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The Public Company Accounting Oversight Board (PCAOB) has released its 2024 Annual Report on the Interim Inspection Program for audits of broker-dealers. This 10th annual report outlines persistent deficiencies in broker-dealer audits and attestation engagements. For management and audit committees, the report offers crucial insights into audit risks, regulatory expectations, and areas where stronger oversight is needed.

Persistent deficiencies raise oversight red flags

In 2024, the PCAOB inspected 60 accounting firms and reviewed 102 audits of broker-dealer financial statements. The PCAOB also examined 93 related attestation engagements—either examinations of compliance reports or reviews of exemption reports. The results were:

• 66% of broker-dealer audits had at least one deficiency related to audit evidence.
• 59% of compliance examinations and 42% of exemption reviews were found deficient.
• Deficiencies were most prevalent among smaller firms that audit fewer broker-dealers or issuers.

These statistics reflect a growing concern about audit quality in the broker-dealer space—and highlight where management and audit committees should be particularly vigilant.

Key areas of concern identified
 

1. Revenue recognition and accuracy

Deficiencies in auditing revenue were the most common and serious. This is nothing new, as revenue had been the area cited with the most deficiencies in the 2023 and 2022 reports as well. Of the 102 audits reviewed, 97 included revenue testing—nearly half (48%) had deficiencies.

Common problems included failure to:

• Verify the accuracy of commissions, advisory fees, 12b-1 fees, and merger/acquisition fees.
• Confirm that performance obligations were distinct and satisfied prior to revenue recognition (as required by ASC 606).
• Disaggregate revenue sources appropriately to reflect their nature and timing.
• Assess the classification and disclosure of revenue, including required qualitative information.
• Test the accuracy and completeness of third-party reports (e.g., clearing broker data) used in audit procedures.

For example, some firms did not test whether securities trade amounts and commission rates were accurate, nor did they evaluate whether revenue from variable annuity trails or 12b-1 fees should have been disaggregated. Others did not ensure advisory fee calculations were tied to accurate Assets Under Management (AUM) data or fee schedules.

Takeaway for management and audit committees:

Audit committees should confirm that revenue processes—including fee calculation, classification, and third-party data use—are well-documented and transparent. Management should ensure contracts and performance obligations are clearly delineated and that disclosures meet ASC 606 requirements. An ASC 606 practice aid, which walks management through the five-step revenue recognition process, can be useful to take inventory of the broker-dealer’s various contracts and how revenue from those contracts should be recognized in the financial statements. Such a practice aid can also prove useful in crafting ASC 606 disclosures.

2. Journal entry testing and fraud risk

Deficiencies in journal entry testing—critical for identifying and responding to fraud risk—were found in 18% of audits.

Common issues included:

• Failing to test the completeness of journal entry populations
• Selecting entries without considering fraud risk characteristics
• Reviewing listings but not examining supporting documentation
• Excluding flagged entries from testing without documented rationale
• Testing too few entries to provide sufficient audit assurance

The PCAOB specifically noted that many auditors failed to respond appropriately to the risk of management override of controls—a key component of fraud risk under PCAOB standards.

Takeaway for management and audit committees:

Ensure your auditors are applying rigorous, risk-based journal entry testing and that internal finance and compliance teams are involved in identifying and monitoring manual entries, especially at period end. Make sure that supporting documentation is retained for all posted journal entries. Also, ensure the journal entry posting process is clearly documented, including the types of journal entries that can be posted, by whom, and who the designated reviewer is. Having such a process clearly documented will make it easier for auditors to understand your broker-dealer’s journal entry process, which is a critical first step in effective journal entry testing.

3. Related party relationships and transactions

Deficiencies in this area were particularly concerning given the potential for misstatement or hidden liabilities. The PCAOB found that some auditors:

• Did not test allocations of revenues and expenses between broker-dealers and affiliates
• Failed to assess the financial capability of affiliates to cover material receivables
• Missed required disclosures of related party transactions under ASC 850

In one case, auditors accepted related-party expense allocations without verifying whether they were accurate, complete, or consistent with underlying agreements.

Takeaway for management and audit committees:

Ensure formal agreements with affiliates are in place and that intercompany transactions are reviewed regularly. If changes to related party transactions are made, these changes should be formally documented in the form of agreement amendments. If an allocation methodology, such as headcount or time studies, is used, broker-dealers must ensure this allocation methodology is thoroughly documented and followed. Disclosures about related parties must be clear and complete. Committees should confirm that auditors are probing related party risks—not just accepting management’s assertions.

Key areas of concern identified – examination engagements (compliance reports)

Of the 29 examination engagements reviewed, 59% had at least one deficiency. Common issues included:

• Incomplete testing of controls over compliance with SEC financial responsibility rules (e.g., the Net Capital Rule, Customer Protection Rule)
• Failure to evaluate the design and operation of controls with a review component (e.g., how management reviews reserve computations or account statements)
• Insufficient testing of IT general controls upon which other control procedures depended
• Lack of compliance testing over reserve account balances and the existence of securities held for customers
• Improper or missing representation letters from broker-dealer management
• Failure to issue modified opinions when material weaknesses in internal control over compliance (ICOC) existed

Takeaway for management and audit committees:

Engage in proactive conversations with your auditor about the internal controls they expect to see in place over the financial responsibility rules. Gain an understanding of your auditor’s testing approach, ensuring it aligns with the expectations of the PCAOB. Throughout the year, make sure sufficient documentation is retained so your auditor can easily test ICOC. Again, what is deemed sufficient should be determined through proactive conversations with your auditor.

Key areas of concern identified – review engagements (exemption reports)

Among the 64 review engagements evaluated, 42% had deficiencies. Key failures included:

• Inadequate understanding of the broker-dealer's exemption under Rule 15c3-3
• Insufficient inquiry into controls or monitoring practices related to exemption compliance
• Failure to test or inquire about the handling of customer checks to ensure prompt transmittal
• Errors or omissions in review reports—such as referencing assertions not made or failing to include required language

Takeaway for management and audit committees:

If your broker-dealer claims an exemption, ensure operational practices support that status. Review internal monitoring processes and make sure what is happening in practice aligns with your written supervisory procedures. If exceptions to your exemption status are identified, ensure they are promptly corrected and that your auditor is notified of the exception.

What you can do now

To help improve the quality of oversight:

• Engage in proactive dialogue with your auditor about the PCAOB’s findings and how they apply to your engagement.
• Assess your auditor’s broker-dealer experience—particularly if your firm is served by a smaller firm.
• Re-examine and test your internal controls over customer protection, capital computations, revenue recognition, and related-party arrangements.
• Strengthen audit committee oversight by requesting clear audit strategies, better documentation, and enhanced reporting on high-risk areas like revenue and related parties.
• Confirm that required auditor communications are received and appropriately documented.

Final thought

The PCAOB’s report is a call to action—not just for auditors, but for management and those charged with governance. As regulatory expectations continue to rise, management and audit committees must ensure that internal processes, control environments, and auditor relationships are all aligned to support accurate, transparent, and compliant financial reporting.

About BerryDunn

BerryDunn's financial services team understands the complex regulatory environment that broker-dealers operate in and provides practical solutions to help you stay ahead of requirements. From broker-dealer financial statement audits to tax preparation and compliance to consulting services, we tailor our services to meet your unique needs. Learn more about our team and services.

The Centers for Medicare & Medicaid Services (CMS) issued the final rule for the PPS for SNFs for FY 2026 which was published in the Federal Register on August 4, 2025; the regulations in this rule are effective October 1, 2025.  

The rule: 

• Updates the PPS payment rates for SNFs for FY 2026 using the market basket update and budget neutrality factors effective October 1, 2025. 

• Updates the International Classification of Diseases, 10th Revision, Clinical Modification (ICF-10) code mappings used under PDPM. 

• Updates the SNF Quality Reporting Program (SNF QRP).

• Updates the SNF Value-Based Purchasing (SNF VBP) Program. 

2026 PPS rate calculations 

The final rule provides a productivity-adjusted market basket increase for SNFs of 3.2% beginning October 1, 2025, which reflects: 

• A market basket increase of 3.3% based on IHS Global Inc.’s (IGI’s) second quarter 2025 forecast with historical data through the first quarter of 2025.  

• An upward forecast error adjustment of 0.6% due to the difference between the estimated and actual percentage increase in the market basket exceeding the 0.5 percentage point threshold.  

• A downward 0.7 percentage point multifactor productivity adjustment (based on the 10-year period ending September 30, 2026).  

The unadjusted federal rates for FY 2026, prior to adjustment for case-mix, are as follows: 

FY 2026 Unadjusted Federal Rate Per Diem – Urban 

FY 2026 Unadjusted Federal Rate Per Diem – Rural 

The rates shown in the tables above are subsequently case-mix adjusted, and a facility-specific wage index—determined by the Core-Based Statistical Area (CBSA) in which each facility is located—is also applied. To assist you with the calculation of your facility-specific PPS rates for FY 2026, our experts at BerryDunn have updated our interactive rate calculator, which is part of the BerryDunn Senior Living Portal.  

Please note: The rates per our calculator are prior to any FY 2026 VBP adjustment. When CMS releases the final VBP incentive payment multipliers for FY 2026, BerryDunn will update the interactive rate calculator as necessary. 

CMS estimates that the aggregate impact of the payment policies in this final rule would result in a net increase of 3.2%, or approximately $1.16 billion, in Medicare Part A payments to SNFs in FY 2026. This estimate does not reflect a projected $208.36 million decrease as a result of the SNF VBP program reductions. 

The projected overall impact to providers in urban and rural areas is an average increase of 3.1% and 3.7%, respectively, with a low of 2.0% for urban Pacific providers and a high of 6.6% for rural Mountain providers—actual impact will vary. 

Changes in PDPM ICD-10 code mappings 

CMS has changed the clinical category assignment for 34 new ICD-10 code mappings that were effective October 1, 2024. These updated code mappings can be found on the PDPM website. 

SNF QRP Update 

Updates to the SNF QRP Program include: 

• CMS finalized removing four items that were previously adopted as standardized patient assessment data elements in the Social Determinants Of Health (SDOH) category, starting with the FY 2027 SNF QRP. These are: 

  • One item related to Living Situation,

  • Two items concerning Food

  • One item regarding Utilities   

• Finalized and codified changes to the reconsideration policy and process. Now, SNFs will be permitted to request an extension to file a reconsideration request. Additionally, CMS is updating the criteria that will be used to evaluate and potentially grant these reconsideration requests. 

SNF VBP Program update 

Updates to the SNF VBP Program include: 

• The Health Equity Adjustment (HEA) will be removed beginning in the FY 2027 program year, to streamline the scoring methodology and offer clearer incentives for SNFs.  

• Final performance standards for the FY 2028 and FY 2029 program years were provided to meet the SNF VBP Program's statutory notice deadline.  

• The previously established scoring methodology will be applied to the SNF Within-Stay Potentially Preventive Readmission (SNF WS PPR) measure, starting with the FY 2028 program year, to align the scoring methodology for this measure with the scoring methodology previously finalized and applied to all other measures in the measure set.  

• Adoption of a new reconsideration process, allowing SNFs to seek reconsideration on Review and Correction requests. 

The following table lists the measures that have been adopted for the SNF VBP Program, along with their status in the program for the FY 2026 program year through the FY 2029 program year. 

If you have any specific questions about the final rule or how it might impact your facility, please contact Ashley Tkowski or Melissa Baez. 

As financial institutions continue to navigate evolving regulatory landscapes, the recently enacted OBBBA legislation introduces a noteworthy incentive aimed at supporting rural and agricultural development. Effective July 4, 2025, the bill provides a 25% federal income tax exemption on interest income earned from qualifying rural or agricultural real estate loans.  

This represents a strategic opportunity for lenders to reassess their portfolios and tax planning strategies. With further guidance expected, institutions should begin preparing to identify eligible loans and evaluate the broader implications of this new provision. 

Key information for financial institutions 

• Effective date: Applies to qualifying loans originated on or after July 4, 2025. 
• Exemption: 25% of the interest income earned on these loans will be tax-exempt. 
• Ineligible loans: Refinanced loans do not qualify. 
• Qualified loans: Loans must be secured by rural or agricultural real estate, defined as property substantially used for: 

• Producing agricultural products (not defined) 
• Fishing or seafood processing 
• Aquaculture (hatcheries, rearing ponds, pens, etc.) 
• Leasehold mortgages on such real estate also qualify, provided they have lien status 

Please also note that, similar to municipal bond investments, these loans are subject to IRC Section 265, which may limit deductibility of interest expense allocable to the tax-exempt income. 

Considerations for financial institutions

Loan identification and tracking: Determine whether any existing lending activity aligns with these definitions and develop a method for flagging and tracking qualifying loans after the effective date. 

Strategic expansion: Assess whether this creates an incentive to expand your presence in agricultural or rural real estate lending. 

Loan pricing models: Revisit pricing for these types of loans to account for the blended tax benefit and any associated disallowed interest expense. 

Tax planning: Analyze how this partial exemption could affect your effective tax rate and broader tax strategies going forward, particularly as it creates a permanent tax difference. 

About BerryDunn

BerryDunn's dedicated audit, tax, and consulting professionals understand the financial services industry and its challenges and are committed to helping you meet and exceed regulatory requirements. We partner with you to bring tailored approaches to fit your needs and operations and provide guidance on best practices and recommendations that make sense for you. Learn more about our services and team.  

Executive Order (EO) 14221 released on February 25, 2025, directed the Secretaries of Labor, Health and Human Services (HHS), and the Treasury to implement changes to improve implementation and increase enforcement of the hospital price transparency (HPT) rule. On May 22, 2025, the agencies announced progress in implementing the EO, including issuance of a request for information (RFI), as well as providing updated guidance regarding requirements for machine readable files. 

HPT enforcement 

An HHS Office of Inspector General (OIG) audit report released in November 2024 estimated only 46% of hospitals were in compliance with HPT rule requirements. While the HHS OIG noted a variety of issues with shoppable services requirements, the most common areas of non-compliance observed related to the machine readable file (MRF), including: 

• Failing to update the file annually 

• Lack of appropriate naming conventions 

• Providing negotiated charges by payer/plan

Civil monetary penalties (CMP) for HPT non-compliance range from $300 to $5,500 per day, depending on hospital bed count. From 2021 – 2024, CMS issued CMP notices totaling approximately $5 million.  

Based on reports from our clients and anecdotes shared by compliance and finance colleagues and from presenters at recent conferences, HPT-related complaints from patients have remained minimal, whereas the pace of CMS non-compliance warning letters has increased. 

Practical tips for HPT compliance 

The risks related to non-compliance with HPT rules can be mitigated through a multidisciplinary team approach, establishing accountability, and engaging external resources to fill gaps in expertise. 

• Making certain to include the functions with an HPT role, such as finance, revenue cycle, revenue integrity, compliance, IT, and payer contracting 

• Considering the vendor as part of the team if any aspect of HPT rule compliance is outsourced 

• Designating an internal resource to monitor and advise your team on HPT-related announcements from regulators and CMS enforcement activity 

• Linking chargemaster/CDM and fee schedule updates to MRF and shoppable services maintenance activities supports compliance with multiple HPT requirements 

• Adding HPT-related audit items to the compliance work plan to demonstrate internal oversight 

BerryDunn’s healthcare compliance team incorporates deep, hands-on knowledge with industry best practices to help your organization manage compliance and revenue integrity risks. Learn more about BerryDunn’s team and services. 

Read this if you are a CFO or on the fundraising team at a nonprofit organization. 

Capital campaigns can be game changers for nonprofits, enabling bold investments in infrastructure, programs, and long-term growth. Whether you're building a new facility, expanding services, or upgrading technology, a capital campaign aligns fundraising with your strategic vision. 

When to consider a capital campaign 

A capital campaign may be right if your organization lacks the funds for a major initiative or your annual budget is unable to support a strategic opportunity. Capital campaigns are also ideal for: 

• Infrastructure improvements  

• Major construction or renovations  

• New or expanded programs 

Capital campaigns often inspire larger gifts and deeper donor engagement than annual appeals, especially when the purpose is clearly communicated.   

Key success factors 

A successful campaign requires more than passion; it demands planning, clarity, and commitment from leadership and the board. Consider these best practices: 

• Clear messaging: Campaign materials should define the fundraising goal, project purpose, and how funds will be used. Avoid overly restrictive language if flexibility is needed. 

• Community engagement: Events, media outreach, and visibility efforts help build momentum and attract new supporters. 

• Board involvement: Active leadership from your board and executive team is essential to credibility and success. 

If you're including an endowment component, remember: Endowed gifts are donor-restricted in perpetuity. Only investment returns, not the original gift, can be used for the restricted purpose. The availability of investment returns is typically determined by a board-approved spending policy that follows the Uniform Prudent Management of Institutional Funds Act (UPMIFA). 

Accounting for capital campaigns under GAAP 

Proper classification and reporting are critical. Follow FASB ASC 958-205 to ensure compliance: 

• Purpose-restricted gifts: Recognized as donor-restricted until the specified use or time condition is met. 

• Endowment gifts: Always classified as donor-restricted in perpetuity; only earnings may be used per the donor’s intent and your spending policy. 

Final thoughts 

In uncertain economic times, a well-executed capital campaign can provide the resources and energy your nonprofit needs to thrive. With the right strategy, your campaign can strengthen donor relationships, elevate your mission, and leave a lasting impact. 

BerryDunn’s team of professionals serves a range of not-for-profit organizations, including but not limited to educational institutions, foundations, behavioral health organizations, community action programs, conservation organizations, and social services agencies. We provide the vital strategic, financial, and operational support necessary to help nonprofits fulfill their missions. Learn more about our team and services.  

The FDIC's Quarterly Banking Profile for quarter one 2025 reports the performance for the 4,022 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 rose by $621 million (10.0%) from the previous quarter to $6.8 billion, with 55.8% of community banks reporting an increase. 

• Pretax return on assets increased to 1.18%, up 11 basis points quarter over quarter and 6 basis points year over year. 

• Net interest margin rose to 3.46%, up 2 basis points from the prior quarter and 23 basis points year over year.

Costs and Efficiency 

• Noninterest expense fell by $423.2 million (2.3%) from the previous quarter but increased 6.0% year over year. 

• Provision expenses declined by 19.0% quarter over quarter, but increased 34.3% year over year, signaling growing concern over potential credit losses. 

• Efficiency ratio improved to 64.69%, down 39 basis points from the prior quarter, indicating better cost control relative to revenue. 

Loan and Deposit Trends 

• Loan and lease balances increased by $15.1 billion (0.8%) quarter over quarter and 4.9% year over year, led by nonfarm nonresidential CRE and 1–4 family residential loans. 

• Domestic deposits rose 1.6% quarter over quarter and 5.2% year over year, with stronger growth in interest-bearing than noninterest-bearing accounts. 

• More than half (59.1%) of community banks reported loan growth, and 69.4% reported deposit growth during the quarter. 

Asset Quality 

• Past-due and nonaccrual loans (PDNA) increased 12 basis points to 1.32%, mainly driven by nonperforming farm and CRE loans. 

• Net charge-off ratio decreased 9 basis points from the prior quarter to 0.15%, matching pre-pandemic levels. 

• Reserve coverage ratio declined significantly to 168.8%, indicating that allowance growth lagged increases in noncurrent loan balances. 

Capital and Structural Stability 

• Capital ratios improved modestly across the board: CBLR rose to 12.30%, and the leverage capital ratio increased to 10.91%. 

• Unrealized losses on securities fell by $6.2 billion (12.4%) from the prior quarter to $43.9 billion total. 

• Community bank count declined by 24 during the quarter due to mergers, transitions, and one failure. 

Conclusion and Outlook 

The first quarter of 2025 was off to a hot start for the banking industry, as seen by the increase in net income, primarily driven by higher net interest income. Net interest margins benefited from a 23 basis point increase from the previous year—a stark change from a year prior. But challenges remain for the industry, as past-due and nonaccrual loans continue to climb (albeit from historically low levels). Even with the continued increase in past-due and nonaccrual loans, net charge-offs remain at historical lows and actually decreased from the previous quarter. 

Regulatory trends continue to dominate headlines, with the most notable changes surrounding tariffs and the recently signed One Big Beautiful Bill Act (OBBBA). Although both tariffs and the OBBBA may have significant direct implications for financial institutions, borrowers will also be significantly impacted, and possibly more so than financial institutions. Financial institutions should be proactive with borrowers, reaching out to inform them of potential changes and seeing how they believe they may be impacted prospectively. This proactive communication will not only signal to borrowers that you are looking out for them but will also allow you to identify potential problem areas early on. As always, your BerryDunn team is here to help! 

Read this if your healthcare organization cannot fill a vacancy in your compliance department or if your program needs expert consultation services. 

Healthcare organizations are currently facing growing financial challenges and experiencing high staff turnover. Recruiting a compliance officer may prove challenging due to the unavailability of experienced professionals or concerns about salary and fringe expenses. Depending on a healthcare organization’s fiscal health, consideration might be given to downsizing the compliance department. This article offers guidance to healthcare administrators as they ponder several compliance-related what-if scenarios.   

What if your compliance officer has resigned and there are no experienced applicants?   

Did you know that the pool of certified compliance professionals varies by region? In its 2024 Healthcare Chief Compliance Officer and Staff Salary Survey, the Health Care Compliance Association (HCCA) reported that the greatest proportion of Chief Compliance Officers (CCOs) in the United States are based in the South Atlantic, Mid-Atlantic, and Pacific regions. In comparison, the New England region (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont) and East South-Central region (Alabama, Kentucky, Mississippi, and Tennessee) have a smaller pool of CCOs.             

Even healthcare organizations that are based in a region with a greater supply of CCOs may face recruiting challenges. Organizations in non-urban areas, such as rural health centers and critical access hospitals, may be stymied by a qualified pool of CCO applicants who are unwilling to relocate.   

What if your compliance department is a department of one?   

If your compliance department is a department of one, then an unfilled vacancy due to a resignation or leave of absence poses significant risks. Questions to consider: 

• How will your organization handle a compliance coverage gap? 

• How will any unresolved, in-process compliance or privacy investigations be resolved? 

• Who will respond to compliance questions, calls on the compliance hotline, or a potential whistleblower? 

• Who will oversee your organization’s response to government payer audits or investigations?   

Even a fully staffed department of one may need a lifeline on occasion. The HCCA’s 2024 survey found that approximately half of their survey participants had five or fewer years of experience. A novice CCO may need to consult a trusted advisor for guidance as healthcare compliance requirements and payer audits increase in number and complexity. Even an experienced CCO in a department of one who has transferred to a new service delivery line may benefit from having an experienced compliance consultant on call. Segments of the healthcare industry that are heavily regulated, such as Federally Qualified Health Centers (FQHCs) and Certified Community Behavioral Health Clinics (CCBHCs), may be baffling to a seasoned compliance professional who is new to the setting.             

What if you can no longer budget for a full-time compliance officer or need to eliminate your compliance department? 

Salaries for CCOs depend on the healthcare organization’s number of employees, annual revenue, and the type of organization. The HCCA found that compensation increases with an organization’s staffing headcount. For example, a CCO’s salary can range from $138,783 in an organization with 100-249 employees to $163,205 in an organization with 500-999 employees. In the HCCA’s survey, the total compensation of healthcare CCOs in nonprofit organizations was $178,265, which was less than in privately held healthcare organizations ($179,553), governmental settings ($190,743), academic healthcare ($216,291), and publicly traded organizations ($286,019). 

Due to increasing costs, declining revenues, and funding challenges, perhaps your healthcare organization has had to make the difficult budgeting decision to downsize or eliminate its compliance department. If so, then your organization should consider outsourcing its compliance functions. An outsourced compliance officer can provide services that are uniquely tailored to the needs of your organization.  

Need help addressing these compliance what-if scenarios?   

BerryDunn’s healthcare compliance team offers outsourced compliance officer services and on-call consultation across the healthcare continuum. Learn more about BerryDunn’s team and services. 

CMS recently extended the deadline for the mandatory SNF provider enrollment off-cycle revalidation to January 1, 2026.  

As we wrote about previously, CMS issued a significant off-cycle mandate requiring all skilled nursing facilities (SNFs) in the US—both for-profit and nonprofit—to revalidate their Medicare provider enrollment records. Originally due by May 1, 2025, then August 1, 2025, the deadline has now been extended to January 1, 2026, giving facilities additional time to comply. This revalidation is essential to maintain Medicare billing privileges and incorporates more rigorous disclosure requirements than ever before. 

The updated process centers around expanded transparency in ownership and control structures. SNFs must report detailed information on all individuals and entities with ownership or managerial roles, including a new category called Additional Disclosable Parties (ADPs). These include anyone who exercises operational, financial, or managerial control, provides real estate, or delivers services such as consulting or accounting. CMS has updated Form CMS-855A and developed a 20-page SNF-specific attachment to capture this information, along with detailed guidance to help facilities navigate the changes. 

The scope of disclosure has also broadened to include parties with formal and informal influence over SNF operations, such as managing employees, consultants, and organizations with financial or operational oversight. Facilities must report granular data on both individuals and organizations, such as ownership percentages, tax IDs, NPIs, and the nature of their relationship to the SNF. The complexity of these requirements makes it critical for SNFs to assess their internal structures, collect necessary documentation, and continue to evaluate management and other changes on a routine basis. Among the many supporting documents required for this effort, CMS is placing a significant emphasis on an organizational chart that outlines the relationships of all organizations and individuals disclosed within the revalidation application. 

To support compliance, CMS encourages the use of its PECOS online portal for submissions and offers help through various channels. Many SNFs are also turning to legal counsel and credentialing professionals for guidance. Firms like BerryDunn have developed tools and resources to help facilities organize and track the required data. While the new January 1, 2026, deadline allows an additional runway, SNFs are encouraged to complete this recertification as soon as possible. Proactive planning and responding to any additional requests (CMS allows a 30-day window for corrections once applications are submitted) is essential to avoid disruptions in Medicare participation. 

We're here to help 

As you prepare, it can be helpful to work with an experienced team of credentialing professionals who will help you navigate the complex process of meeting the new revalidation requirements. BerryDunn’s Credentialing and Enrollment Team is available to offer guidance and support to client organizations as they collect, organize, and track ownership, control, and ADP information, and to guide them through the CMS revalidation process. Additional CMS resources are available, including a dedicated email, SNFDisclosures@cms.hhs.gov, and PECOS support, via the External User Services (EUS) Help Desk. The Help Desk can also be reached by phone at 1.866.484.8049 or email at EUS_Support@cms.hms.gov. 

This article is based on an episode of the Let's Talk Parks with BerryDunn podcast. Listen to the full episode. 

July is National Parks and Recreation Month, and it’s the perfect time to celebrate the people who transform everyday spaces into places of joy, connection, and belonging. To highlight this year’s theme, ‘Build together, play together,’ members of BerryDunn’s Parks, Recreation, and Libraries team share stories of projects that helped communities thrive—and the personal ways they embrace play in their own lives. 

From bustling cities to quiet towns, parks and recreation departments are shaping the future through thoughtful planning, conservation, and inclusive programming. Their work proves that when we invest in shared spaces, we invest in each other. We are proud to support this meaningful work and to share these successes.  

Strategic planning for community growth 

Communities across America are discovering how intentional parks and recreation planning can spark transformation. In Charles County, Maryland, a comprehensive Land Preservation Parks and Recreation Plan (LPPRP) has become a blueprint for community development. 

“Through leadership and strategic guidance, the planning process brought together various voices throughout the county,” says Lisa Wolff, senior consultant with BerryDunn’s Parks, Recreation and Libraries team. 

In Timnath, Colorado, community feedback didn’t just shape ideas—it drove action. When 95% of residents voiced support for a new recreation center, the town moved swiftly from vision to reality. Ryan Hegreness, who managed Timnath’s Parks, Recreation, and Open Space Master Plan, saw firsthand how listening to residents can accelerate change. 

Meanwhile, in Greeley, Colorado, BerryDunn Manager Nikki Ginger has been impressed with how the strategic investment in master planning and facility assessments is helping the Culture, Park, and Recreation Department strengthen diverse communities and meet evolving needs. 

Preservation and heritage 

Parks aren’t just about play—they’re about protecting what matters. In 2023 alone, Charles County preserved 1,700 acres of farmland and forest, secured $1.7 million in open space grants, and obtained over $380,000 in rural legacy funds for conservation easements. 

These efforts safeguard not only natural landscapes but cultural treasures like Mallows Bay, home to the “Ghost Fleet of the Potomac.” Designated a National Marine Sanctuary in 2019, this hauntingly beautiful spot holds nearly 200 historic shipwrecks—the largest collection in the Chesapeake Bay watershed. 

Recreation and community connection 

Park professionals don’t just build spaces—they create moments. Ryan Hegreness’ local pickup soccer group is a daily ritual that brings together teens, seniors, and everyone in between. “It’s a powerful example of how sports can bring people together—not just during your childhood, but throughout your life,” Hegreness shares. 

Lisa Wolff’s journey began as a “parks and rec kid” in Wilmington, Delaware. Today, she hikes, kayaks, and serves on her local Parks and Recreation Advisory Board. Her story reflects the countless individuals who find friendship, purpose, and joy through recreation. 

Professional impact and leadership 

The influence of parks and recreation stretches far beyond playgrounds—it’s about leadership, vision, and lifelong service. Elsa Fisher, newly elected to the Skokie Park District Board of Commissioners, brings four decades of experience to her role. “I am experiencing local parks and recreation with a new perspective,” Fisher says, highlighting her work in budgeting, park development, and community events. 

For professionals like Lisa Wolff, the work is deeply personal. “The quality of my life matters. And that’s why I celebrate Parks and Recreation Month with excitement and gratitude for a career path that really makes me smile pretty much every day.” 

Happy Parks and Recreation Month!  

From strategic planning to conservation, from pickup games to public service, parks and recreation professionals are building stronger, more connected communities. 'Build together, play together' isn’t just a theme—it’s a way of life. And this July, we honor the people who make it all possible. 

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 team and the services we offer.