Skip to Main Content


Gain perspectivesThought leadership


Read this if you are an administrator, compliance officer, or health information management/medical records professional at a Medicare skilled nursing facility.

The Office for Civil Rights (OCR) at the US Department of Health and Human Services is responsible for ensuring patients’ rights to timely access to health records. Since the start of 2024, the OCR has issued two settlements with skilled nursing facilities (SNFs) under the OCR Right of Access Initiative. Both settlements were related to potential violations under the Health Insurance Portability and Accountability Act (HIPAA) Right of Access provision, which requires that individuals or their personal representatives have timely access to their health information.

As a HIPAA-covered entity, a SNF must provide access to the individual’s protected health information within 30 days of receiving a request from the patient or the patient’s personal representative, such as a guardian. In both recent SNF right of access cases, the OCR noted that access was not provided to the patients’ personal representative in a timely manner (161 days and 323 days, respectively). 

Both settlements, which were published on the OCR’s website, led to the imposition of significant civil money penalties (CMPs) against the SNFs. In one case, the OCR imposed a CMP of $100,000, which was not contested by the SNF. In the second case, the SNF challenged the imposition of a $75,000 CMP and agreed to a $35,000 settlement.

Other non-financial outcomes of an OCR Right of Access Settlement

In addition to the financial and reputational implications of an OCR Right of Access Settlement, a SNF must also undertake the following actions:

  • Revise and obtain the OCR’s approval of any noncompliant HIPAA policies and procedures (P&P) 
  • Provide the OCR with copies of all training materials that the SNF must use to train its workforce about the revised HIPAA P&P
  • Submit and obtain the OCR’s approval of the training plan outlining the topics to be covered, when the sessions will be held, and the names of the trainers
  • Send a signed attestation to the OCR documenting when the trainings have been completed


  • A patient or their personal representative may file a complaint directly with the Office for Civil Rights in writing, by email, by fax, or electronically via the OCR’s Complaint Portal
  • Subject to certain exceptions, the Privacy Rule at 45 CFR 164.502(g) requires covered entities to treat an individual’s personal representative as the individual with respect to uses and disclosures of the individual’s protected health information, as well as the individual’s rights under the rule. The personal representative “stands in the shoes” of the individual and can act for the individual and exercise the individual’s rights.

Actionable items to help ensure compliance with the Privacy Rule

  • Periodically (we suggest at least annually) check your SNF’s policies, procedures, and workflows that focus on access to medical records. We recommend you review:
    • Documentation of the turn-around times (TATs) for processing requests
    • The process for informing your patient or the patient’s representative, in writing and within the initial 30-day period if a request for records cannot be accommodated within 30 calendar days (only one extension may be made for an additional 30 days)
    • That the correspondence template provides a written statement of the reasons for the delay and the date when the SNF will complete its action on the request
  • Confirm that your SNF’s access to medical records timelines complies with your state’s requirements, as they may be more restrictive than the federal regulations. For example, California requires a 15-calendar day turnaround time while Texas requires action within 15 business days. Be aware that the OCR issued a Notice of Public Rulemaking on December 10, 2020, proposing that its current 30-day rule be decreased to 15 days. This change in federal rules has not yet gone into effect, but it is still expected and your SNF should be prepared. 
  • Maintain a log of medical records requests, including date received, person requesting, response due date, person responsible for completion of the request, and person assigned to review the record prior to release (such as Director of Nursing, Administrator) for completeness. 
  • We also recommend reviewing BerryDunn’s resource, Best Practices for Responding to Medical Record Requests in Healthcare Compliance Insights.

Need help assessing your SNF’s HIPAA program? BerryDunn can help.

BerryDunn’s SNF operations, compliance, and HIPAA privacy experts can answer your questions and provide an external review of policies, procedures, workflows, and training tools. Please contact Trisha Lee, Robyn Hoffmann, or Olga Gross-Balzano


SNFs and HIPAA Right of Access: Understand the requirements and avoid costly penalties

At first glance, the healthcare patient check-in process seems straightforward. But when examined through the lens of your revenue cycle and patient experience, it’s one of the most important interactions for your team to get right.

Several key elements must be taken into consideration to create a smooth and simple patient check-in. Patient satisfaction is the tip of the iceberg. You want your patients to have a great experience that is efficient, easy-to-understand, and doesn’t create billing headaches for them later on. The good news is that the same techniques that give your patients a good experience also form the basis for an optimal revenue cycle. Developing this process starts with the undersurface elements that patients never see.

Scripting for patient access teams

Communicating clearly, consistently, and positively is important to put patients at ease, and to make sure that you collect the most accurate and up-to-date information from patients. Doing this correctly up front will save time and will prevent denials and associated workload and revenue loss. The best practice is to establish scripting for your patient access staff and provide training to make sure they are confident in the scripting provided. Here are some examples:

When confirming that patient information is up to date:

Say this: “To ensure your account is as accurate as possible, we require all patients to present a minimum amount of information.”

Not that: “Have there been any changes in your information since the last time you were here?”

Or when connecting a self-pay patient with a financial counselor:

Say this: “Before scheduling your appointment, I will connect with a financial counselor who can determine if you qualify for assistance and will help you understand your financial obligations.”

Not that: “We can’t schedule you until you speak with someone in Finance.”

Developing clear and efficient scripting will give your team the tools to communicate effectively and will help your patients feel like they are well taken care of.

Schegistration: What is it? 

What is “schegistration” anyway? Schegistration is the process of scheduling a patient appointment while also pre-registering the patient at the same time. By gathering and confirming information at the time of scheduling, the in-person check-in process will have fewer steps and will be quicker and easier for both the patient and your team.

Technology: Align your EHR with patient access workflows

Technology, specifically your Electronic Health Record (EHR), can either make your workflows more efficient, or can hinder your patient access staff. It’s important to align your technology platforms with your operational workflows, so it is seamless for your staff to enter and pull up information. It’s also important to have your staff trained regularly on your technology systems so they feel confident that they are using the system correctly and most efficiently.

Documentation: Write it down! 

When you develop new workflows to increase efficiency and the patient experience, it can be challenging for staff to make the change. In a busy office environment, it can also be difficult to train new staff effectively. To make it easy and to create consistency and continuity, it’s important to develop standard operating procedures and to document them thoroughly. Providing easy to understand instructions, including visuals of workflows, will reduce errors, promote standardization, and improve accountability.

Leadership: Reinforce best practice workflows

Keeping workflows optimized takes the whole team, beginning with leadership. The leaders of your patient access team should act as reinforcement when team members learn and complete best practice check-in workflows. Having documentation readily available and providing support and encouragement to team members will help keep your processes running smoothly.

Patient access team collaboration

Establish clear expectations to foster a supportive team environment and facilitate problem-solving and quick assistance. When scripting, workflows, and documentation are consistent, it’s easy for team members to help each other out and support each other when challenges arise.

The healthcare revenue cycle is an intricate system involving interdependent functions. Like an ecosystem, each component plays an important role in the system. The patient access process is just one piece of the puzzle. Optimizing your revenue cycle also includes looking at these areas: coding and compliance, billing, and denial management.

BerryDunn's audit, tax, clinical, and consulting professionals, focused on specific healthcare industry areas, understand the biggest challenges facing healthcare leaders, and are committed to helping you meet and exceed regulatory requirements, maximize your revenue, minimize your risk, improve your operations—and most importantly—facilitate positive outcomes. Learn more about our healthcare consulting team

Optimizing revenue cycle processes: Patient check-in

Read this if your organization uses provider-based billing. 

Like an old car rusting in a field, provider-based billing is not something that gets much attention. Hospitals have set up departments to manage it, completed their attestations (or not), and then forgotten about it, leaving it to rust in the field. Provider-based billing is one of those things that is not a problem until it is. There are many reasons why hospitals may want to review their provider-based billing processes:

  1. Facility updates are constant in healthcare and departments may have moved since their initial inceptions
  2. Hospital acquisitions and mergers have changed ownership structures and may have removed grandfather status protections
  3. When leadership changes, new leadership often assumes that everything was set up and is being billed correctly
  4. Commercial payor guidance has and continues to change 
  5. CMS provider-based rules have changed

Many hospitals move department locations and do not give much thought to the claim implications. Besides address, enrollment, and credentialing updates that may or may not be needed, the move may make the department ineligible to continue provider-based billing because it no longer meets the criteria under the updated regulations.

Attestations for smoother audits

Very few hospitals have a library where they can easily access all their attestations. Many providers don’t ever submit an attestation to Medicare as they are not required to do so. However, not having one opens the hospital to more risk if the department is ever deemed non-compliant with the regulations. If the hospital has a library of all attestations, an audit can be a quick and painless experience. The audit would involve:

  • Confirming nothing has changed since the attestation in terms of location and structure
  • Reviewing some claims to identify if charges are split and billed correctly
  • Ascertaining if payor rules are being followed
  • Checking that signage is correct in the lobby of provider-based locations.
  • Reviewing the 855 form and confirming the required departments are listed

If an attestation is not available, the audit becomes more difficult. If the department is on the main campus and meets all the provider-based rules, the audit easily follows the above steps. If the department is not on the main campus, the audit becomes more challenging, as you would need to confirm:

  • The department is located within 35 miles of the main campus
  • If the department is or was grandfathered and doesn’t need to meet the requirements
  • If an attestation should be completed
  • How/when was the department created, and what other facts pertaining to its inception are relevant  

Difficulties arise when a hospital identifies that a department does not meet the current criteria and an attestation is not available. Simply stopping billing as provider-based billing is not sufficient as there are False-Claim Act and other compliance implications. Regardless of the remedy, identifying these issues on your own—as opposed to during an external audit—is certainly better. It will provide you time to fully research the situation and confirm if there is or is not really a concern. If it is confirmed that billing was incorrect, proactively self-disclosing the issues is certainly better than defending an audit. 

Proactive audits for peace of mind

You may be wondering why we are writing about provider-based billing now. The reality is that we are seeing more provider-based billing issues both with our clients and across the country. Hospitals are very busy and there is simply not enough time to worry about everything. This is an area where a quick audit can bring peace of mind and also force your teams to become reacquainted with the updated regulations and safeguard against future problems. 

BerryDunn has assisted several health systems with auditing and working through provider-based concerns. Our experts are available to support clients with questions or concerns about their provider-based departments. If you have questions about your specific situation, please don’t hesitate to contact us. We’re here to help.

Provider-based billing: An ounce of prevention

Non-profit financial statements include a wealth of important knowledge and can often be overwhelming. When sharing your financial statements with your board of directors or other stakeholders, it can be useful to simplify your financial statements so the key information stands out and unimportant information doesn’t cause confusion. In our work with independent schools and other non-profit clients, we’ve seen many ways that financial statements can be simplified to paint a clearer picture of your organization’s health.

Engage with stakeholders to improve your financial statements 

Boards, donors, creditors, and other stakeholders gain key insights to a non-profit's financial status through reading the financial statements, allowing them to make informed strategic decisions. These reports also allow for improving communication between organizations and their stakeholders. Financial reporting additionally provides historical knowledge that can assist with strategic planning and forecasting.

As a first step in improving the ease with which your financial statements can be read, proactively engage with your stakeholders to gather feedback on the effectiveness and clarity of your current financial statements. To do this, consider conducting informational sessions or webinars to explain changes and address questions. Make sure to understand the needs of your stakeholders and what financial statement items they are most interested in and tailor disclosures to address their concerns and the items that matter most to them.

Simplify your financial statement disclosures 

For any financial statements that are to be issued in accordance with US generally accepted accounting principles (US GAAP), there are a certain number of required disclosures. Subject to materiality, for each financial statement line item, there is a related disclosure, and any item in your financial information that is material should be disclosed. As a general rule, if a trial balance account is less than 5% of total revenue, it could be grouped into an “other” category instead of being presented as a separate financial statement line item. This can also be done on the statement of financial position, but using 5% of total assets or total liabilities. Removing these smaller items can put more focus on the important items within your financial statements.

Another way to simplify your financial statements is to consider removing some small, fixed assets from your statements. For example, the purchase of an office printer could technically be considered a fixed asset to be capitalized, but it’s likely not worth the effort—and it makes the financial statement look more complex than necessary. Consider implementing a financial statement capitalization policy that determines a dollar limit threshold for capitalizing fixed assets and expensing items under that threshold.

Remove disclosures once they’re no longer needed  

Other common items that can increase the length of financial statements are disclosures related to the implementation of new accounting policies. In the year of adoption, footnotes are required to explain the impact of the adoption. In following years, not as many disclosures are necessary and can be removed. Ensure that information that is remaining after the year of adoption is either required under US GAAP or is necessary to stakeholders. If it’s not, remove it.

Take ownership of your financial statements 

Although your CPA firm might assist with the preparation of the financial statements, the ultimate responsibility rests on your organization’s management team to produce financial statements in accordance with US GAAP and satisfy the needs of your stakeholders. Ensuring your financial statements are optimized opens a great opportunity for you to sit down with your audit team and discuss your needs. Contact us at any time to set up a meeting and learn more.

Optimizing financial statements for independent schools

Read this if your organization is looking to make an elective pay election.

The Department of the Treasury and the IRS on March 5 released final regulations (TD 9988) on the elective pay election for certain energy tax credits under IRC Section 6417, added by the Inflation Reduction Act (IRA), which treats the credits as a  payment against federal income tax liabilities. 

The final regulations adopt the proposed regulations (REG-101607-23) with some modifications that clarify which applicable entities are eligible to make an elective pay election and how the election should be made. 

The IRS also updated the elective payment frequently asked questions based on the final regulations. Finally, the IRS issued Notice 2024-27, which requests additional comments on any situations in which an elective payment election could be made for a clean energy credit that was purchased in a transfer,  a sequence of events referred to as chaining.    


The IRA introduced, for tax years beginning after December 31, 2022, the ability for some entities to monetize applicable tax credits via an “elective pay” election under IRC Section 6417. This allows applicable entities to treat certain credits as payment against their federal income tax liabilities and to receive a refund of any excess payment.  

Eligible credits and entities

The IRA specifies that only some credits and entities are eligible for the elective pay election under Section 6417. Applicable credits include: 

Credit for Alternative Fuel Vehicle Refueling/Recharging Property (Section 30C) Advanced Manufacturing Production Credit (Section 45X)
Renewable Electricity Production Credit (Section 45) Clean Electricity Production Credit (Section 45Y)
Carbon Oxide Sequestration Credit (Section 45Q) Energy Credit (Section 48)
Zero-Emission Nuclear Power Production Credit (Section 45U) Qualifying Advanced Energy Project Credit (Section 48C)  
Clean Hydrogen Production Credit (Section 45V) Clean Electricity Investment Credit (Section 48E)
Commercial Clean Vehicle Credit (Section 45W) - Tax-exempt entities only 

Eligible entities, referred to as “applicable entities,” include: 

  • Tax-exempt organizations
  • Any state, the District of Columbia, or political subdivision 
  • An Indian tribal government or subdivision 
  • Any Alaska native corporation 
  • The Tennessee Valley Authority 
  • Rural electric cooperatives
  • An agency or instrumentality of certain applicable entities


While the final regulations bring clarity to the issue of determining which entities are eligible to make an elective pay election, they notably exclude partnerships from making such an election (except with respect to Section 45V, 45Q, and 45X credits). This exclusion has significant implications for the renewable energy sector, where projects are commonly structured as partnership entities to pool capital, diversify risk, and combine the expertise of various entity partners. 

During the comment period on the proposed regulations, several commenters advocated for the inclusion of mixed partnerships—that is, partnerships that consist of both applicable entity and non-applicable entity partners—as applicable entities to allow for an elective payment election equal to the applicable entity partner’s allocable credit. However, the Treasury and the IRS rejected those suggestions and adopted the regulations as originally proposed.

However, the final regulations do allow entities to make a valid election out of Subchapter K as a means for these entities to make an elective pay election. Feedback from commenters highlights the complexities and burdensome requirements that arise from making such an election out of Subchapter K, limiting its usefulness. The Treasury and the IRS acknowledged such challenges and simultaneously issued proposed regulations under Section 761 for renewable energy projects that validly elect out of Subchapter K. Under the proposed regulations, exceptions would allow certain unincorporated organizations to make an elective pay election. 

Tax-exempt grants and loans

The final regulations adopt special rules regarding qualified energy property acquired using certain tax-exempt grants and forgivable loans. The rules state that (1) tax-exempt amounts are includable in the basis of the property and (2) “no excess benefit” can be derived from the use of restricted tax-exempt amounts used towards acquiring investment-related credit property. 

The addition of the “no excess benefit” rule effectively limits the amount of the applicable credit that can be claimed such that the sum of any restricted tax-exempt amount(s) and the applicable credit does not exceed the cost of the investment-related credit property. This rule applies only to tax-exempt amounts that are restricted for the specific use of purchasing, constructing, reconstructing, erecting, or acquiring the investment-related credit property. The final regulations include examples to illustrate this rule.  

Making the election

To participate in the elective pay election, all credits must undergo a prefiling registration process and the applicable entity must secure a valid registration number. Credits can be registered as early as the first day of the taxable year in which the qualified energy property is placed in service. Any election received by the IRS without a valid registration number will be deemed ineligible. As currently established, a “short form” renewal process for multiyear credits such as the production tax credit is not available. A new registration must be submitted each year a credit is generated. 

Applicable entities that already file an annual tax return would continue to file that return with the appropriate tax credit form and Form 3800 completed. Applicable entities that do not file an annual information return with the IRS would utilize Form 990-T. Note that the elective pay election must be made on an originally filed return (including extensions) and cannot be made on an amended return. 

The final regulations also confirm that fiscal year organizations that do not normally have tax filing requirements may adopt a tax year-end different from its current accounting year-end. Such organizations are required to maintain adequate books and records of any differences between their normal fiscal year-end books and adopted tax year-end books. This provides increased opportunity for organizations that placed qualified energy property in service early in 2023 and otherwise would have been excluded from a tax credit benefit. 

Processing of payments

The Treasury and the IRS opted not to define a specific time frame for processing payment of an elective pay election, instead indicating in the preamble that the prefiling registration process is designed to verify certain limited information in advance and mitigate the risk of delayed payment processing by the IRS. 

The final regulations additionally confirm that applicable entities that choose to make this election will receive payment in one lump sum as opposed to multiple payments. Some commenters had suggested an accelerated payment mechanism that would enable applicable entities to submit the election as early as the placed-in-service date of the qualified energy property, thus enabling the IRS to provide pre-payment of a portion of the applicable credit based on a review of the prefiling registration information. Given that the elective payment amount is treated as made when a credit claim or the annual tax return is filed, the Treasury and the IRS concluded that it would not be possible to implement this mechanism. 

Written by Leah Turner, Aaron Wright, and Gabe Rubio. Copyright ©2024 BDO USA, P.C. All rights reserved.

Treasury, IRS release final regulations on elective pay election for energy tax credits

The Federal Deposit Insurance Corporation (FDIC) recently issued its fourth quarter 2023 Quarterly Banking Profile. The report provides financial information based on Call Reports filed by 4,587 FDIC-insured commercial banks and savings institutions. The report also contains a section specific to community bank performance. In fourth quarter 2023, this section included the financial information of 4,140 FDIC-insured community banks. BerryDunn’s key takeaways from the report are as follows:

Community banks’ full year net income down $2 billion from 2022.

Full-year net income declined 7.1% in 2023 to $26.6 billion from $28.6 billion in 2022. Quarterly net income for community banks declined 9.9% in fourth quarter 2023, a $650.2 million decrease from the prior quarter resulting in $5.9 billion in quarterly net income. Compared to fourth quarter 2022, net income had decreased $1.9 billion, or 24.7%. More than half (59.7%) of all community banks reported a decline in net income compared to third quarter 2023. Net income for community banks was impacted by higher noninterest expense, lower noninterest income, and increased loan loss provisions.

Community banks’ net interest margins (NIM) remain constant in the fourth quarter at 3.35%.

Despite remaining consistent quarter-over-quarter, NIM was down 36 basis points from the year-ago quarter. The yield on earning assets increased 88 basis points while the cost of funds increased 124 basis points. Despite the significant decline, the community banks’ NIM performance continued to prevail over the overall banking industry’s NIM of 3.28%, which declined three basis points in fourth quarter 2023. Despite the decline, the banking industry’s NIM remained three basis points above the pre-pandemic average NIM of 3.25%.

Loan  and lease balances continued to grow in fourth quarter 2023, with 76.2% of community banks reporting quarterly loan growth. 

Loan and lease balances continued to see widespread growth in fourth quarter 2023. Community banks saw loan growth in all major portfolios. Residential real estate loans exhibited the most growth from the third quarter at 1.9%, followed closely by nonfarm, nonresidential CRE loans at 1.6%. Total loans and leases grew 7.9% from one year ago. This year-over-year growth was also driven by residential real estate and nonfarm, nonresidential CRE loans, which showed growth year-over-year of 10.1% and 7.2%, respectively.

Community banking: When one door closes, another opens

With many calendar year-end institutions having wrapped up, or in the process of wrapping up year-end financial statement audits, it is starting to feel as if we can finally put a cap on 2023. What a year it was! Although the above analytics might not paint the rosiest of pictures, with full-year net income having slid 7.1%, there is still a lot to celebrate from 2023. On the financial side, loan demand continued to remain relatively strong, especially given the challenging rate environment, with loan balances having grown 7.9% from one year ago. Deposit balances, although not matching the growth in loans, also increased from one year ago, having increased 2.3%. Although inflation remained stubborn throughout 2023 and thus far through 2024, the prospects of a “soft landing” have grown for many, with unemployment remaining at historic lows. Recently, the Fed signaled they hope to cut interest rates three times in 2024, although this seems to be a moving target, given inflation’s persistence. 

Let’s not forget, 2023 marked the year of adoption of the current expected credit loss (CECL) standard for many institutions. This is a monumental change for institutions, which completely overhauls the way institutions think about their allowance for loan losses. Not only did allowance calculations get completely revamped, many now relying significantly on vendors and peer data but as a result, processes, internal controls, and documentation also changed significantly from the previous incurred loss methodology. It is fitting for all of us to take a deep breath, as it feels as if we’ve all held our breath for the last few years leading up to adoption. We made it. Most of us are finally on the other side of an accounting standard that was issued seven years ago—and was partly a response to a crisis that occurred 15 years ago. 

Although there may be future adjustments and iterations, the CECL standard is here to stay. So, once we take that deep breath, it’s time to dig back in and continue to refine and build upon the calculation and processes we’ve implemented in 2023. We’ve come to learn that, among other things, documentation is key under the CECL methodology, arguably more so than under the incurred loss methodology, and thus should continue to be a focus in 2024.

It may be hard to believe, but it’s been just over a year since the bank failures of March 2023. This was a scary time for the banking industry, as uncertainty set in as to whether your institution could be next. But, for many institutions, this event can be looked back on as a positive moment in 2023. This event brought the differences in banks, community vs. regional vs. global, to the spotlight, allowing community bankers to showcase their differences, highlighting how community-oriented your institutions really are.

So, with that, we give a salute to 2023 and look ahead to 2024. We’ve learned a lot and we have 2023, in part, to thank for that. If quarter one is any indication, we’re in for another rollercoaster of a ride in 2024. Artificial intelligence, including “Gen AI,” continues to dominate headlines, the Fed continues to humor the idea of cutting interest rates, and let’s not forget, 2024 is an election year. But what is a “normal” year anymore? If anything, the last few years have exemplified just how resilient the community banking space really is and have given us the tools and confidence to adapt to change in nearly real-time. In other words, bring it on, 2024. As always, BerryDunn’s Financial Services team will be right alongside you, navigating every rise, bump, and drop of this rollercoaster ride.

FDIC Issues its Fourth Quarter 2023 Quarterly Banking Profile

Did you know that one in 36 children is diagnosed with autism, with many children and adults alike left undiagnosed? In addition, one in six people claim a sensory need or sensitivity. These sensitivities can create challenges for enjoying public spaces, just as physical limitations do.

Parks and recreation agencies, like any public-serving organization, have an obligation to equally serve all members of their communities. But knowing that something must be done is not the same thing as knowing how to approach it. As heard in a recent episode of the Let’s Talk Parks with BerryDunn podcast, host Becky Dunlap spoke with Meredith Tekin, President of the International Board of Credentialing and Continuing Education Standards (IBCCES), and Lane Gram, Manager for Parks and Recreation in Gilbert, Arizona, about how the town is undertaking the endeavor of making their parks and facilities accessible and enjoyable for all.

For the Town of Gilbert, inclusivity is a strategic priority. Their goal was for accessibility to extend beyond physical modifications, and into the heart of the experiences that their parks provide. Below are four of the key takeaways from their journey to having several of their parks and facilities designated as Certified Autism Centers.

Seek out the inclusivity experts

The Town of Gilbert realized they had some blind spots and didn’t have the best practice expertise to address inclusivity on their own. To solve this problem, they decided to seek the guidance, and certification from, the International Board of Credentialing and Continuing Education Standards (IBCCES). IBCCES is a global leader in professional autism and neurodiversity training and offers various certifications that can be earned by meeting their stringent criteria, including an Autism Certification for Parks and Recreation Departments.

Meredith Tekin, President of IBCCES, describes how they help organizations: “IBCCES works with a variety of organizations and industries for our certification programs. When you become certified, first and foremost, you do have a third-party, IBCCES, that is there to support you, provide recommendations and guidance for areas that your staff doesn't have intimate knowledge of. And we're here not only for the training portion, but throughout the lifetime of the certification.”

Be proactive about knowing the needs of your community 

Often, for those who are not neurodivergent, it can seem like a guessing game when trying to figure out how to be inclusive in ways that matter. It may take a bad experience and a complaint before it’s clear what is needed. To avoid this, in Gilbert, they took a proactive approach.

Lane explains, “For the Town of Gilbert, the process to become certified really started with our registration process and wanting the members of our community to feel like we were open to individuals with disabilities or special needs of any kind being involved in our programs. We added questions to our registration process to make people feel more comfortable in providing information [about which accommodations they need] and from there then we started with the training for the employees and all staff, at every level.”

This proactive approach makes it easy for the community to express their needs and allows the town to anticipate those needs ahead of time. As one example, they now offer a “quiet tent” at their 4th of July celebration where they provide noise-cancelling headphones and other comforts for those who need to take a break from the noise from fireworks and crowds.

Focus on inclusivity training for all parks and recreation staff

Training is a critical part of the IBCCES certification process. "To be considered a certified autism center, the baseline is that at least 80% or more of the public-facing staff have to complete some level of training with us. So, for an organization like a parks and recreation department, we train the staff, we have multiple levels and types of training depending on that person’s role and how they interact with the public,” explained Meredith.

Lane found the training incredibly helpful in giving staff members the understanding and communication tools to be more inclusive. She said, “A lot of other benefits came along with it, just general sensitivity and awareness for our staff to be treating everyone in the general community with respect and not just making a judgment based on what they might look like or how they're behaving. And so, for our staff, I think it's just making them better people and better stewards for the community and providing a better opportunity for community members to be involved in our programs.”

She gave an example of the impact: During a road shutdown, a bicyclist was in visible distress about changing their regular route. Understanding that this was a big deal to that person, and wanting them to have a good experience, the staff found a way for the cyclist to continue on their usual route that was not disruptive to the work they were doing. It may sound simple, but the staff used compassion and problem solving to create a better experience for that particular person.

Overcommunicate and prioritize inclusive services

For those with special needs, physical or otherwise, it’s incredibly important to have information available ahead of time. A site can be technically “accessible,” but is it accessible for the specific person who wants to go there? A person with mobility issues may be able to walk fine on certain surfaces, but may have issues with a particular type of surface. They want to know before they go that they’ll be able to get around and have a good experience--or know that it’s not a place where they will feel at ease so they can avoid it.

According to Meredith, “If you think you're over-communicating, you're probably doing just enough.” IBCCES recommends an easy to find website that gives as much detail as possible about the location or facility. 360-degree video tours, sensory guides, and photos are all good options for helping the community understand what they can expect. On-site, it’s also important to clearly communicate, via symbol-based signage, so people can easily find restrooms, parking, and other facilities at the location.

As part of the IBCCES certification, the organization provides sensory guides that rate on a scale of 1 to 10 the intensity of touch, taste, sound, sight, and smell experiences at each location, and provides a narrative about the types of experiences one can expect. This is an easy-to-understand tool that can help those with sensitivities plan ahead and choose activities that are best for them.

So, where to begin? For Gilbert, AZ, the process began by making accessibility and inclusivity a top priority as they partnered with BerryDunn on their most recent master plan. Highlighting inclusivity initiatives at the highest level of planning is critical in helping ensure that strategies are put into place throughout the organization to support these efforts in a holistic way.

For more ideas on how to create inclusive spaces, listen to the full conversation

BerryDunn works with parks, recreation, and library organizations across the US to help them strengthen operations, innovate, and enhance services that benefit their communities. We bring decades of experience working in public service in similar roles as our clients. Our expertise includes strategic and master planning, pricing and cost recovery, feasibility studies, and organizational and operational assessments, including recreation assessments. Learn more about our team and services. 

Expanding inclusivity: Making parks inclusive for those with autism

“Tell me and I forget. Teach me and I remember. Involve me and I learn.” — Benjamin Franklin

Investing in your staff is key to any successful organization. Having the wherewithal to be able to train a group of people, some willing and some unwilling, can be a daunting task. Yet, no matter how difficult to manage or how time-involving training is, it is an essential part of both a successful EHR go-live and maintenance of a system. No matter how technologically advanced the new EHR system may be, if an organization slacks on the training, it will never see the full return on investment of the cost of the system.

From years of implementation experience, I have compiled the five best practice methods to enable an organization to reach its maximal return on investment and user satisfaction with an EHR system.

EHR superuser training

A superuser doesn’t need to be the most technically savvy user, but they need to be able to be teachable and to transfer that learned knowledge to the other staff. These users should be the first to experience a new system. Oftentimes, some of these staff members would have been involved in the selection process. They are the organization’s first-line users and defenders of the new EHR functionality, and the ones that others turn to when they need help. Therefore, they are called super. For best results, there should be, at minimum, one superuser per specialty per every 15 users. At the time of go-live, these superusers need to be relieved of all their routine duties and focus on assisting the staff with the EHR adoption during the go-live dates.

EHR User Acceptance Testing (UAT)

It may say testing, but this is also a training method, and it should involve those already trained as superusers. UAT is time utilized as a field training exercise for your newly trained and specialty experienced superusers to test the system for proper process workflow in all fields of expertise. A testing script should be utilized for each process workflow and there should be room on that script for comments from the testers on improvements that need to be made prior to staff training. Each moment the superusers work on the testing scripts is a training exercise in navigating the system and making them comfortable with teaching their peers at the next venture.

EHR End User Training (EUT): The see, touch, and repeat approach

Training can be performed in many forms. As an organization, a decision on which format of training works best must be decided upon and then kept consistent. Methods of training could be in person, virtual, or online. The key to successful training, no matter which plan an organization chooses, is to involve the "see, touch, and repeat" approach to learning. Trainees should see the system in action, touch the keyboards or tablets and follow along with the instructor or through a written scenario, and repeat the processes multiple times at their own leisure in a testing environment. Implementing this method allows all generations of users in the organization to be properly trained on the new EHR.

In-person classes should be:

  • Separated by specialty or process
  • Involve manageable group sizes (one user per computer)
  • Include a brief overview of the EHR
  • Include a demonstration of the process workflow in action
  • Be followed by the user repeating the process on their own device

If there are more than two hours of content to train on, the recommendation is to divide the training into smaller durations to maximize the effects of learning.

Virtual classes involve an instructor performing the same steps as in-person training, but the end user attends from their office or a designated learning area. These can be pre-recorded and the EUT can occur during the optimal time for the user to have complete devotion to the training. In these instances, logins to the testing/training site need to be given out in a separate communication, and these logins should be single-user available, as to avoid complications from locked accounts if many end users are training at the same time. A trainer needs to have availability for questions if this process is utilized.

Online classes involve pre-recorded demonstrations that are included with process workflow scenarios. In these, the end user goes to a training site and watches sections of demonstrations one at a time. At the end of each section, the user may rewatch the online demonstration as many times as they need to, but there must be a self-paced scenario that the user follows along to perform the touch and repeat portion of the learning. Additionally, there needs to be contact information for a trainer should there be issues or questions. Many organizations utilizing this method of training allow the end user access to these training videos for refreshers once the EHR implementation has occurred.

EHR Just In Time (JIT) and At the Elbow (ATE) training

The JIT/ATE training is essential during and post go-live. Once an organization implements the EHR, there is always going to be someone who did not complete the training. That is where the superusers become involved and train these individuals in their time of need. These short, microburst, JIT trainings may involve a superuser hovering nearby the new user as they navigate through a documentation for the very first time. ATE training involves a superuser reaching out to a user who has had training but may have forgotten steps involved to complete the documentation. These are the times that those superusers show how super they are.

Post implementation of the EHR, as the superusers resume their normal duties, there will still be a need for JIT/ATE training, and their expertise will be sought out after by their peers, further assisting in a successful adoption of an EHR. In addition to the superusers, if available, a dedicated informatics employee should be making frequent rounding, looking out for those who may be struggling with the EHR documentation processes and workflows, and performing JIT/ATE training at these discovered instances.

EHR training refreshers and audits

“There are no shortcuts to any place worth going.” – Beverly Sills

This final stage of training is continuous. Once you have an EHR, there will always be a need for training. No matter how successful your training may have been, habits and shortcuts to documenting in an EHR are bound to occur, and then spread throughout the organization. For the most part, these shortcuts result in mis-documentation; audits must be performed to determine how detrimental to proper documentation they are. Once the issues have been identified, the organization must determine how to correct the issue. Sometimes this involves going directly to the end user whose documentation is at subpar levels and performing JIT/ATE training. If it is widespread, a refresher course for all end users may be required to correct the issues. Sometimes a communication of corrective action may work in substitution for JIT/ATE training.

“Don’t decrease the goal. Increase the effort.” — Tom Coleman

Regardless of the effort, all end users should have a contact to reach out to for assistance post EHR go-live and the ability to access a training site as needed. New hire training sessions should continue to be optimizable on documentation.

BerryDunn’s team of consultants is happy to assist you with creating a Request for Proposal, selecting the right EHR vendor for your organization, developing communication, change management, training plans, and project management for the system implementation.

Training: The key to a successful EHR go-live

Read this if you are interested in leadership.

Every successful leader uses their knowledge of their individual strengths, the mentorship of other leaders, and their driving purpose to create an authentic leadership style unique to them and their organization.

Recently, Sarah Belliveau, BerryDunn’s CEO, shared with Shawn Tuttle, the firm’s Director of Learning and Development, some insight into how she has navigated the different stages of her leadership journey. From joining the firm while still in college, to managing and developing the firm’s Not-for-Profit team, to leading the organization through challenging times, Sarah has leaned on her strengths, her colleagues, and her purpose to guide her. 

This conversation has been excerpted from the podcast BerryDunn Leadership Insights. Listen to the full conversation here

Career stage: Early career

Key strategies: Finding the right fit, advocating for yourself 

Shawn Tuttle: I thought maybe we could start with just hearing a little bit more about your journey at BerryDunn. I've heard you talk about being the first intern.

Sarah Belliveau: That's my favorite self-appointed title. That last semester at school, I needed a part-time job because I was paying my way through school and so I reached out to the principal in charge of our Bangor [Maine] office at the time, who had hired me [to begin full-time work in the summer], and I said I've got a relatively light load, if you have an opportunity for me, I'd love to start working. And so, I worked part-time while I was finishing up at school. And so, what struck me right out of the gate with BerryDunn is that that decision to allow me to do that was not for the benefit of BerryDunn, it was not because they had a need. They'd already done their hiring for the winter. It was because I had a need, and they took that into consideration and were concerned about me as a whole person. That was probably the first moment when I thought, "That is exactly where I need to work." 

And throughout—from the moment I started at BerryDunn, until I took on this new role—one of the things that made it so rewarding was that I had an opportunity to really participate in the development of our people. So, I call myself the original intern because I probably am the original intern, but also because the internship program was so important to me, as I was leading teams and helping BerryDunn grow and focusing on learning and development, I was a member of our inaugural Learning and Development Committee. And so, I just sort of had an opportunity to experience, both personally and in my work with staff, the full life cycle of developing people at BerryDunn. 

Shawn Tuttle: I'm thinking about, as you're talking, the three contexts that we talk about leadership in—so, self-leadership, leadership of others, and leadership of the organization—and your journey has really been about all three. Even that first instance you described is about self-leadership, saying, "I really want to get started, I really want to do this, and going and asking if it was possible, so taking that initiative."

Sarah Belliveau: Yes, absolutely. Advocating for yourself, recognizing what you need and what's important to you, and being brave enough to ask for it.

Career stage: Emerging as a leader

Key strategies: Finding great mentors and continuing to learn and grow 

Shawn Tuttle: Have you had a particularly impactful mentor in your journey?

Sarah Belliveau: I've had many and very impactful mentors, but the ones I think that have been most impactful are women leaders who have not been afraid to share their voice and use their voice and advocate or sponsor and make sure that I had opportunities that I may not have otherwise had. So those mentors have been absolutely powerful and impactful to my career.

Shawn Tuttle: That's such a strong thread, the, you know, sponsorship, empowerment, the availability of opportunities in your career and what you value and in the ways now that people have been impactful to you.

Sarah Belliveau: And [that] informs how I lead now. It is because I want to make sure everybody has those same opportunities.

Career stage: Leading a complex organization

Key strategies: Identifying your purpose and passion, bringing the right voices to the table 

Shawn Tuttle: Tell us about your interest in your current role.

Sarah Belliveau: [At] every point along my journey with BerryDunn, I have been provided opportunities to do what I love to do, what I found interesting, what fit in my life at the time, [and I’ve been given the] opportunity to work with folks from across the firm to develop something that had never been done before. Recognizing that the importance, for me, [was] in making sure that everyone has that opportunity and that those opportunities continue to grow well beyond when I'm here. And so, I recognize[d] for me personally that the next challenge and that next opportunity that was going to give me an opportunity to grow really was centered around making sure that the firm stays strong for future generations.

Shawn Tuttle: Is there anything specific you do on a day-to-day basis that's energizing?

Sarah Belliveau: Yeah, every single day. And this is the way it's been my whole career, really. It's one of the reasons why I've loved the career that I've been in is that every day, most days are very different, and every day I come in and there's the possibility that I'm going to be amazed by something that somebody has done. I'll hear about a new service that someone in the firm is developing, or I'll hear about a really cool client project that we're doing in Colorado, or I'll hear about, you know, a not-for-profit client that we're working with that is making important change in our communities. It's been really, really, really cool.

Sarah Belliveau has led the firm since 2021. Her intimate knowledge of BerryDunn’s culture, coupled with decades of working in direct client service, team development, and collaboration with diverse practice groups positioned her well to lead the dynamic group that the firm’s clients and community have come to expect.

Shawn Tuttle leads the firm’s Learning and Development efforts with a mission to empower continuous development that drives individual, team, and firm success.

Leveraging strengths, mentors, and purpose: The journey to authentic leadership