CARES Act

The COVID-19 pandemic taught our public health systems a number of critical lessons about how we should engage, communicate, partner, and share data with other agencies and our communities. It also reinforced the importance of applying an intentional health equity lens to the system to better support vulnerable communities in times of crisis.  

While the pandemic may have elevated these issues, vulnerable communities have faced inequities in our health systems for decades. If agencies do not center equity in all public health goals and operations, they continue to risk creating policies and services that further those inequities. Applying an equity lens requires public health agencies to consider systemic causes of health disparities (i.e., poverty, education, racism) and how they operationalize policies, practices, and programs that improve health for all. 

Centering health equity across your organization 

BerryDunn’s public health consulting team believes health equity should be an overarching goal of a public health system—not just a standalone program or a one-time initiative. Achieving health equity requires public health systems to be intentionally inclusive and equitable; all organizational areas need to work together to promote the attainment of the highest level of health for every person.  

Our approach to health equity starts with the goal of creating inclusive and equitable public health systems, and takes into account a wide range of considerations: 

In any community, the health of individuals is influenced by many factors, including the environment in which people live, work, learn, and recreate. To address the different factors at play, meaningful efforts to achieve health equity can’t exist in a silo. These efforts must be integrated across all departments of a public health agency. From frontline staff working directly with community members to finance staff working behind the scenes, all members of the organization are critical to successfully implementing a sustainable health equity approach.  

As an example, centering health equity within human resources and workforce development processes helps promote the recruitment and retention of a diverse public health workforce, and could include: 

• Recruiting public health specialists who reflect the focus populations and/or the communities receiving services to better support cultural and linguistic needs.  
• Hiring local community members serving as community health workers to help create rapport and trust with marginalized communities.  

Health equity approaches can also be implemented in areas such as budget and resource allocation, data collection, and other organizational processes, policies, and procedures. Some strategies include: 

• Establishing language standards to help ensure information is clear and accessible to everyone.  
• Using plain language in budget documents to help community partners understand how public health funds are limited or restricted.  
• Implementing processes such as a health equity lens review of all existing and new organizational policies to help identify hidden systemic or structural implications and open the way to new, more equitable approaches. 

Incorporating a health equity lens in strategic planning 

An equity-centered approach can be integrated into any public health strategic planning effort, such as state health improvement planning and programmatic strategic planning. A key component of any strategic planning project is community engagement to reach historically marginalized populations and members of communities that may be disparately impacted by certain health conditions or environmental factors. A standard practice is to recruit key community members, disparate populations, and/or people with lived experience who can help provide input on public health services.  

The following example draws on our team’s experience supporting West Virginia’s State Health Improvement Plan development process. 

In West Virginia, our Public Health team hosted in-person and virtual listening sessions with the public as part of the state health improvement plan development process. These sessions were publicized through a wide range of community partners and scheduled to accommodate varying availability and work schedules. Sessions were held in accessible and familiar public settings, as well as online to maximize opportunities for diverse participation, perspectives, and input. Centering health equity in this approach to strategic planning helped ensure that the final product represented the voices and experiences of those who are most affected.  

Determining how and when to apply a health equity lens across a public health system can be challenging. The first step is to assess current organizational conditions that may be creating or fostering the root causes of disparate outcomes. Some questions to ask include: 

• How are public health resources shared?  
• Who has the power or authority to make decisions?  
• What assumptions influence how the system functions, or the services are delivered?  

Understanding the answers to these questions can help you build a plan for operationalizing health equity principles across programs, the workforce, and finance. It can be useful to have a third party conduct an independent review of your agency’s policies, practices, and processes through an equity lens. Our team provides recommendations based on best practices from the field, as well as effective change management and equity-centered approaches.   

Read this if you're a broker-dealer. 

The implementation of Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) 606, Revenue from Contracts with Customers, which has been in effect since 2018 for broker-dealers, has had a profound impact on financial reporting across various industries. For broker-dealers, the adoption of this standard has introduced new challenges and considerations in recognizing revenue accurately and in accordance with the principles outlined in ASC 606.  

FASB ASC 606 provides a comprehensive framework for recognizing revenue from customer contracts. The standard replaces the previous industry-specific guidance and aims to create consistency and comparability across different sectors by establishing a five-step process for recognizing revenue. For broker-dealers, who engage in a wide range of financial transactions, the standard requires a careful assessment of revenue recognition practices.  

The ASC 606 five-step process for broker-dealers  

1. Identification of contracts with customers

Broker-dealers must identify contracts with customers, which can include various financial instruments and transactions. The standard emphasizes the importance of assessing whether an agreement creates enforceable rights and obligations between parties.  

2. Performance obligations

ASC 606 introduces the concept of performance obligations, which are promises to transfer goods or services to customers. For broker-dealers, this may involve analyzing the various components of financial transactions to determine distinct performance obligations.  

3. Determine the transaction price

Determining the transaction price is crucial and should only reflect the amount of consideration to which a broker-dealer expects to be entitled in exchange for goods or services transferred. The transaction price includes only those amounts to which the reporting entity has rights under the present contract.  

4. Transaction price allocation

The transaction price needs to be allocated to each performance obligation in a manner that reflects the stand-alone selling price.  

5. Timing of revenue recognition

ASC 606 provides guidance on when revenue should be recognized. Factors to consider include the transfer of control, delivery of services, or the satisfaction of other identified performance obligations.  

There were many challenges faced by broker-dealers with the implementation of ASC 606.  BerryDunn’s broker-dealer team is well positioned to bring tailored, innovative solutions and a proactive approach to help clients overcome these challenges, ensuring measurable results and open communication throughout the process. 

Challenges faced by broker-dealers in implementing ASC 606

• Complexity of financial transactions: Broker-dealers engage in a wide array of complex financial transactions, involving multiple components and varying terms. Identifying distinct performance obligations and accurately allocating transaction prices to each component can be challenging.  

• Variable consideration and contingent fees: Financial arrangements often include variable consideration, such as contingent fees, performance-based incentives, or market fluctuations. Determining the appropriate estimation methods for variable consideration introduces challenges in accurately reflecting the total transaction price.  

• Identification of performance obligations: Defining performance obligations in broker-dealer transactions requires a nuanced understanding of the services provided. Determining whether services are distinct and should be accounted for separately can be subjective and may vary based on the specifics of each transaction.  

• Technology and data management: Many broker-dealers rely on sophisticated trading platforms and systems for their operations. Implementing ASC 606 often necessitates adjustments to these systems to capture and track the required data for accurate revenue recognition.  

• Transition from industry-specific guidance: Broker-dealers were accustomed to industry-specific guidance for revenue recognition before ASC 606. The transition to a more principles-based approach requires a shift in mindset and the development of new processes to align with the standard's overarching principles.  

• Documentation and disclosures: The standard introduces enhanced disclosure requirements, demanding comprehensive documentation and transparent reporting. Broker-dealers must invest time and resources in developing robust documentation processes to meet these disclosure obligations.  

• Impact on key financial metrics: Implementing ASC 606 can lead to significant changes in reported revenue figures and other key financial metrics. Broker-dealers need to anticipate and communicate these changes to stakeholders, managing potential concerns or misunderstandings about the impact on financial performance.  

• Training and education: The adoption of ASC 606 requires a solid understanding of the standard's principles among finance and accounting teams. Broker-dealers need to invest in training programs to ensure that their staff is equipped to apply the standard correctly and consistently across the organization.  

• Contract modifications and changes: Broker-dealer contracts are dynamic and may undergo modifications over time. Managing changes in contract terms and assessing their impact on revenue recognition adds another layer of complexity to compliance with ASC 606.  

• Audit and compliance assurance: Ensuring compliance with ASC 606 requires thorough audit processes. Broker-dealers need to work closely with auditors to address any complexities, provide documentation, and demonstrate adherence to the standard's requirements.  

ASC 606 has brought about a paradigm shift in how broker-dealers recognize revenue. Adhering to the principles outlined in ASC 606 requires a thorough understanding of complex financial transactions and the ability to apply the standard's provisions accurately. Successful implementation not only ensures compliance with accounting standards but also enhances transparency and consistency in financial reporting for broker-dealers.  

As the industry continues to evolve, staying abreast of regulatory changes and refining revenue recognition practices will be crucial for navigating the dynamic landscape. Let BerryDunn’s broker-dealer team help you navigate the effects of ASC 606, contact us with any questions.   

Read this if your parks and recreation agency has recently completed a master plan or is ready to update its master plan.

Your parks and recreation master plan was created with the goals and values of your community at its core. It’s part of what makes your community a great place to live, work, and play. It’s also a living document, designed to meet both current and future community needs—and to evolve as those needs change.

Establishing an ongoing process for updating your master plan helps your department keep pace with the priorities and interests of your community and builds strong support for your master planning efforts. Tracking and reporting progress on your master plan, utilizing a well-defined work plan is key to long-term, continuous improvement—and a master plan that helps your community thrive.

Below are six strategies to ensure a successful parks and recreation master plan implementation. These strategies reflect the commitment and discipline required to engage your staff and integrate the process into your daily operations, now and in the future.

1. Embed the plan

Your master plan becomes the roadmap for your department. It serves as a reference point that will guide decision-making as well as community response when new issues arise—it is a framework within which to evaluate potential changes or updates. To embed the master plan into your organizational knowledge base:

• Make the plan part of your new employee orientation program.
• Post the executive summary of the plan on your department website and track its progress. This helps the community at large understand the department’s strategic direction and its commitment to results.
• Make printed copies of the executive summary available to interested partners and community members to provide a quick snapshot of the plan.

2. Conquer and divide

Begin the implementation process by creating a project management team or assigning a staff member who will “champion” the project. Your project leader will be responsible for monitoring and reporting on the plan’s progress and working with other staff, county management, and other departments to effectively integrate the plan within your operations.

• Assign accountability for each master plan recommendation to a staff member or team. The project manager will have responsibility for tracking the progress of the master plan implementation.
• Divide the plan into separate fiscal years and track progress one year at a time as part of an ongoing work plan.
• Develop strategies for each action item in the plan. Strategies are developed prior to the start of each fiscal year by the staff members who are accountable for completing the action item.

3. Report and format

The department should regularly report on the progress of the master plan project. The formatting suggestions below will facilitate quarterly and annual reports from staff and/or team leaders.

• A best practice is to develop a spreadsheet or use strategic planning software to list the goals, objectives, action items, start dates, and completion dates for each fiscal year of your plan. Include the names of the staff members responsible for completing the action items.
• Each accountable team or staff member is responsible for reporting on the progress of their action item on a quarterly basis.

4. Tell the master plan story

It’s important to assess the progress of your master plan project and share updates with your staff, as well as your stakeholders and community, on a regular basis. Tell the story of your progress and accomplishments.

• Conduct staff meetings on a quarterly or semi-annual basis to review your progress.
• At the end of the year, perform an annual review of the master plan and document any changes to the objectives and action items in order to reflect changes in your department's priorities.
• This process can be included in an annual review meeting in which the next years’ objectives and action items are discussed as part of the annual budget process. Action items will tie into both the operating and capital budget process.
• Update your major stakeholders and the community on the plan’s implementation and results every year.

5. Monitor and revise the master plan

To keep the master plan actively on your staff’s radar—and embedded in your department’s knowledge base—visual aids can be an important tool.

• Post a chart of each year’s recommendations and action items on office walls in administrative areas, with a check-off column designating completion, as part of a visual management program.
• If new ideas surface during the year, include them on a written “parking lot” and review them as part of the annual project review to evaluate whether they should change or replace any existing strategies or action items.

6. Review and renew your master plan

The five-year mark is a good time to review and renew your parks and recreation master plan, which you have been tracking each year using the suggestions above.

• Conduct a shortened update process, which includes repeating the statistically valid survey and demographic projections that informed your current plan.
• Adjust existing recommendations as necessary, based on your review.

These six strategies for implementing your parks and recreation master plan will ensure that your master plan will continue to align with the needs and priorities of your community and become firmly embedded in the knowledge base and culture of your department.

BerryDunn works with parks, recreation, and library agencies across the country to help them strengthen their operations, innovate, and enhance services that benefit their communities. Learn more about our services and meet our team.

Read this if you are a FINOP.

We often see broker-dealers receive 12b-1 fees in the course of ordinary business. With these fees, we often see the broker-dealer acting as a pass-through, retaining these fees on its balance sheet until the ultimate payee requests such funds, typically for payment or reimbursement of expenses that are permissible to be paid from 12b-1 fees, as outlined in the distribution agreement. These fees can often be substantial and result in significant receivables on the broker-dealer’s balance sheet.

These receivables are generally considered unsecured and thus are not allowable assets for the purpose of calculating net capital under the Securities Exchange Act (SEA) Rule 15c3-1. However, in FINRA’s Regulatory Notice 21-27, published July 22, 2021, FINRA made updates to their interpretations of SEA Rule 15c3-1, which included adding an interpretation on unsecured receivables. This interpretation can be found in 15c3-1(c)(2)(iv)(C)/095 of FINRA’s interpretations. Specifically, broker-dealers may include unsecured receivables (such as 12b-1 fee receivables) as an allowable asset for purposes of calculating net capital if the following criteria are met:

1. The receivable is offset by a related payable.

2. A written contract exists between the broker-dealer and the payee, in which:

a. The broker-dealer’s liability for the amount payable is limited solely to the proceeds of the receivable; and
b. The payee waives payment of the amount payable until the broker-dealer has received payment of the related amount receivable; and

3. If the broker-dealer is subject to the Aggregate Indebtedness Standard of paragraph (a)(1)(i) of SEA Rule 15c3-1 and:

a. The portion of the payable due within 12 months is included in aggregate indebtedness; and
b. The broker-dealer’s net capital requirement shall be increased by an amount equal to 1% of the portion of the payable that was not included in aggregate indebtedness.

We often see 2b above being of most significance. It is essential that broker-dealers ensure such language is in their written contracts if they anticipate including 12b-1 fee receivables as an allowable asset in their net capital calculation. Being aware of this interpretation can also be helpful when initially writing distribution agreements, as broker-dealers can ensure such language is included in the original agreement, rather than possibly needing to revisit and amend at a later date.

Although technically a separate exercise, the above guidance can also have implications on revenue recognition. Broker-dealers must recognize revenue from contracts with customers under Accounting Standards Codification (ASC) Topic 606. Among other things, ASC Topic 606 establishes criteria for principal vs. agent considerations. In general, transactions in which the broker-dealer is determined to be acting in a principal capacity are recorded on a gross basis (the revenue and any related expenses are separately recorded on the broker-dealer’s income statement). In those instances where the broker-dealer determines it is acting as agent, the transaction is recorded on a net basis (the revenue and any related expenses are recorded on a net basis, with any residual revenue being recorded on the broker-dealer’s income statement).

Although the principal vs. agent determination is technically a separate exercise from determining if an asset is allowable or non-allowable, there could be some overlap amongst these exercises. For instance, ASC 606-10-55-39 provides various indicators to consider, one of which is “the entity is primarily responsible for fulfilling the promise to provide the specified good or service.” If the entity is primarily responsible, they are acting in a principal capacity. However, it could be determined the entity is not primarily responsible if they do not have a responsibility to make payment to the payee until they are in receipt of the funds.

That being said, even if this fact pattern exists, the other indicators listed in ASC 606-10-55-39 (and any others deemed to be relevant) still need to be considered in making the principal vs. agent determination. Furthermore, even if the broker-dealer is not obligated to pay the payee until they are in receipt of the 12b-1 fees, there may be other evidence that, when used in conjunction with this evidence, still makes the broker-dealer conclude it is acting in a principal capacity.

12b-1 fee receivables can be a significant portion of a broker-dealer’s assets. If determined to be non-allowable, this could have significant implications on a broker-dealer’s net capital compliance. However, as noted in 15c3-1(c)(2)(iv)(C)/095, such receivables can be considered allowable if certain criteria are met. It is important for broker-dealers who plan to include such receivables as allowable assets to closely review their 12b-1 fee arrangements to ensure these criteria are met. As always, if you have any questions, please don’t hesitate to reach out to the BerryDunn broker-dealer team.

Enterprise Resource Planning (ERP) systems provide a shared platform for people in your organization to work together––and the benefits can be game changing. That said, an effective strategy involves more than simply choosing the right software platform. Integrating your systems will change the way people in your organization work, and change can be challenging! For that reason, change management should be a key component of your ERP implementation project.

Here are eight key success factors to help guide your organization through an ERP implementation.

ERP implementation: The planning phase

ERP implementations rely on collaboration and communication across departments. So, from the start, set up your organization for success.

1. Stakeholder buy-in

Before you plunge in, you need everyone on board. That means helping employees understand the need for change and gaining buy-in from key stakeholders across departments who will help implement and later use the system. It’s critical to have senior management's sponsorship to reinforce decisions made along the way.

2. Strong project management

Establish your project management team right away. Create clearly defined roles and responsibilities, protocols for team collaboration, and project governance structures for decision-making. Senior management’s role is to set the tone and direction of the project and provide visible and active executive sponsorship throughout the process.

ERP implementation: The platform and vendor selection phase

The next milestone is to choose your ERP solution through an RFP process. The RFP should clearly define the functional and technical requirements of the ideal solution and also describe your organization’s business process.

3. Early vendor engagement

Engage vendors through pre-RFP activities such as vendor outreach sessions. This gives your team the opportunity to familiarize themselves with potential partners, explore options, and assess vendor compatibility issues.

4. Partner with the vendor

Plan the ERP implementation with your vendor. Based on the scope of work, set realistic expectations and timelines that take into consideration the staff involved and other responsibilities they may have. As soon as possible, work with the vendor to begin data conversion, interface planning, training, and testing.

ERP implementation: Launch phase

Organizations are often challenged during the ERP implementation process by their staff’s reluctance to accept new roles and responsibilities. An internal change management focus can help maintain staff confidence and keep stakeholders engaged.

5. Prepare your organization for change

Consistent communication is vital. Keep your employees engaged and empowered to do their best by providing regular updates, reaffirming confidence in your staff and empathy for their challenges, and showing active, visible executive support.

6. Test, test, test

In the course of an ERP implementation, you can expect crashes and bugs––even with the most well-designed software. Test at the early stages and continue throughout the implementation to ensure your ERP system functions properly and any issues are identified and fixed before going live.

7. Train, train, train

It’s easy to underestimate the time it takes to train people on new systems and processes. Discuss a plan for customized training with your vendor early on. To make end-user training successful, training should begin before the implementation phase and continue beyond it. Customize your training programs and materials and hold regular cross-functional team meetings.

ERP implementation: Stabilization phase

Stabilization is a process of optimizing your ERP system so that your organization can get the most out of its investment. This includes identifying post-go-live assistance, developing a plan for further training and support, and confirming roles and responsibilities for IT and key users of the system.

8. Reinforce the change

Continue to communicate with your staff about the reasons you began your ERP journey in the first place––the benefits of sticking with the plan. Embed the ERP system within your culture and practices, beware of backsliding, and develop a plan for maintenance and continuous improvement.

BerryDunn’s local government team partners with municipal, county, regional, and quasi-governmental entities to meet the most critical needs of your community. Whether we’re helping clients with strategic planning, economic development, public safety, or organizational excellence, we take pride in tailoring our projects to fit your unique needs, either at the enterprise level or within and across departments. We care about what we do, and we care about the people impacted by our work.  

BerryDunn provides ERP consulting to local and state governments, higher education institutions, and for-profit organizations. Learn more about our ERP consulting services.