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Read this if you are involved in preparing or reviewing government financial statements or capital asset disclosures. 

In today’s governmental accounting space, transparency isn’t just a best practice; it’s expected. Internal and external users rely on financial statements not just for numbers, but for a clear and concise picture of how a government is managing its assets and planning for the future. To support this level of clarity, the Governmental Accounting Standards Board (GASB) released Statement No. 104, Disclosure of Certain Capital Assets, in September 2024. 

This new standard doesn’t alter how capital assets are measured or recorded, but it raises the bar on how governments disclose them, specifically when it comes to leases, Subscription-Based Information Technology Agreements (SBITAs), intangible assets, and assets that are being considered for sale. Whether you are involved in governmental accounting, policy setting, or audit, GASB 104 is a standard that deserves your attention.    

A unified framework for disclosing assets 

Over the last decade, GASB issued several new standards like GASB 87 on leases, GASB 94 on public-private partnerships, and GASB 96 on SBITAs that brought right-to-use assets into the spotlight. However, until now, there hasn't been a unified framework for how to disclose these newer types of assets in the capital assets footnote. In addition, guidance around capital assets held for sale was missing. Governments often hold buildings, land, or equipment for sale, but users of the financial statements rarely saw this activity clearly disclosed. This made it difficult for financial statement readers to assess liquidity, asset management, and overall long-term financial health. GASB 104 closes those gaps. It enhances the capital asset disclosures required by GASB 34 and adds new rules for how to handle assets that are expected to be sold. 

GASB 104 requirements 

Here’s a breakdown of what the standard requires governments to do: 

• Disclose lease assets under GASB 87 separately, by major class of the underlying asset. 

• Disclose right-to-use assets related to public-private or public-public partnerships under GASB 94 separately.

• Disclose subscription-based IT assets under GASB 96 distinctly from other capital assets. 

• Break out other intangible assets (i.e., software, trademarks, licenses) by major class. 

• Disclose information about capital assets held for sale, including their cost, depreciation, and whether they’re pledged as collateral. 

To be considered “held for sale,” an asset must meet two criteria: 

1. The government has decided to sell it. 

2. It is probable the sale will happen within one year of the financial statement date. 

If those criteria are met, the asset must be disclosed in the notes; however, it should still be classified under its original capital asset category.  

Key considerations 

As your organization prepares for implementation, here are things to keep in mind: 

• Right-to-use vs. owned assets: Users analyze these differently. Leased or subscription-based assets may not carry the same risks or benefits as owned assets, and that distinction matters to financial statement users. 

• Classifying intangible assets: Intangible capital assets should not be grouped with physical ones. Governments need to carefully categorize and disclose each major type separately. 

• Evaluating assets held for sale: Determining “probability of sale within one year” requires professional judgment. Consider legal approvals, marketing activity, and market conditions when making this decision. 

• Debt collateral: If a capital asset held for sale is tied to outstanding debt, that linkage must be disclosed. This helps users understand which future asset sales are already marked for debt repayment. 

Real-world examples 

GASB provided examples to illustrate certain requirements of this Statement. According to GASB: 

• “The examples are illustrative only and are not intended to modify or limit the requirements of this Statement or to indicate the Board’s endorsement of the policies or practices shown.” 

• “The examples are nonauthoritative and no inferences about determining materiality should be drawn from them.” 

Example 1: Capital assets note disclosure

This example illustrates how a government might present its capital assets note disclosure for governmental activities, reflecting some of the key requirements outlined in this Statement. Alternative formats may also meet the disclosure requirements. 

Example 2: Capital assets held for sale disclosure 

Among the capital assets reported under governmental activities are buildings classified as held for sale. These buildings have a combined historical cost of $8.0 million and accumulated depreciation of $5.0 million. Additionally, they are pledged as collateral for outstanding debt totaling $1.5 million. 

Implementation considerations 

Since GASB 104 is primarily a disclosure standard, it does not affect the recognition or measurement for assets held for sale. That said, there are a few things you’ll want to be mindful of: 

• Inventory your assets: You’ll need to identify lease, subscription, and partnership assets early, especially if they haven’t been disaggregated in past reports. 

• Update templates: Capital asset note disclosures will need formatting changes to accommodate the new categories and detail requirements. 

• Evaluate sale activity regularly: GASB 104 requires you to assess assets held for sale at every reporting period, not just year-end. 

• Coordinate across departments: Accounting may need input from legal, facilities, and IT to assess which assets fall under GASB 104’s scope. 

Essential items to share 

If you’re preparing for a board or council meeting or even speaking with an audit committee, here are some points worth sharing: 

• Why this matters: GASB 104 promotes transparency and improves comparability across governments. It aligns financial reporting with modern practices. 

• What's changing: Disclosures will become more detailed. Expect to see new categories in capital asset notes and clearer reporting around assets planned for sale. 

• Strategic value: These changes aren’t just for compliance. They tell a better story about how your government is managing its resources and planning for the future. 

• No budget impact: This is not a change to how assets are valued or expensed. It’s about giving users better information in the notes. 

  This is also a good time to emphasize that implementation planning is underway and that the organization is aiming for smooth adoption. 

Effective date 

The requirements of GASB 104 take effect for fiscal years beginning after June 15, 2025. Earlier application is encouraged. Governments are also expected to apply the standard retroactively, if practicable. That means adjusting prior-period financial statements to reflect the new disclosures, unless doing so is not feasible. If prior-period restatement isn’t possible, that must be disclosed in the notes. 

Final thoughts 

GASB 104 marks a shift in how governments report their capital assets. It reflects how operations have evolved, especially with the rise of leased assets, cloud-based arrangements, and asset sales as part of an overall financial strategy. While the new disclosure requirements may take some effort to implement, they ultimately serve the broader goal of improving accountability and decision-making. Financial statement users will have better visibility into the types of assets a government controls, how those assets are used, and what the government’s long-term plans look like. 

How BerryDunn can help 

Implementing GASB 104 can be complex, requiring a careful approach to help ensure both compliance and transparency in financial reporting. BerryDunn’s team of governmental professionals iswell well-versed in helping entities evaluate their capital asset disclosures, apply the latest reporting requirements, and prepare clear, accurate financial statements. From assisting with the classification of intangible assets to analyzing assets held for sale and developing updated note disclosures, we offer customized support to meet your needs. Learn more about our team and services. 

Imagine this: You’re at a family reunion and Uncle Bob decides to use the college fund to pay for a bouncy castle “because the kids looked bored.” Sure, it worked, but now the college fund is short—and Bob’s in hot water. That’s essentially what the US Department of Housing and Urban Development’s (HUD) PIH Notice 2025-14 is trying to stop (minus the bouncy castle). 

In its newly released PIH Notice 2025-14, HUD lays out clear guidance for Public Housing Agencies (PHA) on how to properly manage, report, and safeguard Operating Funds—especially when using centralized accounts like PayMaster or Revolving Fund Accounts. Think of this as the rulebook that keeps Uncle Bob from dipping into the wrong piggy bank. 

This article will share the main takeaways from the Notice. 

What is PIH Notice 2025-14 about? 

The notice is aimed at PHAs managing public housing funds, including those in the Moving to Work (MTW) program. It provides detailed instructions on the acceptable use of Operating Funds, how to structure centralized accounts, and how to avoid misusing restricted funds. 

Key highlights 

• Operating Funds are sacred (and restricted): These federal dollars must only be used for eligible public housing expenses. No crossing the streams with other programs unless HUD explicitly says it's okay. 
• Centralized accounts need guardrails: While PHAs can use pooled bank accounts to streamline spending, they must track every dollar, making sure each program’s money is spent correctly and reported cleanly. 
• New rules for Financial Data Schedule (FDS) reporting: 
  • Certain line items (e.g., Lines 144, 172, 347, 352) now have updated definitions and require justifications if classified as long-term. 
  • Inter-program balances must be settled to avoid being misreported as cash. 
  • Misuse or reclassification of restricted funds could lead to program noncompliance and penalties. 

Best practices required 

To stay compliant, PHAs must adopt strong internal controls and financial management practices. This includes regular reconciliation of accounts, clear documentation for centralized payer accounts, and ensuring that all transactions are authorized, compliant, and properly recorded. Think of it like running your own business—you wouldn’t want your intern paying the electric bill with Monopoly money, right?  

Common pitfalls to avoid 

HUD is clear about what not to do. PHAs should never use Public Housing funds to cover other programs—even temporarily. Advancing funds beyond the allowed expenditure rate is also off-limits. Long-term balances must be documented and justified, and inter-program debts should not be written off without HUD’s explicit approval. 

Consequences 

Noncompliance with these guidelines can lead to serious consequences, including sanctions, repayment obligations, or direct HUD intervention under the US Housing Act. In other words: if you mess up the books, HUD might just shut the whole party down. 

In summary 

PIH Notice 2025-14 is HUD’s reminder that good accounting isn’t optional—it’s essential. By setting firm expectations for how Operating Funds can be used and reported, HUD aims to keep PHAs transparent, compliant, and financially healthy. 

So, before you let Uncle Bob anywhere near your budget spreadsheets, give this notice a thorough read. 

At BerryDunn, we understand that affordable housing organizations are unique and dynamic organizations with specific challenges and opportunities. Our commitment to specialization provides our clients with a team of specialists who understand the complex accounting, regulatory, and tax issues of affordable housing organizations. Learn more about our services and team.  

Each time I leave another Medicaid Enterprise Systems Conference (MESC), I’m struck again by how impactful this gathering is—both personally and professionally. It’s often said that “if you’ve seen one Medicaid program, then you’ve seen one Medicaid program.” It’s a phrase that gets trotted out now and then to highlight how unique and nuanced these programs are across each of the states and territories. While that’s true to a certain extent, we have so much more in common than we have differences.

There’s something both comforting and energizing about spending a week surrounded by thousands of people (over 2,100 this year!) who share the same commitment to the future of Medicaid. It reminds us that we are not alone. We may all come at this from different perspectives and backgrounds, but the sense of solidarity and camaraderie is a welcome respite in a world of constant change and shifting values.

As many speakers mentioned in varied (and occasionally colorful) language throughout the week, this work we do is hard! It challenges us from all directions and requires us to continuously cultivate resilience, creativity, and a willingness to reimagine what’s possible. That resilience requires us all to balance the demands of this work with time for reflection and self-care.

Continuing the trend we’ve seen in past years, the New England States Consortium Systems Organization (NESCSO) thoughtfully incorporated the theme of balance and wellness throughout the week’s activities. In addition to morning yoga, massages, and a sunrise fun run along the Milwaukee waterfront, this theme shone through in the keynote plenary session that kicked off the week. Dan Harris, retired journalist and author of 10% Happier, set the tone with a candidly heartfelt discussion on the importance of protecting our mental well-being in a high-stress environment. His introduction to the value of meditation was delivered with a great blend of humor and practicality that resonated with this crowd. One of his final points struck me as especially relevant when he reminded us all that “action absorbs anxiety.” Those three words became my mantra for the week and helped me focus my energy as I attended sessions and engaged with various states, territories, and vendors.

With this year’s conference coming directly on the heels of major new legislation impacting Medicaid (HR-1) and recent CMS guidance (SHO #25-003), attendees were understandably focused on topics like looming community engagement requirements, funding changes, and expanded leverage and reuse expectations. As we were reminded in both the keynote and the welcoming remarks from David Huffman, NESCSO’s Executive Director, this is a human program. Everyone needs healthcare, and we must keep those we serve front of mind as we move forward in the coming years. Wisconsin’s Medicaid Director, Bill Hanna, echoed this sentiment when he encouraged participants to be guided by the core values of our respective programs.

This tone of person-centric design and value-driven decision-making carried through many of the sessions. As states and territories discussed leverage and reuse opportunities, there was also a focus on the relationship-building required to make these partnerships successful. As programs shared their approaches to developing and managing MES Advanced Planning Documents (APDs) in response to SHO #23-003, there was a continued emphasis on outcomes and user experience as key performance metrics. This balance—between meeting evolving legislative requirements and focusing on the people at the core of Medicaid (both recipients and the workforce that supports them)—felt like an organic and collective response to the current pressures facing state and territorial programs.

It was exciting to see so many bright and creative program leaders rising up in a proactive, rather than reactive, way to meet the demands placed on us this year. This solution-focused and innovative mindset will be what guides states and territories in the future. CMS shared this sentiment during the closing plenary, voicing appreciation for all the effort shown by states, territories, and their partners to make this program successful. They also acknowledged again that this work is hard.

That truth keeps circling in my mind as I travel home—this work is hard. It’s complicated. It’s occasional fodder for political headlines. It’s also vital and absolutely necessary. Medicaid covers roughly one in five people in the U.S. I think about that as I stand in line at the TSA checkpoint for my flight home and wait in baggage claim to gather my belongings. The people around us in our everyday lives are the people we serve. We all owe it to them to continue working hard to make this program as good as it can be. After this past week, I feel a renewed sense of pride and optimism, having seen all the bright and dedicated people who are working tirelessly to keep Medicaid strong into the future.

Well done, Milwaukee. I—and the rest of the BerryDunn team—can’t wait to see you all next year in Portland, Oregon!

A new Executive Order issued by President Donald Trump on August 7, 2025, brings major changes to how federal agencies handle discretionary grants. Titled "Improving Oversight of Federal Grantmaking," the changes in this Order introduce more political oversight, tighter controls on how funds are used, and new compliance rules that will directly affect organizations receiving federal funding. 

What counts as discretionary funding? 

Discretionary funding refers to competitive grants that organizations must apply for. Federal agencies decide who gets the funding, how much they receive, and for how long. This is different from funding that’s automatically allocated through legislation. 

Increased political oversight 

Under the new rules, each federal agency must appoint a senior political official to oversee discretionary grants. This person will: 

• Review grant announcements before they’re published. 
• Review all grant awards before they’re issued. 
• Conduct annual reviews of existing grants to ensure they align with agency goals and show meaningful progress. 

This marks a big shift from how grants were managed in the past and adds a new layer of uncertainty to the process. 

New factors that could influence grant decisions 

The Executive Order gives these senior appointees broad authority to use their judgment when reviewing grants. They’re expected to consider several key factors, including: 

• Whether the grant supports the President’s policy goals. 
• Whether the funds are being used in ways that align with certain values (e.g., not promoting racial preferences or specific views on gender). 
• A preference for organizations with lower indirect cost rates. 
• The organization’s alignment with the Administration’s policies and commitment to “Gold Standard Science”—a set of principles focused on transparency, rigor, and reproducibility in research. 
• A goal of distributing grants to a wide range of recipients, balancing short-term results with long-term impact. 
• For science-related grants, at least one subject matter expert must review the application. 

New rules for managing and accessing funds 

Agencies will update their grant guidance and agreements to reflect the new rules. This includes: 

• Adding clauses that allow grants to be terminated for convenience. 
• Requiring prior approval and written justification for drawing down project-specific funds. 
• Limiting how much grant money can be used for administrative and facility costs. 

What grant recipients should expect 

These changes add complexity to an already challenging funding environment. Here’s what organizations should keep in mind: 

• Agencies may ask to revise existing grant agreements to include new terms, like the ability to end a grant if it no longer meets program goals. 
• Delays in receiving funds are likely, which could affect daily operations and long-term planning. 
• Some parts of the Executive Order will require formal rulemaking, so the full impact may evolve over time. 
• Future applicants should prepare for more detailed reviews of their proposals. 

How to prepare for this federal grantmaking Executive Order 

To stay ahead, organizations should consider the following steps: 

• Diversify funding sources by exploring private grants, corporate partnerships, and earned income. 
• Strengthen internal systems for tracking compliance, deadlines, and performance. 
• Review current grants to ensure they align with the new priorities. 
• Research organizations should document how they follow “Gold Standard Science” and show alignment with administration goals. 
• Develop backup plans in case of funding delays or early terminations. 

What's next? 

This Executive Order represents a major shift in how federal discretionary grants are awarded and managed. With more political oversight and new administrative requirements, organizations will need to adapt quickly. While some changes will take time to implement, others may roll out soon. Staying informed and proactive will be key to maintaining funding and compliance in this new environment. 

If your organization relies on federal grants, BerryDunn can help you prepare. From grant consulting to nonprofit and local government consulting, our experts have the insight and practical knowledge to set you up for success. 

In today's rapidly evolving business landscape, boards of directors are more than just stewards of governance—they are the strategic compass guiding an organization toward enduring success. As the challenges facing companies grow increasingly complex, from disruptive technological trends to shifting societal expectations, the board's role has never been more critical.  

This series is designed to empower board members with the insights and tools necessary to navigate change with confidence. Our experts, each a leader in their respective fields, will share real-world examples, practical frameworks, and actionable advice in a Q&A format, and lessons learned from their personal and professional journeys.   

Learning and development: A culture of continuous improvement 

For the latest installment of our board leadership series, BerryDunn Learning Consultant, Michelle Holloway, shares insights on learning and development, including designing effective trainings, aligning courses with an organization’s goals, and getting buy-in from leadership.   

Q: Can you describe your approach to designing an effective training program for employees? What key steps do you follow from initial concept to delivery?    

A: At BerryDunn, we don’t currently have a standardized approach to training design, although this may be something on our future horizon. We tailor our training design to meet the distinct needs of each of our three learning consultants, ensuring that our approach is as unique as the audiences we serve. However, I have found that starting with the end in mind can be highly effective. This closely aligns with the Flipped Kirkpatrick method, in which you start by asking what results you want the training to achieve. This is where the bulk of the time can be spent, collaborating with stakeholders to clarify:  

• What is your “why?”  

• What change is your program trying to effect? (i.e., Are you trying to decrease errors? Increase sales? Improve customer/client satisfaction?) 

• How will success be measured? Is there a baseline of data to serve as your starting reference point? 

Q: How do you determine the learning objectives and goals for a training program?  

A: To ensure they are clear, measurable, and aligned with both organizational needs and learner expectations, there are several key steps involved:  

• Identify business needs: Understand the broader business goals and how the training program can support these objectives to help ensure that the training is both relevant and impactful.  

• Conduct a training needs analysis: Use surveys, performance data analysis, observations, and interviews to assess the current skills and knowledge of the learners to identify gaps.  

• Define desired outcomes: Clearly articulate what you want learners to achieve by the end of the training, making these outcomes specific and aligned with the identified business needs.  

• Prioritize objectives: Determine which objectives are most critical to achieving the desired outcomes and focus on those to help create a more targeted and effective training program.  

• Test and refine: Before finalizing, review the objectives with stakeholders and potential learners to make sure they are clear and achievable, and then adjust based on feedback. 

• Align with assessment methods: Make sure the objectives can be measured through appropriate assessment methods such as practical exercises, performance evaluations, knowledge retention quizzes, and behavioral assessments. 

Q: How do you balance theoretical knowledge with practical, hands-on training in your programs?  

A: This is a crucial aspect of creating effective learning experiences. Here are some strategies to achieve this balance:  

• Integrate real-world scenarios: Using case studies, simulations, and role-playing exercises to apply theoretical concepts to real-world situations helps learners connect the dots between theory-based knowledge and see the practical relevance of what they are learning.   

• Blended learning approach: Combine online theoretical modules with in-person or virtual hands-on sessions to allow learners to absorb the theory-based knowledge at their own pace and then apply and practice it in a guided, simulated environment.  

• Project-based learning: Assign projects that require learners to apply theoretical knowledge to solve real problems, encouraging critical thinking and practical application of knowledge.   

• Interactive workshops: Conduct workshops that mix lectures with interactive activities. For example, after a theoretical lecture, have learners participate in group discussions or hands-on labs to reinforce the concepts.  

• Feedback and reflection: Encourage learners to reflect on their practical experiences and provide feedback on how the theory helped or could be improved. This reflection helps solidify their understanding and application of the knowledge.  

• Mentorship and coaching: Post-training reinforcement is critical to knowledge retention and positive learner outcomes. One option would be to pair learners with mentors or coaches who can provide practical insights and guidance on applying theoretical knowledge in real-world contexts.   

Q: What considerations do you factor in when designing training for remote or hybrid teams compared to in-office teams?   

A: This involves several unique considerations to ensure effectiveness and engagement. Here are some key factors:  

• Accessibility: Ensure that all training materials are accessible to everyone, regardless of their location or abilities. This could include providing video transcripts, closed captions, and alternative formats like audio recordings.   

• Flexibility: Offer a mix of synchronous (live) and asynchronous (self-paced) training options. This can allow attendees to choose what works best for their schedules and learning preferences.   

• Engagement: Use interactive elements such as quizzes, polls, and virtual breakout rooms to keep remote learners engaged. Incorporating gamification and social learning opportunities can also help make learning fun while fostering interaction and motivation.   

• Technology: Ensure that the technology used for training is reliable and user-friendly. Be prepared to provide support and training, if needed, on how to use the necessary tools and platforms.   

• Communication: Use multiple channels like email, chat, and video calls to maintain clear and consistent communication throughout the training process. This helps to keep everyone informed, connected, and motivated.   

• Collaboration: Facilitate collaboration between remote and in-office employees through group activities and projects. This can be accomplished by using collaborative tools like shared documents and virtual whiteboards to drive teamwork.   

• Feedback and support: Provide opportunities for learners to give feedback on the training and offer support through mentors or coaches.   

By considering these factors, you can create a training program that effectively meets the needs of remote, hybrid, and in-office teams, while also ensuring that participants have a positive, productive learning experience.   

Q: What role does follow-up or continuous learning play in ensuring long-term success of a training program?   

A: Conducting follow-up and continuous learning is critical to learner retention and whether your training program will be successful or not. Follow-up activities will help reinforce the knowledge and skills acquired during training. Repetition and practice are critical to building muscle memory for long-term retention and ensuring learners can effectively apply what they’ve learned. Continuous learning opportunities, such as practical assignments, facilitate the transfer of skills from the training environment to the workplace. This helps learners integrate new skills into their daily work. Regular follow-up and practice boost learners’ confidence in their abilities, which, in turn, translates into better performance and a greater willingness to take on new challenges. Ongoing support and feedback mechanisms allow learners to identify areas for improvement, refine their skills, and achieve mastery and continuous professional development. Follow-up activities help keep learners engaged and motivated. Sustained engagement is vital for fostering a culture of continuous improvement within the organization. By incorporating follow-up and continuous learning into your training programs, you can ensure that the initial investment in training yields long-term benefits for both the individuals and your organization.   

Q: How do you ensure that leadership and senior management are aligned and supportive of the training initiatives you develop?   

A: Ensuring that leadership and senior management are aligned and supportive of training initiatives is critical to their success. Some strategies that have proven beneficial throughout my career include:   

• Align with organizational goals: Clearly demonstrate how the training will support the organization’s strategic goals. This helps leaders see the direct impact on business outcomes.  

• Engage early and often: Involve senior leaders from the beginning of the training development process and seek their input on key business challenges and how training can address them.  

• Identify an executive sponsor: Identify and engage an executive sponsor who can champion the training initiative. Optimally, this person should be respected within the organization and have a vested interest in the success of the program.  

• Provide data and metrics: Use data, when possible, to show the potential return on investment (ROI) of the training.  

• Regular updates and feedback: Keep leadership informed about the progress of the training by providing regular updates. Solicit feedback and adjust as needed to ensure alignment with their expectations.  

Adopting these strategies can help you secure the support and alignment of leadership, ensuring that your training efforts are well-received and effective.  

About Michelle 

Michelle Holloway joined BerryDunn's Learning and Development team as a Learning Consultant in August 2024. She is a transformational leader with over 15 years of adult learning experience and has earned a reputation for embracing challenges and driving operational excellence. Michelle honed her expertise in training program development and administration, encompassing strategy, budget planning, and team optimization. Her ability to build consensus among executive teams and stakeholders has consistently promoted transparency and influenced positive change. She excels at overseeing the development, implementation, and delivery of scalable programs that adapt to the evolving needs of the business. Michelle is adept at designing and facilitating highly effective training curricula across various modalities, including computer-based courses, web-based courses, interactive classrooms, and virtual webinars. Her collaborative approach with partners, stakeholders, and vendors ensures the successful execution of program strategies and plans. 

BerryDunn partners with organizations to create work environments where business success and personal growth coexist and where people are confident knowing their workplace positively contributes to their well-being. We take a comprehensive approach to our workforce and well-being work, considering how business needs, organizational capacity, and the employee experience work together to drive your business forward. Learn more about our workforce and well-being team and services.