financial services

As BerryDunn’s Healthcare Practice Group lead, Lisa Trundy-Whitten is closely attuned to the healthcare industry. From challenges faced by healthcare organizations to the solutions BerryDunn’s experts can provide, Lisa shares thoughtful insights for healthcare leaders.   

We recently hosted the NAVIGATE Healthcare Leadership Summit, our annual virtual event featuring BerryDunn industry experts and four hours of educational sessions on critical issues facing healthcare today. Our team offered strategic insights on:

• Navigating the industry's most pressing challenges 
• Exploring OBBBA and the Rural Healthcare Transformation Program 
• Responding to payer audits and protecting revenue 
• Strengthening AI oversight after implementation

Navigating the now 

We kicked off the summit with a discussion on the state of the industry. From hospitals to senior living and home health and hospice to health centers, we recognize the challenges you face—shrinking margins, rising labor costs, workforce shortages, Medicare and Medicaid reimbursement, increased payer complexity, capital demands (e.g., aging facilities, technology investments), and more. The session offered several best practices, including:

• Staying ahead of CMS Fraud, Waste, and Abuse (FWA) compliance 
• Identifying regulatory risks, planning, and preparing to adapt 
• Focusing on audit readiness 
• Reviewing policies and procedures to align with requirements, revising as needed 
• Prioritizing payer strategy and price transparency and negotiation 
• Verifying the latest requirements online to avoid denied or delayed claims

OBBBA and the Rural Health Transformation Program Insights 

The H.R. 1 One Big Beautiful Bill Act (OBBBA) and Rural Health Transformation Program (RHTP) are important developments for finance and revenue cycle leaders to watch. Key takeaways from this session are:

OBBBA: 

• Automate eligibility checking. 
• Monitor payer mix and model impacts of Medicaid changes. 
• Review policies and procedures, update, and train staff. 
• Strengthen your revenue cycle and compliance programs. 

RHTP: 

• Monitor state rural health website for opportunities. 
• Join CMS and state list services. 
• Find the best opportunity for your organization to participate. 
• Determine populations to serve and services.  
• Identify areas to grow, develop, or partner with another organization. 

Payer audit strategies 

Payer audits continue to evolve across Medicare, Medicaid, and commercial plans, requiring providers to understand audit types, risks, and emerging trends to respond effectively. Our experts recommend the following actions: 

• Assess audit type and intent to guide response strategy. 
• Find out who initiated the audit, what’s being requested, deadlines, and submission requirements. 
• Don’t submit incomplete or excessive documentation because it increases risk rather than strengthening position. 
• Get better outcomes with strong documentation and an organized approach. 
• Evaluate results, address repayment or appeals, and implement corrective actions to reduce future risk. 

AI in the enterprise 

AI adoption in healthcare is quickly moving from experimentation to widespread operational use, but many organizations still lack the governance, controls, and oversight needed to manage associated risks. Here’s some post-implementation guidance: 

• Policy integration and oversight are critical.  
• Key risks include data exposure, bias, cybersecurity threats, over-reliance, and IP violations.  
• Control practices like data classification, human involvement, and traceability are essential. 
• Governance requires defined leadership, policies, and cross-functional involvement.  
• Monitoring, auditing, and reassessment are vital. 

Key takeaways

• Address financial and operational pressure by evaluating margin pressure, labor costs, workforce shortages, reimbursement challenges, payer complexity, and capital needs. 
• Prepare for regulatory and reimbursement changes by monitoring developments tied to OBBBA, Medicaid impacts, and RHTP funding opportunities. 
• Strengthen payer audit response by clarifying audit type, request scope, deadlines, documentation requirements, and follow-up actions. 
• Build stronger compliance and revenue cycle processes by updating policies, training staff, and improving audit readiness. 
• Establish AI governance after implementation by defining oversight, managing risk, and using controls such as data classification, human review, and ongoing monitoring. 

BerryDunn can help 

We’re here to support you. Reach out with questions or for guidance on how to strengthen your operations. I encourage you to learn more about our team and comprehensive services across healthcare.   

Best, 

Lisa Trundy-Whitten 

Read this if you are involved in budgeting, performance, or oversight of FQHC operations.

This article is the third in a three-part series to help Federally Qualified Health Centers understand how site- and program-specific accounting is essential to sustainability.

Site- and program-specific accounting is a powerful tool that gives Federally Qualified Health Centers (FQHCs) the visibility they need to optimize operations for long-term sustainability. Article one explores why that visibility matters—because an organization-wide view can't reveal what's happening at individual locations and within programs. Article two then breaks down how to lay the groundwork for reliable reporting by restructuring the general ledger, modifying payroll data, and aligning the accounting structure with the EHR so results can be reported consistently. 

That leads to the practical question at the core of this article: How do you use months of accumulated site- and program-specific financial data to plan and budget? This article explains how FQHCs can translate location- and service line-level reporting into budgets that reflect real operating conditions, engage site and program leaders, and create accountability by regularly comparing results to budget and monitoring performance trends over time. 

Driving change with site- and program-specific financials 

With systems modified to report on sites and programs, an FQHC can begin tracking monthly financials and using the data to fine-tune planning and budgeting. If reporting shows that a program or site is not performing well, questions arise. Has there been significant turnover at that location? What's the reason behind it? What are other sites doing differently that might lead to better results? 

Without the level of detail provided by site- and program-specific accounting, an underperforming site can adversely impact the financial performance of the entire organization without ever being identified as the problem. However, when systems are modified to report on location or service-line performance, organizations can analyze the data to determine why a site or program is underperforming and take corrective action. Conversely, if the financials indicate a high-performing location with strong provider productivity, key metrics can be reviewed to identify the differentiators. Once identified, those practices can be replicated across locations to achieve similar results. 

Site- and program-specific reporting also creates valuable benchmarking opportunities. Comparing locations and programs allows leadership to identify operational differences, understand why performance varies, and replicate successful practices across the organization. 

If the data points to a patient mix issue at one health center, leadership may determine that the site faces structural challenges that differ from those at other locations. Understanding those factors allows the organization to establish realistic expectations and make informed strategic decisions regarding resource allocation and support.  

However, if the financial reporting shows that a lack of centralized scheduling gives providers too much control and results in fewer appointments than at other sites, the cause is clear. Modifying schedule templates may lead to a substantial increase in provider productivity and potentially additional revenue. Likewise, when the data indicates provider productivity is low and that seeing one additional patient per day will improve financial performance, there's an obvious path to improvement. 

Without reporting by site and by program, results for the entire organization are lumped together without any insight into the root cause. Moving to a more granular level of financial reporting ultimately supports financial stability and sustainability by helping leadership identify issues and address them more effectively. It's no longer a guessing game. 

Budgeting, buy-in, and accountability 

After implementation, budgets can be built by location and program. To create meaningful accountability and organizational alignment, it’s essential that key stakeholders—program and site directors—participate in the budget process. Their involvement helps ensure budget assumptions are realistic, operational priorities are understood, and goals are aligned across the organization. Then, through monthly financial reports and reviews of results, directors are accountable for the performance of their respective site or program. Results could even be tied to their compensation, reinforcing accountability for achieving budget goals. 

Director involvement gives them ownership and a clearer path to achieving goals. If they aren't invited to collaborate, and decisions are instead made at the C-suite level and given as mandates, the likelihood of stakeholder buy-in decreases.  

Not only does accounting by program and location support improved financial results and sustainability, but it also enhances communication at the management and board levels by improving transparency. It facilitates clearer reporting and provides an in-depth understanding of performance. This, in turn, gives leadership the ability to make more strategic decisions around correcting underperformance and replicating successes while strengthening the organization’s long-term financial sustainability through a more accurate understanding of operational performance.

BerryDunn can help  

Faced with rapid changes in an increasingly competitive environment, community health centers rely on our seasoned professionals to refine business strategies, streamline operations, and introduce proven best practices to enhance performance while managing costs. Our team works with a comprehensive range of community health providers, including FQHCs, FQHC Look-Alikes (LALs), and Rural Health Clinics (RHCs). Learn more about our team and the services we provide. 

Medicaid providers need to understand what changes have been implemented in each of the state Medicaid programs in which they participate. This article outlines recent guidance from CMS Administrator Dr. Mehmet Oz directing state Medicaid programs to strengthen provider revalidation efforts, explains why these changes matter for providers, and highlights practical actions organizations can take to prepare for increased scrutiny, tighter timelines, and potential enrollment-related compliance risks.

Who this applies to: Medicaid providers in all 50 states 

Impact of new revalidation requirements on Medicaid providers

The updated CMS requirements add scrutiny and compressed timelines, heightening operational urgency and compliance risk for providers.

• Revalidation requests may occur sooner than expected. 
• Providers may be required to resubmit full enrollment documentation. 
• The traditional five-year revalidation cycle may be interrupted or shortened. 
• Providers identified as high risk may be subject to additional oversight. 

Increased enforcement is linked to a broader federal effort to address Medicaid fraud, waste, and abuse, and compliance risks CMS faces in funding unqualified providers. 

• Revalidation is moving from routine to continuous monitoring as a method for detecting fraud. 
• There will be a tighter review of licensing, staffing, operations, programs, etc. 
• The guidance will vary by state but will have federal oversight. 

Guidance for Medicaid providers 

While each state’s strategy for phased revalidation will vary, now is the time for providers to prepare. 

• Confirm that you have access to your state’s Medicaid provider revalidation portal. 
• Ensure that your organizational contact information is correct. 
• Verify that your enrollment data with your state department of health is accurate. 
• Review your NPPES profile to ensure your taxonomy is accurate. 
• Gather your documentation now to be prepared. 
• Watch for a revalidation notification—delivery method may vary by state. 
• Be timely with your response and thoroughly provide requested documentation. 
• Visit the revalidation portal for additional details. 

Failure to meet deadlines or provide requested documentation could lead to claim denials or termination from state participation. 

Key takeaways

• Prepare for shorter revalidation cycles and earlier requests. 
• Update enrollment data and documentation now. 
• Expect increased scrutiny and ongoing monitoring. 
• Respond quickly to revalidation notices to avoid disruptions. 

BerryDunn can help 

Need help complying with your state’s provider revalidation strategy? BerryDunn’s team of experts understands the challenges that these off-cycle revalidations can have when staffing and workforce are already stretched thin and can help with short-term or longer-term solutions.  

Our firsthand experience as an NCQA-certified CR serving clients across the continuum of care means we offer a variety of strategic credentialing, enrollment, and payer contracting consulting services to meet your organization’s specific needs. With a strong focus on the provider experience, our thought leaders help organizations accelerate onboarding, maintain compliance with state, federal, and payer requirements, and improve revenue cycle performance by minimizing credentialing and enrollment delays and having a sound payer contracting and reimbursement strategy. Learn more about our team and services. 

State Medicaid agencies and Managed Care Organizations (MCOs) are facing growing pressure to better coordinate care across providers, vendors, and different state and federal agencies while reducing administrative complexity for members. Federal and state priorities—including greater focus on behavioral health integration, mental health parity, continuity of coverage, and proactive oversight—are also increasing expectations around coordination, accountability, and operational performance. 

These shifts were reflected in recent industry discussions, including conversations at the 2026 Medicaid Managed Care Conference in San Diego, which reinforced broader trends emerging across Medicaid managed care: stronger coordination across complex care systems, reducing barriers that make it harder for members to access and navigate care, and earlier identification of member needs, service gaps, and challenges. 

While Medicaid managed care programs vary across states, several common operational challenges continue to surface across programs. 

Reducing fragmentation across care delivery systems 

One recurring challenge involves fragmentation across the organizations, vendors, providers, and systems involved in managing member care. 

As Medicaid programs adapt to new federal requirements and continue expanding focus on behavioral health integration, Long-Term services and Supports (LTSS), social determinants of health, and complex care management, states are strengthening coordination across overlapping care delivery systems. Care transitions often require coordination across multiple entities, including state agencies, MCOs, providers, and case workers—each responsible for different aspects of the member experience. 

Without clear expectations around information sharing, accountability, and follow-through across multiple handoffs, coordination breakdowns may occur. As a result, organizations are focused on building more standardized and coordinated operational models through: 

• Clear accountability structures and standardized escalation pathways 
• Shared visibility into care transitions and barriers 
• More integrated care planning approaches 

Together, these approaches reflect growing recognition that fragmentation is as much an operational challenge as a clinical one. For states, this trend is likely to drive greater emphasis on coordination requirements within procurements, contracts, and oversight of health plan activities. 

Addressing administrative complexity, member navigation challenges, and continuity of care 

Members often must navigate multiple administrative care coordination challenges simultaneously in order to maintain coverage and receive care, including: 

• Managing eligibility and coverage renewal requirements 
• Delays and requirements related to service and medication approvals 
• Resolving coverage denials and grievance issues 
• Managing prescription coverage and pharmacy requirements 
• Language and communication barriers 
• Navigating multiple organizations involved in coverage and care 

Recent Medicaid public health emergency unwinding activities and prior state experiences implementing community engagement requirements highlighted how procedural barriers and communication challenges impact continuity of coverage and access to care, particularly for vulnerable populations and individuals with complex needs. Recent KFF analyses of Medicaid unwinding data found that a significant share of Medicaid disenrollments nationally were tied to procedural reasons rather than confirmed ineligibility. 

As states implement new federal Medicaid eligibility and redetermination requirements, many managed care programs may face renewed pressure to strengthen member outreach, communication, and navigation support in order to reduce avoidable coverage disruptions. 

Moving from reactive intervention to proactive, data-driven oversight 

Historically, managed care oversight has focused heavily on retrospective reporting and compliance monitoring. Today, organizations are seeking to identify risks earlier—before they result in avoidable utilization, member dissatisfaction, or coverage disruptions. 

This shift is driving greater focus on: 

• Real-time operational dashboards and integrated reporting across vendors and functions 
• Utilization management and care transition monitoring 
• Predictive analytics and risk stratification 
• Proactive member outreach models 
• Greater visibility into operational “friction points” across the member experience 

This growing emphasis underscores that challenges for members, such as delayed authorizations, communication breakdowns, fragmented transitions, or barriers navigating eligibility, authorization, or care coordination processes, can directly impact program quality, equity, and continuity of care. In response, State Medicaid managed care programs are looking for ways to better connect areas such as member services, utilization management, pharmacy, grievances, and care management to identify barriers and risks earlier in the member journey. 

Creating seamless member experiences 

Medicaid managed care programs continue evolving alongside changing regulatory requirements, member needs, and growing expectations around coordination and accountability. More focus on coordination, greater insight into how systems perform in practice, and earlier identification of risk (not solely whether minimum compliance requirements are being met) can create a better member experience. Streamlining managed care operations requires stronger coordination across systems, vendors, and care coordination activities to support more seamless and member-centered experiences. 

How BerryDunn can help 

We provide key insights to Medicaid agencies seeking opportunities to improve their delivery of services, expand and manage provider networks, and mature provider payment models. We can help you oversee benefits and services through contracted arrangements with MCOs. Learn more about our services and team.  

The Rural Health Transformation Program (RHTP) presents a meaningful opportunity for organizations working to expand access and improve outcomes in rural communities. But with federal funding comes a heightened level of scrutiny. Accounting professionals play a critical role in ensuring grant management activities are set up properly, funds are managed appropriately, compliance requirements are met, and risks are minimized. 

A strong foundation starts with understanding and applying the requirements in 2 CFR 200. Below are five essential areas every RHTP recipient should address to set up the grant management activities properly to support compliance and long-term success. 

1. Build an accounting system that meets federal standards 

Your accounting system should be designed to support clear, accurate grant tracking. At a minimum, it must allow you to: 

• Track RHTP funds separately using unique fund identifiers 
• Monitor budget-to-actual performance by approved cost categories 
• Maintain transaction-level detail with supporting documentation 
• Provide a complete audit trail from financial reports to source documents 
• Align with federal or state reporting requirements for RHTP activities 
• Adequately track grant activities for subrecipients 

Cost classification is a key component of this structure. Direct costs are tied specifically to the grant, such as program staff salaries, supplies, travel, and contracted services. Indirect costs support shared operations like administration, facilities, and IT. 

Organizations must either use a federally negotiated indirect cost rate agreement (NICRA) or elect the 15% de minimis rate if the organization does not have a negotiated rate. 

Personnel expenses require particular attention. Time and effort reporting must reflect actual work performed, include total compensated activity, and be reviewed and approved. For employees working across multiple cost centers or activities, certifications should occur at least twice per year. 

2. Establish internal controls that support compliance with Section 200.303

This starts with a strong control environment. Organizations should have documented financial policies aligned with federal requirements, clearly defined roles and responsibilities, and ongoing staff training. Leadership should actively reinforce the importance of compliance. 

Day-to-day control activities are just as critical. These include: 

• Segregating duties across authorization, custody, and recordkeeping (ARC) 
• Defining clear mitigating controls in instances where the ARC activities cannot be separated  
• Defining approval thresholds and workflows 
• Performing regular reconciliations and management reviews 
• Maintaining organized and complete documentation 
• Retaining records for at least three years from the date of submission of the final financial report, in accordance with 2 CFR 200.334 (longer if required for audit, litigation, or other federal requirements)

If your program includes equipment purchases, you will also need property records and procedures for conducting physical inventories. 

3. Follow procurement standards to ensure fair and open competition 

Federal procurement rules are designed to promote competition and responsible spending. Your policies should align with the thresholds outlined in 2 CFR 200. 

• Micro-purchases up to $10,000 do not require quotes but must be reasonably priced 
• Small purchases up to $250,000 require quotes from multiple qualified sources 
• Larger purchases may require sealed bids or competitive proposals, depending on the situation 
• Sole-source procurement is allowed only in limited circumstances and must be fully justified and documented

Before entering into any covered transaction over $25,000, you must verify that the vendor is not suspended or debarred using SAM.gov. Many organizations extend this practice to all purchases as a risk mitigation step. These checks performed against SAM.gov are also required for any employees being paid under the grant in excess of $25,000. Organizations should have procedures in place to perform these checks on a monthly basis. 

Conflict of interest policies should also be clearly defined. These should address financial interests, family relationships, gifts, and outside employment, along with disclosure requirements and enforcement measures. 

4. Strengthen subrecipient oversight 

If your organization passes funding through to subrecipients, you are responsible for ensuring those subrecipients comply with federal requirements. 

Start by determining whether an entity is a subrecipient or a contractor. Subrecipients carry out program activities and make programmatic decisions. Contractors provide goods or services as part of normal business operations. This distinction affects how you monitor and manage the relationship, so it should be clearly documented. 

• The prime recipient should develop clear grant agreements, terms and conditions, and other grant reporting templates that are in compliance with 2 CFR Part 200 and the specific requirements of the RHT program. These documents should be developed in order to provide the subrecipients with clear guidance and responsibilities under the grant.  
• Before issuing an award, assess subrecipient risk based on factors like prior audit results, experience with federal funding, and internal systems. You will also need to confirm eligibility through SAM.gov and communicate all required award details. 
• Ongoing monitoring should include reviewing financial and performance reports, conducting site visits when appropriate, and obtaining single audits for entities that meet the federal threshold. Any audit findings must be addressed with a formal management decision within six months. 

5. Apply the rules for allowable costs 

Every cost charged to RHTP funding must meet the five tests for allowability. Costs must be reasonable, allocable, consistent, conform to the award terms, and fully documented. 

Some expenses require prior written approval before they can be charged to the grant. These may include pre-award costs beyond 90 days, equipment purchases over $5,000, certain participant support costs, foreign travel, and significant budget changes. 

There are also costs that are always unallowable. These include alcohol, entertainment, fundraising expenses, personal-use items, lobbying, fines, and losses from other awards. Charging these costs can lead to audit findings or repayment requirements. 

Set the foundation early 

Managing RHTP funding successfully requires more than basic accounting. It demands a proactive approach to compliance across systems, processes, and people. 

By strengthening your accounting infrastructure, reinforcing internal controls, aligning procurement practices, developing clear guidance for your subrecipients, actively monitoring subrecipients, and applying allowability rules, you can reduce risk and position your organization for clean audits and successful program outcomes. 

A solid compliance framework does more than protect funding. It allows your organization to stay focused on its mission to improve rural health where it is needed most. 

How BerryDunn can help 

Our experienced consultants have decades of expertise advising rural healthcare providers. We partner with clients to deliver rural healthcare transformation services that are practical, compliant, and sustainable—grounded in firsthand experience with rural delivery models, workforce constraints, and community needs, and aligned with CMS requirements. Learn more about our services and team.