surcharged. Any surcharge must not exceed the merchant’s actual cost of processing the transaction and is generally capped by the card networks. Businesses must also clearly disclose the surcharge before payment is completed and confirm that their Point-of-Sale (POS) system can properly distinguish between credit and debit card transactions. If your business operates in a state where surcharging is prohibited or heavily regulated, a dual-pricing model may be a viable alternative.

What is dual pricing? 

Dual pricing presents customers with two prices upfront: a lower cash price and a higher card price that reflects the cost of card acceptance. Unlike surcharging, no additional fee is added at checkout. Instead, both prices are disclosed before the customer makes a purchasing decision, allowing the customer to choose their preferred payment method. 

Dual pricing is generally permitted throughout the United States when implemented as a properly disclosed cash-discount program. Businesses should work with their processor and legal counsel to ensure compliance with applicable laws, card-brand rules, and disclosure requirements.

Best practices for dual pricing compliance 

• Establish the card price as the posted price and offer a clearly labeled cash discount. 
• Display both prices prominently on shelves, menus, websites, and other customer-facing materials before checkout. 
• Use consistent signage at entrances, checkout areas, and on receipts. 
• Ensure receipts clearly show the transaction amount and any applicable cash discount. 
• Utilize POS software designed to support compliant dual-pricing programs. 
• Train employees to explain the pricing structure consistently and accurately. 

Customers should always be able to understand the price they are paying and how their choice of payment method affects the final transaction amount.

Addressing rising credit card processing costs 

As credit card processing costs continue to rise, many businesses are looking for ways to manage these expenses without significantly impacting profitability. Both surcharging and dual pricing can help offset processing costs, but each approach comes with specific legal and operational requirements. The key to a successful program is transparency: customers should clearly understand their options and pricing before making a purchase. By working closely with your payment processor, reviewing applicable state laws, and communicating openly with customers, businesses can implement a compliant solution that balances cost recovery with a positive customer experience.

State laws change frequently. Please consult the most current laws for up-to-date information. 

Key takeaways

• Compare surcharging and dual pricing before choosing a way to recover credit card processing costs. 
• Review state laws, card network rules, and disclosure requirements before adding a credit card surcharge. 
• Confirm that your point-of-sale system can distinguish between credit and debit card transactions. 
• Disclose cash and card prices clearly before checkout so customers understand payment-related costs. 
• Train employees to explain the pricing structure consistently and accurately. 

About BerryDunn 

BerryDunn’s outsourced accounting services are tailored to the volume of work you have. Whether you need extra help in your office during peak times or interim leadership support during periods of transition, we can help you. We offer the expertise of a fully staffed accounting department for short-term assignments or long-term engagements―so you can focus on your business. Learn more about our team and services.

Compliance is more than a checklist: it is the foundation of organizational success. Across Medicaid agencies, health plans, healthcare providers, and community organizations, compliance creates the structure and consistency needed to fulfill the mission, protect those served, safeguard public resources, and earn stakeholder trust.

For Medicaid agencies in particular, the importance of compliance has never been greater. As states manage increasing program complexity, evolving federal requirements, heightened program integrity expectations, and growing scrutiny from oversight entities, compliance provides a critical framework for accountability, transparency, and responsible stewardship of taxpayer dollars.

Many organizations view compliance as a regulatory requirement or cost of doing business. In reality, it provides the framework needed to operate effectively, manage risk, and achieve sustainable success. For state Medicaid agencies, this framework is especially important as they operate under continual oversight from Centers for Medicare and Medicaid Services (CMS), the Office of Inspector General (OIG), state auditors, legislatures, and other stakeholders. A strong compliance program helps agencies proactively identify risks, strengthen controls, support program integrity, and demonstrate responsible stewardship of public funds.

A football game without rules, officials, coaches, or clear expectations would quickly become chaotic. Standards, oversight, and accountability do not hinder performance; they create the structure necessary for success. To achieve their objectives, organizations need clear expectations, defined processes, and effective governance. Compliance provides that foundation.

Without it, organizations face greater risk of errors, inefficiency, fraud, waste, abuse, regulatory violations, and reputational harm. Effective compliance supports sound decision-making, promotes consistency, and creates conditions for long-term success.

Putting compliance into practice

Strong compliance programs integrate governance, risk management, communication, training, monitoring, and continuous improvement into day-to-day operations.

At its best, the compliance function is a trusted advisor helping leaders identify risks, strengthen controls, improve performance, and make informed decisions.

Organizations with mature compliance programs are often better positioned to identify risks, adapt to changes, and maintain public trust. For Medicaid agencies, effective compliance programs can also support audit readiness, strengthen oversight of contractors and providers, improve program integrity efforts, and help identify and address issues before they become findings, corrective actions, or larger program risks.

Turning compliance into action

Organizations seeking to strengthen compliance do not need to address every challenge at once. Meaningful progress begins with a few foundational steps:

• Establish accountability. Clearly define compliance responsibilities and ensure leaders and employees understand their role in managing risk and supporting organizational objectives.
• Document expectations. Establish written policies and procedures that provide consistent guidance, support decision-making, and promote operational consistency.
• Foster a culture of compliance. Encourage employees to ask questions, report concerns, and view compliance as a shared responsibility.
• Evaluate and improve. Regularly assess risks, monitor performance, and use lessons learned to strengthen processes, controls, and outcomes.

Compliance is about trust

Compliance builds confidence that public funds are used appropriately, services are delivered responsibly, and decisions are made with integrity and transparency. For Medicaid agencies, that confidence extends to beneficiaries, providers, taxpayers, legislators, federal partners, and oversight entities that rely on the agency to be responsible stewards of public resources.

That trust depends on leadership commitment and ongoing investment in oversight, training, communication, monitoring, and continuous improvement. Compliance cannot reside within a single department. It must be embedded throughout an organization.

As organizations navigate increasingly complex regulatory, operational, and financial environments, leaders should periodically step back and ask:

• Are our compliance activities aligned with our mission and strategic goals?
• Do we have the people, resources, expertise, and infrastructure needed to manage risk effectively?
• Are compliance considerations integrated into decision-making across the organization?
• Does our culture promote accountability, transparency, and continuous improvement?

The answers may reveal vulnerabilities that threaten mission success, as well as opportunities to improve outcomes, strengthen resilience, and better position the organization for the future.

The question for leaders is not whether an organization is compliant today, but whether it has the governance, oversight, and the culture necessary to remain successful tomorrow. When embedded in strategy and operations, compliance becomes a driver of organizational excellence. It transforms mission into action, principles into practice, and strategy into measurable results. Beyond the checklist, compliance enables organizations to lead with integrity, manage uncertainty with confidence, and achieve sustainable success.

The questions posed in this article are intended to start a broader conversation about how compliance supports organizational performance. Future articles will explore practical strategies for strengthening governance, managing risk, developing effective written policies and procedures, and fostering a culture of integrity and accountability. Together, these elements can help organizations move beyond compliance as an obligation and leverage it as a strategic advantage.

Key takeaways

• Recognize compliance as the foundation for organizational success, not just a regulatory requirement or cost of doing business.
• Use compliance to create the structure, consistency, and accountability needed to fulfill the mission and safeguard public resources.
• Integrate governance, risk management, communication, training, monitoring, and continuous improvement into day-to-day operations.
• Strengthen controls, audit readiness, contractor and provider oversight, and program integrity efforts before issues become findings or corrective actions.
• Evaluate whether compliance activities are aligned with mission, strategic goals, decision-making, and the culture needed for long-term success.

BerryDunn’s Medicaid Practice Group helps Medicaid agencies improve the health and lives of individuals by empowering, inspiring, and partnering with our clients—we innovate, share deep expertise, and provide an independent perspective to resolve challenges. We are the success partner for Medicaid agencies, building healthier communities and stronger futures. Learn more about our team and services.

A modest rate increase and CMS's inquiry into PDPM case-mix growth

The Centers for Medicare and Medicaid Services (CMS) issued the FFY 2027 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule, which was published in the Federal Register on July 31, 2026.  

The rule updates SNF PPS payment rates effective from October 1, 2026, to September 30, 2027, and includes changes to the SNF Quality Reporting Program (QRP), the SNF Value-Based Purchasing (VBP) Program, and several policy initiatives that may shape future reimbursement. 

While the payment update is relatively straightforward, CMS devoted considerable attention to reviewing trends under the Patient Driven Payment Model (PDPM), signaling continued focus on coding practices and potential future payment adjustments. Providers should pay close attention to this area as CMS evaluates comments received regarding case-mix growth and potential PDPM recalibrations. 

FFY 2027 PPS rate calculations 

CMS finalized a 2.4% payment update for FFY 2027, reflecting: 

• A 3.3% SNF market basket increase 
• Less a 0.9 percentage-point productivity adjustment 
• No forecast error adjustment 

CMS estimates that the aggregate impact of the payment policies in this Final Rule will result in an increase of 2.4%, or approximately $882.7 million, in Medicare Part A payments to SNFs in FFY 2027. These estimates do not include the impact of SNF Value-Based Purchasing (VBP) adjustments, which CMS estimates will reduce payments by approximately $203.6 million. The impact of the update will vary by provider based on wage index changes, geographic location, resident case mix, and facility-specific VBP performance. 

CMS projects an average payment increase of 2.4% for urban SNFs and 2.7% for rural SNFs, with a low of 0.5% for rural Mountain providers and a high of 4.6% for rural New England providers. Actual provider-level impact will vary based on wage index changes and other facility-specific factors. 

The unadjusted federal rates for FFY 2027, prior to adjustment for case-mix, are as follows:  

FFY 2027 Unadjusted Federal Rate Per Diem – Urban 

FFY 2027 Unadjusted Federal Rate Per Diem – Rural 

These rates remain subject to PDPM case-mix adjustments and facility-specific wage index adjustments.

Updated PPS Rate Calculator available

As in prior years, BerryDunn has updated its interactive PPS Rate Calculator within the BerryDunn Senior Living Portal to incorporate the FFY 2027 payment rates and wage index information to assist you with the calculation of your facility-specific PPS rates.

Access the PPS Rate Calculator. 

Please note that calculated rates do not reflect facility-specific SNF VBP adjustments. BerryDunn will update the calculator as necessary once final incentive payment multipliers become available. Meanwhile, VBP information, including the incentive payment modifier for FFY27, has been made available to providers in iQIES. We recommend reviewing data carefully and promptly, as any requests for corrections are accepted by CMS through the end of August. 

CMS focuses on PDPM case-mix growth 

The most notable policy discussion in this year's Final Rule is CMS's continued evaluation of PDPM reimbursement trends. 

CMS previously solicited stakeholder feedback through a Request for Information (RFI) regarding observed increases in certain PDPM coding elements since implementation. Examples cited by CMS include substantial increases in reporting of diagnosis codes that increase PDPM reimbursement, such as malnutrition, swallowing disorders, and depression indicators. CMS noted that these trends have occurred while certain categories of resource utilization have declined.  

The agency presented potential methodologies for measuring what it refers to as "case-mix creep" and sought stakeholder feedback regarding possible future payment adjustments. While CMS did not finalize any PDPM payment reductions in this rule, the methodology discussed in the proposed rule produced a hypothetical system-wide case-mix creep adjustment factor of 0.957, which CMS estimated could equate to a 4.3% reduction in CMIs/base rates or a 3.6% reduction in total payments. Providers should view this discussion as a clear signal that CMS is actively evaluating whether future reimbursement modifications are warranted.  

CMS did not finalize any PDPM-related payment adjustments in FFY 2027. However, organizations should continue emphasizing accurate, well-supported clinical documentation and coding practices. 

SNF QRP update  

CMS finalized several changes to the SNF Quality Reporting Program. 

Removal of COVID-19 measures 

Beginning with FFY 2028 SNF QRP reporting, CMS is removing: 

• COVID-19 Vaccination Coverage Among Healthcare Personnel 
• COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date 
   

CMS noted that evolving vaccination guidance and the move toward individualized clinical decision-making have reduced the usefulness of these measures for quality reporting purposes.  

Shorter data submission deadlines 

CMS finalized changes that will significantly shorten quality reporting submission timelines.  

Beginning with FFY 2029 SNF QRP reporting, providers must submit data by the 15th day of the second month following the end of each calendar quarter, approximately 45 days after quarter-end, replacing the current four-and-a-half-month submission time frame. CMS stated the change is intended to improve the timeliness of publicly reported quality information.  

All-payer MDS reporting requirement 

CMS finalized a requirement that SNFs submit MDS data for all residents receiving covered skilled services, regardless of payer, beginning with the FFY 2031 SNF QRP. This change is intended to align SNF quality reporting with other post-acute care settings and provide a broader picture of SNF quality performance. 

SNF VBP program update  

CMS finalized performance standards for FFY 2029 and FFY 2030, revised the snapshot date for two MDS-based VBP measures to align with the revised QRP submission timeline, and made technical regulatory updates.   

CMS estimates that the SNF VBP Program will result in an approximately $203.6 million reduction in aggregate payments to SNFs nationwide during FFY 2027.

Bottom line for SNFs 

The FFY 2027 Final Rule delivers a modest 2.4% payment increase. 

CMS signaled continued interest in PDPM coding trends and potential future payment refinements. At the same time, providers should begin preparing for accelerated QRP reporting timelines and eventual all-payer MDS submission requirements. 

For most organizations, the immediate next step is understanding the impact of the FFY 2027 rates on facility-specific reimbursement. BerryDunn's updated PPS Rate Calculator can help quantify that impact and support budgeting efforts for the coming fiscal year. 

If you have any questions about the Final Rule or how it might affect your facility, please contact Ashley Tkowski or Melissa Baez.

Every July, the National Recreation and Park Association (NRPA) celebrates Park and Recreation Month. This year's theme, "The Power Of," highlights the power of connection, play, community, nature, belonging, and well-being. But what does that actually look like?

When we posed that question to BerryDunn's Art Thatcher and Nikki Ginger, two longtime parks and recreation professionals who now advise agencies across the country, neither started by talking about facilities, amenities, or capital projects. They talked about people.

By the end of the conversation, a different question emerged: What if the real power of parks and recreation isn't in the places themselves, but in their ability to bring people together? 

The power of connection 

We live in a world designed to make interaction optional. We can stream entertainment without leaving the couch, order dinner without speaking to anyone, and maintain friendships through text chains and social media updates. Yet people continue to flock to parks, concerts, community events, trails, and recreation programs because technology may help us communicate, but it doesn't replace the human need to connect. 

Nikki was reminded of that recently when the Chicago Park District announced plans for moveable outdoor seating, something she first saw during a trip to Paris. This simple, though surprisingly rare, feature allows visitors to pull a chair into the shade, turn it toward a friend, or arrange them into small groups. It's a small design choice, but it reflects a much larger truth. People are looking for opportunities to gather, and parks create the conditions that make those connections possible.

Art sees those opportunities everywhere. He believes parks succeed because they provide something people are increasingly missing: common ground. Walk through a park alone and most people keep to themselves. Walk with a dog, a grandchild, a soccer ball, or even an artist's sketchbook, and the entire dynamic changes. Suddenly people are smiling, asking questions, and striking up conversations.

People look for common ground, and parks create thousands of those moments every day. A soccer game, a walking trail, a community event, or a neighborhood playground may be what brings people to a space, but the relationships that form there are what give it meaning.

Throughout his career, Art has seen parks and recreation bridge generations, cultures, and neighborhoods in ways few other institutions can. As he put it, "A pool table is still a pool table whether you're 12 or 82." The activity may look simple, but it creates a rare opportunity for people of different ages and backgrounds to share an experience. The activity may be different, but the outcome is often the same: people finding a reason to connect. 

The power of play 

Play tends to get dismissed as something that belongs to children, but Art and Nikki would strongly disagree. 

In fact, many of life's most important lessons are learned through recreation. Board games teach strategy and problem solving. Team sports teach collaboration and resilience. Friendly competition teaches us how to win graciously and lose gracefully. 

Art laughed as he described a household rule while raising his children in a highly competitive family: "The first one to cry goes to bed." Behind the humor, though, was a serious point. Play gives people a safe environment to experiment, learn, fail, adapt, and grow. The lessons may begin on a playing field or around a game board, but they often carry into school, work, relationships, and everyday life. 

Play also has a unique ability to bridge divides. Art pointed to the World Cup as a perfect example. Fans from around the globe gather around a shared love of the game, setting aside cultural differences and preconceived notions. Visitors discover that communities are often more welcoming than expected. Residents discover they have more in common with people from different backgrounds than they realized. For a few hours, politics, geography, and stereotypes take a back seat to a shared experience. 

For Nikki, play is also closely tied to wellness and longevity. She pointed to research on Blue Zone communities, where people regularly live longer, healthier lives than average. One of the common threads is meaningful engagement with family, friends, and community. Recreation often provides the vehicle for those interactions, creating opportunities for people to stay active, involved, and connected across generations. 

She's seen that firsthand in her own family. When conversations begin heading into uncomfortable territory, Nikki has a simple solution: bring out a game. Almost immediately, the conversation changes. People stop focusing on their differences and start focusing on a shared experience. The atmosphere lightens. Everyone reconnects. It goes beyond being a distraction from real life. It can actually be the catalyst for helping us navigate real life. 

The power of community 

One theme surfaced repeatedly throughout our conversation: people want to be together. 

The growing popularity of community events proves it. Movie nights in the park, outdoor concerts, food truck festivals, and community celebrations continue to draw strong participation, even though people could enjoy the same entertainment from the comfort of home. That's because the attraction isn't really the movie, the concert, or even the food; it's the shared experience. 

As Nikki put it, people want to gather. Sometimes they just need an excuse.  

Art shared a similar story. When a friend's son was in town playing baseball, a simple invitation went out to a small group of friends. By game time, nearly twenty people had shown up. The baseball game gave them a reason to gather, but seeing one another was what made the evening memorable.

That ability to create community is why Art still remembers something a city manager told him decades ago: 

"You are my feel-good department." While police departments respond to emergencies and public works departments maintain infrastructure, parks and recreation creates experiences people look forward to. It creates moments of joy, celebration, connection, and belonging that shape how people experience their community. 

In a world where so many conversations focus on what's broken, parks and recreation offers something different: opportunities to build relationships, create memories, and strengthen the ties that make communities feel like home. 

The power of nature and belonging 

If the pandemic taught communities anything, it was that access to nature isn't a luxury. It's essential. 

Both Art and Nikki have watched communities rediscover the value of trails, open spaces, neighborhood parks, and outdoor recreation over the past several years. During COVID, people sought refuge outdoors. What many discovered was that these spaces offered far more than recreation. They offered relief, connection, perspective, and resilience. 

The renewed appreciation for outdoor spaces has led to another shift that Art sees in communities across the country. For years, many communities poured resources into destination facilities and large sports complexes. Today, residents increasingly ask for something much simpler: a quality park close to home. 

They want a place to walk with their families, sit under a tree, read a book, or simply spend time outside. They want a place where neighbors recognize one another and where the community feels accessible, familiar, and welcoming. 

In short, they want a place that feels like theirs. As Art noted, if you want to see how much people value a park, tell them it's going away. 

Residents who haven't visited in months will show up at meetings to defend it. Not because they're thinking about a playground or a walking path, but because they're thinking about what that place represents. It's part of their identity, their neighborhood, and their community. 

Common ground 

Throughout our conversation, Art and Nikki kept returning to the same idea, even when they were answering completely different questions. Whether they were talking about play, nature, community events, or neighborhood parks, the underlying value was remarkably similar: Parks and recreation creates common ground. 

A soccer game is a universal language that requires no translation, no matter where in the world you are. A community concert gives friends a reason to gather. A walking trail creates chance encounters. A neighborhood park becomes part of a community's shared identity. 

In a time when people often feel isolated, stressed, or divided, parks and recreation provides something increasingly valuable: opportunities to show up, share an experience, and connect with one another. That's what Nikki sees in crowded movie nights, multigenerational programs, and communities rallying around the spaces they love. It's what Art has seen throughout a career spent helping communities build places where relationships can grow. 

The parks may bring people in. The programs may get them involved. But the real power of parks and recreation lies in what happens next: the conversation that starts on a walking trail, the friendship that forms at a community event, the neighbors who become connected through a shared place. 

Sometimes all it takes is a little common ground to turn a space into a community. 

Innovative strategies for parks, recreation, and libraries 

BerryDunn's consultants work with you to improve operations, drive innovation, identify improvements to services based on community need, and elevate your brand and image―all from the perspective of our team’s combined 100 years of hands-on experience. We provide practical park solutions, recreation expertise, and library consulting. Learn more about our services and team.  

The FDIC's Quarterly Banking Profile for first quarter 2026 reports the performance for the 3,852 community banks evaluated. Here are the key highlights: 

Note: Graphs are for all FDIC-insured institutions unless the graph indicates it is only for FDIC-insured community banks. 

Financial Performance 

• Quarterly net income increased $302.7 million (3.9%) from the previous quarter to $8.1 billion, with 55.8% of community banks reporting an increase. 

• Pretax return on assets increased to 1.42%, up 7 basis points quarter over quarter, increasing by 26 basis points year over year. 

• Net interest margin decreased to 3.71%, down 6 basis points from the prior quarter; however, overall increased by 24 basis points year over year. 

Costs and Efficiency 

• Noninterest expense decreased by $310 million (1.7%) from the previous quarter but has increased 6.4% year over year. 

• Provision expense decreased by 34.4% quarter over quarter and 11.3% year over year, while asset quality indicators remained mixed.  

• Efficiency ratio decreased to 61.87%, down 0.64% from the prior year first quarter, indicating increased cost control relative to revenue. 

Loan and Deposit Trends  

• Loan and lease balances increased by $16.1 billion, or 0.8%, quarter over quarter and 5.4% year over year. Quarter-over-quarter growth was led by nonfarm nonresidential CRE loans, while year-over-year growth was led by nonfarm nonresidential CRE, 1–4 family residential real estate loans, and commercial and industrial loans. 

• Domestic deposits rose 1.2% quarter over quarter and 4.6% year over year, with growth in both interest-bearing and noninterest-bearing accounts.

• Nearly 58% of community banks reported loan growth, and about 69% reported deposit growth during the quarter. 

Asset Quality 

• Past-due and nonaccrual loans (PDNA) increased 9 basis points to 1.44% from the previous quarter. 

• Net charge-off ratio decreased 11 basis points from the prior quarter to 0.18%, continuing to be above the pre-pandemic average of 0.15%. 

• Reserve coverage ratio continued to decline to 146.4%, as the allowance for credit losses decreased while noncurrent loan balances increased. 

Capital and Structural Stability 

• Most capital ratios increased from the prior quarter. The tier 1 risk-based capital ratio for community banks that did not opt into the CBLR framework rose 13 basis points to 14.43%, while the average CBLR for banks using the framework remained relatively unchanged at 12.36%. The leverage capital ratio for all community banks increased 11 basis points to 11.15%. 

• Unrealized losses on securities increased by $2.6 billion (8.9%) from the prior quarter to $32.2 billion in total.  

• Community bank count declined by 59 during the quarter due to transitions, sales, mergers and acquisitions, and one community bank failure. 

Conclusion and Outlook 

The first quarter of 2026 reflected a modest increase in earnings performance for community banks. Quarterly net income increased $302.7 million (3.9%) from the prior quarter to $8.1 billion. Pretax return on assets improved by 7 basis points to 1.42%, marking a 26-basis-point increase from a year earlier. Net interest margin, however, edged down to 3.71%, declining 6 basis points from the previous quarter but remaining 24 basis points above the same period in 2025, suggesting that the benefits of higher asset yields may be stabilizing. 

Expense trends provided some relief during the quarter, supporting improved operating efficiency. Noninterest expenses declined by $310 million (1.7%) from the prior quarter, although they remain 6.4% higher year over year. Provision expenses fell significantly, decreasing 34.4% quarter over quarter and 11.3% year over year. As a result, the reserve coverage ratio continued to trend lower, falling to 146.4%, suggesting that reserve growth has not kept pace with rising levels of noncurrent loans. 

Balance sheet growth remained steady, with both lending and deposit activity continuing to expand. Loan and lease balances increased by $16.1 billion (0.8%) quarter over quarter and 5.4% year over year, driven primarily by growth in nonfarm nonresidential commercial real estate, 1–4 family residential mortgages, and commercial and industrial lending. Domestic deposits rose 1.2% during the quarter and 4.6% year over year, with gains in both interest-bearing and noninterest-bearing accounts. Growth was broadly distributed, as nearly 58% of community banks reported loan growth and approximately 69% reported deposit growth. 

Asset quality metrics presented a mixed picture. Past-due and nonaccrual loans increased 9 basis points to 1.44%; however, at the same time, the net charge-off ratio declined to 0.18%, down 11 basis points from the previous quarter but still above pre-pandemic levels of 0.15%. 

From a capital and structural standpoint, the sector remained sound. Regulatory capital ratios generally improved, with the tier 1 risk-based capital ratio for community banks that did not opt into the CBLR framework increasing to 14.43% and the leverage capital ratio for all community banks increasing to 11.15%. However, unrealized losses on securities grew by $2.6 billion (8.9%) during the quarter to $32.2 billion, reflecting some renewed pressure on securities valuations. 

Looking ahead, community banks enter the remainder of 2026 with improved earnings performance, better expense control, and steady balance sheet growth. However, evolving net interest margin dynamics, modest softening in certain asset quality indicators, and persistent unrealized securities losses may require continued vigilance. As economic conditions shift and consolidation trends persist, institutions will need to remain focused on disciplined credit management, efficient operations, and strategic growth. As the regulatory environment continues to evolve, BerryDunn's Federal Impacts page remains a valuable resource for timely updates that may affect your institution or its borrowers. We wish you continued success in 2026, and as always, your BerryDunn team is here to help.

Who this applies to: Owners, administrators, CEOs, COOs, CFOs, finance directors, directors of nursing, HR, and IT at nursing facilities.

The Centers for Medicare and Medicaid Services (CMS) has strict regulations for reporting direct care staffing and census information through the Payroll-Based Journal (PBJ) system, requiring nursing facilities to report this information quarterly. CMS publishes the data and uses it to determine star ratings on the staffing component of the Nursing Home Compare website. While star ratings are obviously important for your facility’s reputation and ability to attract new patients and residents, there are other reasons that you should ensure that the data you submit on your PBJ is accurate and complete. This article offers nine actionable steps you can take to prepare your nursing facility for the CMS Payroll-based Journal audit.

Why accurate PBJ data is important 

The data you provide can be accessed by other regulatory agencies, including state licensing agencies, and may be used for licensing and complaint investigation surveys, with any identified non-compliance resulting in citations, fines, or penalties. In 2026, the Office of Inspector General (OIG) started PBJ data audits as they relate to medical director hours reporting. Some state Medicaid agencies utilize PBJ data in a variety of ways, such as to validate paid nursing hours reported on Medicaid cost reports. Facilities need to be aware of a wide range of potential data uses and have comprehensive internal data review procedures to help ensure the public use file reflects accurate reporting and that the facility is prepared for an audit.

PBJ Data Specifications revisions 

A revised version of the PBJ Data Specifications (Version 4.10.0) is required as of April 2026.  Another recently announced change is that, effective August 17, 2026, the PBJ system will transition to the Internet Quality Improvement and Evaluation System (iQIES). This change impacts an organization’s access to the reporting platform because it requires an HCQIS Access Roles and Profile (HARP) login to access iQIES. Please note, similar to the Provider Statistical and Reimbursement (PS&R) report, providers have an option to request different levels of access to PBJ: 

According to CMS provider file data published June 1, 2026, about 4% of Skilled Nursing Facilities (SNFs) nationwide missed PBJ submission, submitted incorrect/unverifiable data, or failed a PBJ audit. 

Best practices for timely, accurate PBJ reporting 

1. Maintain and test access to the reporting portal(s) 

With turnover and planned and unplanned absences, we recommend that at least two staff members maintain logins and practice submitting reports. With the PBJ reporting transition to iQIES in August 2026 and April – June 2026 reports due by November 14, 2026, it is critical that facilities establish all required access (including back-up personnel) ahead of the reporting deadline. The iQIES Service Center is projecting an increase in the volume of calls and emails between July 2, 2026, and August 14, 2026, in preparation for this transition.  

2. Understand that less might be more  

PBJ reporting includes required and optional elements. The optional data may include worked hours for other service workers. Evaluate whether your organization should report optional data elements. If you opt to report this type of data, be sure that it is accurate and complete. 

3. Plan ahead and consider more frequent submissions 

Allow your team enough time for review after the quarter ends, but prior to the cut-off date. It is a requirement to file quarterly, but you may also submit data more frequently, such as after processing each pay period. This approach allows for more timely identification of employee classification issues or technical challenges. It also gets responsible staff into the habit of maintaining records on an ongoing basis, rather than as a quarterly event.  

4. Don't forget to verify your submission  

Do not skip the confirmations and available reports for review prior to the deadline. A frequent mistake we see in the industry is related to not reading acceptance/rejection reports carefully and assuming that the submission was accepted as submitted. Once the final data file is uploaded, SNF/NFs need to check their Final File Validation Report to verify that the data was submitted successfully. Please be aware that it may require up to 24 hours for the validation report to be available and allow for time to correct any errors and resubmissions, if needed. 

5. Make finding a needle in a haystack easier 

Carefully review and summarize data as described in the PBJ Report User Guide (CASPER Section 12 – Reports). We recommend obtaining all related reports (in CASPER, “D” at the end of the report number indicates detailed reports and “S” refers to summary reports). We recommend utilizing Excel data summarization tools to carefully review data. To help facilities with transition from CASPER to iQIES reporting, below is a list of available reports in both systems. 

Please note that users will only be allowed to run reports for the providers to which they have access with their iQIES role. The iQIES reports are expected to contain the same information as the CASPER reports, updated to have the iQIES formatting. CMS planned to migrate previous submissions for up to 10 years, which will allow users to run all reports except the Submitter Final Validation report for data submitted in QIES and iQIES (see notes in table below). 

iQIES users can schedule reports to run at their preferred frequency. Review these reports to help ensure the quarterly PBJ data reflects your records. Most of the detail reports (D) are available as a .csv file download, which is instrumental with the assistance of Excel templates to simplify and expedite your review. We recommend using pivot tables, data filtering, and conditional formatting rules to bring attention to potential errors, omissions, or high-risk audit areas, including:

• Any days without at minimum eight RN hours
• Exempt staff with >40 reported worked hours per week
• Non-exempt (hourly) staff with more than 80 hours per week or >300 hours per month
• High or low average total nurse (aides, LPNs, and RNs) staffing (less than two and more than five hours per patient day. Visit BerryDunn’s senior living self-service benchmarking portal for comparison to your peers
• Changes in total average nurse staff hours per patient day by over 10% compared to the previous quarter(s)

6. Share the knowledge with PBJ reporting and management teams

Educate your PBJ reporting and management oversight team, discuss, and gain clarity on your internal record-keeping policies and procedures. Obtain the most recent manuals. We recommend electronic bookmarks to the CMS site rather than printed paper copies, as the guidance may change.

7. Trust but verify to help ensure compliance

While you may have complete trust in your team, nobody is immune to an occasional mistake or omission. Responsibility for PBJ compliance is with facility leadership. Review the reports carefully and make timely corrections.

8. Keep a close eye on the Nursing Home Compare website

Check the CMS nursing home compare information for your facility regularly to help ensure information is correct.

9. Don't panic: It is fixable!

If you have an unfavorable PBJ audit, there are actions you can take to remedy the situation and avoid it in the future. We suggest that your team:

• Includes the PBJ program compliance review in your QAPI initiatives, which makes it a multi-departmental challenge to get back on track and prevent any future non-compliance
• Engages your communications team in crafting a meaningful response to any potential community inquiries if you receive a one-star rating in staffing. Be prepared to describe the issue objectively and without blame, while outlining the steps the facility is taking to improve.
• Takes an objective look at your systems. Consider an external consultant to help with identification of the process gap and ideas for sustainable remediation.

If you have any questions, please reach out to Olga Gross-Balzano or a member of BerryDunn’s Senior Living team of experts.

Who this article applies to: CFOs, controllers, and internal audit professionals at financial institutions

Occupational fraud remains a persistent and costly risk for financial services organizations. In its 2026 Report to the Nations, the Association of Certified Fraud Examiners studied 2,402 fraud cases globally totaling more than $3.4 billion in losses across industries, including financial services. The report estimates that organizations lose about 5% of annual revenue to fraud, underscoring that no institution is immune. Equally important, many organizations never fully recover those losses, with over half of victims recovering nothing, highlighting the need for a proactive fraud risk management approach rather than post-event remediation.

Risk profile for banks and investment firms 

The report includes targeted insights for the banking and financial services sector: 

• Median loss per case: $100,000 
• Average loss per case: $1,535,000 
• Median duration: 8 months  

These figures are consistent with overall global trends, but the financial sector’s exposure to high-value transactions, complex systems, and regulatory scrutiny increases both the potential impact and reputational risk associated with fraud events.

Fraud types most relevant to financial institutions 

The report identifies three primary fraud categories: 

• Asset misappropriation: 90% of cases; lower median loss 
• Corruption: 45% of cases—includes conflicts of interest and kickbacks; moderate loss 
• Financial statement fraud: 6% of cases; highest losses at $1 million median

Within financial services, asset misappropriation-related schemes are most prevalent. However, although financial statement fraud is less frequent, it presents the greatest dollar exposure. 

Fraud detection and why whistleblower programs matter 

Because fraud losses escalate over time, improving detection is one of the most effective ways to limit impact. Key insights include: 

• 43% of fraud cases were detected through tips, over half of which came from employees. 
• Email and web-based reporting channels are now more commonly used than hotlines. 

Institutions with strong whistleblower frameworks and accessible reporting channels are significantly better positioned to detect fraud early and minimize losses. The most effective frameworks are comprehensive, independent, and trusted by employees.

Higher roles, higher fraud exposure 

Fraud risk is closely tied to access and authority, requiring strong governance and oversight. Employees and managers commit most fraud, but executives cause the largest losses, with risk increasing alongside authority, tenure, and collusion.

Behavioral red flags 

Most perpetrators exhibit warning signs, such as financial pressure or unusual relationships. Behavioral monitoring can enhance fraud detection, particularly for high-risk roles. Always consider the components of the fraud triangle: incentive, opportunity, and rationalization. 

Internal control failure   

Approximately 70% of fraud cases involve control failures rather than absence of controls. For regulated institutions, this highlights the need for effective execution and monitoring of controls, not just design.  

Core controls include management review, data monitoring, and surprise audits. Fraud awareness training and regular reassessment of risk frameworks are also essential, as many organizations still respond to fraud reactively rather than proactively.

Aligning fraud risk management with strategic decision-making 

Fraud risk extends beyond operations to compliance, governance, and reputation. Organizations that emphasize active monitoring, strong controls, and a culture of accountability are best positioned to reduce losses and strengthen risk management. In our complimentary whitepaper on preventing financial institution fraud, we take a deeper look at how to successfully implement a strong anti-fraud plan. Commit to enhancing fraud prevention to build trust with your board, employees, customers, and the broader public—an investment that delivers strong value for any financial institution. 

Key takeaways

• Recognize persistent fraud risk, with organizations losing an estimated 5% of annual revenue to fraud and many recovering none of those losses. 
• Improve detection by strengthening whistleblower programs and digital reporting channels, especially for employees. 
• Address high-impact fraud by focusing on asset misappropriation while monitoring high-cost financial statement fraud. 
• Increase oversight of senior roles, where fraud risk and losses are greater. 
• Check internal controls with monitoring, management review, and ongoing risk assessment. 

BerryDunn can help 

Our risk management team helps clients develop and implement effective risk management programs tailored to each organization’s size, risk level, and resources. Learn more about our team and services.