IT security

According to the US Department of Housing and Urban Development’s (HUD’s) 2024 Annual Homelessness Assessment Report, nearly 770,000 people experienced homelessness on a single night in January 2024, an 18% increase from the prior year and the highest total since point-in-time counts began in 2007. Family homelessness surged by almost 40%, and unsheltered homelessness grew in parallel, with more than one-third of all unhoused individuals living in tents, vehicles, encampments, or other places not meant for human habitation. Chronic homelessness also reached a record high, with over 152,000 people experiencing long-term or repeated episodes of homelessness; nearly two-thirds were unsheltered.

The Supplemental Nutrition Assistance Program (SNAP) is one of the most effective stabilizers for extremely low-income households, reducing food insecurity by up to 30% and lowering downstream healthcare costs, according to research from the University of Pennsylvania Leonard Davis Institute of Health Economics and Harvard Public Health scholars. For people experiencing homelessness, particularly those who are unsheltered, SNAP access often determines whether limited resources can be redirected toward transportation, medical care, or pathways into housing.

The H.R. 1 One Big Beautiful Bill Act (OBBBA) marks a critical turning point. By expanding Able Bodied Adults Without Dependents (ABAWD) requirements and tightening SNAP and Medicaid eligibility, the bill reshapes access to public assistance programs that help prevent people from falling deeper into homelessness. New compliance hurdles threaten food security for many unsheltered individuals who cannot realistically meet the documentation and work requirements. The OBBBA ABAWD expansion points to the need for a new statewide approach to unsheltered homelessness that better supports the safety and health of unsheltered families.  

Why unsheltered adults are most at risk under ABAWD rules 

Under OBBBA, SNAP eligibility and participation rules are significantly tightened through an expansion of ABAWD requirements. The law extends SNAP time limits to all adults ages 18-64 and eliminates the longstanding exemption for people experiencing homelessness. Individuals subject to ABAWD rules must now document at least 80 hours per month of work, job training, or qualifying volunteer activities to maintain benefits. OBBBA also narrows overall SNAP eligibility, resulting in benefit losses for additional groups, including certain immigrants, such as asylees and parolees, individuals with deportation withheld, and individuals exiting the foster care system.

These changes have particular implications for people experiencing homelessness, for whom meeting work and reporting requirements is often far more difficult. Unhoused individuals frequently lack a permanent address, reliable transportation, or consistent access to phones, internet, or mail. Lost identification documents, irregular schedules, and high rates of chronic physical and behavioral health conditions further limit their ability to document hours or navigate verification systems. Older unhoused adults, now newly subject to ABAWD rules, often face compounded barriers due to health conditions or unstable work histories. 

At the same time, OBBBA increases administrative and reporting demands across SNAP. For individuals without stable housing, these added requirements raise the risk of procedural disenrollment even when eligibility criteria are technically met. As SNAP access declines, food insecurity among people experiencing homelessness is expected to increase, shifting greater demand onto food pantries, shelters, and other emergency food providers. Estimates from the Urban Institute suggest that nearly 700,000 young adults could lose some or all SNAP benefits each month under expanded work‑reporting rules, underscoring the scale of potential impact.

SNAP ABAWD requirements: Before and after OBBBA 

OBBBA significantly expands SNAP ABAWD requirements, removing the longstanding homelessness exemption and increasing documentation and work reporting expectations. 

What states can expect 

States must now implement expanded ABAWD rules under far tighter federal expectations. OBBBA increases state administrative cost‑sharing for SNAP and adds new sanctions, reporting mandates, and verification requirements, creating significant fiscal and operational strain for human services agencies already managing complex caseloads. 

OBBBA’s SNAP changes result in: 

• Increased administrative costs and cost-sharing 
• Need to modify systems and technologies 
• Close workforce and provider capacity gaps, such as workforce training slots, subsidized employment programs 
• Documentation bottlenecks and backlog due to increased reporting and verification requirements 
• Concerns over equity impact, including older adults, individuals with disabilities, and vulnerable populations 
• Increased pressure on emergency services 
• Additional pressure on community partners and systems as more people lose benefits 

Collectively, states face greater fiscal pressure: increased responsibility for SNAP administration and rising demand from individuals who have become newly food‑insecure. 

What can states do? 

States can consider the following strategies across eligibility, workforce, and employment programs to mitigate these risks. 

1. Strengthen ABAWD Screening and Exemption Identification 

With the elimination of the homelessness exemption, states must ensure all remaining exemptions are identified early and accurately, particularly physical or mental unfitness for work, which is highly prevalent among unsheltered adults. States can: 

• Partner with community health centers and behavioral health providers to rapidly document qualifying impairments

• Train eligibility workers, outreach teams, shelter staff, and case managers to flag individuals likely to qualify for exemptions

2. Build Direct Pathways into SNAP Employment & Training (E&T) 

For individuals unable to secure consistent work hours, E&T will become a primary compliance pathway. States can: 

• Co-design low-barrier, trauma-informed E&T tracks with homelessness providers

• Ensure programs are flexible, accessible, and supported by transportation or virtual options

3. Co-locate Eligibility Services in Homelessness Settings 

Preventing procedural terminations will require bringing eligibility services directly to people experiencing homelessness. States can: 

• Deploy mobile eligibility teams to shelters, encampments, day centers, meal sites, and transitional housing
• Embed SNAP, Medicaid, and workforce eligibility staff in high-volume service providers, including behavioral health clinics and social service providers
• Establish rapid recertification stations to assist with reporting, documentation, and renewals
• Partner with libraries and community centers to provide digital access, printing, and identity verification support

4. Coordinate SNAP, Medicaid, and housing systems 

Because OBBBA also imposes Medicaid cuts and work requirements, cross-program coordination is essential to maintain stability. States can: 

• Integrate data systems to trigger alerts when individuals lose benefits or fall out of compliance

• Create unified outreach teams spanning SNAP, Medicaid, and housing services

5. Strengthen housing placement infrastructure 

Loss of nutrition and health benefits increases the risk of prolonged homelessness, making housing exits more urgent. States can: 

• Expand supportive housing for chronically homeless adults newly subject to ABAWD requirements. 

• Increase landlord engagement and mitigation funds to shorten placement timelines. 

• Integrate housing navigation into SNAP and Medicaid case management. 

6. Reduce administrative burden 

Expanded ABAWD rules significantly increase administrative demands. To reduce churn and unnecessary benefit loss, states can: 

• Automate work hour reporting and simplify notices. 
• Implement presumptive eligibility for high-risk populations while documentation is gathered. 
• Expedite renewals and recertifications for individuals facing termination due to administrative barriers. 

State strategies to mitigate ABAWD-related risk 

States can mitigate the impact of expanded ABAWD requirements through coordinated eligibility, workforce, housing, and administrative strategies. 

OBBBA’s expanded ABAWD time limits and massive cuts to SNAP arrive at a moment of rising unsheltered homelessness, shrinking safety nets, and deepening public health risks. The combination threatens to push thousands of adults into homelessness while overwhelming state systems. By recognizing the convergence of ABAWD rules and unsheltered homelessness and responding proactively, states can prevent avoidable harm, reduce long-term costs, and stabilize residents on the brink. 

BerryDunn can help

Our human services consulting team works with you to help build sustainable programs that support the safety and well-being of children, youth, and families, while supporting the professionals who serve them. We work with agencies to leverage information and drive data-based decision-making for interested parties to create more stable environments that support the reduction in vulnerability among children, youth, and families. Learn more about our team and services. 

Read this if you are a finance director or executive director at a public housing agency.

Beginning with calendar year 2026, public housing agencies (PHAs) will be required to submit an annual Federal Financial Report (SF-425) for each operating subsidy grant. Reporting will continue annually until all funds are fully expended or returned to HUD. These changes reflect HUD’s increased focus on transparency, grant life cycle oversight, and compliance monitoring. 

Key changes to SF-425 

Under the updated guidance: 

• PHAs must submit annual SF-425s at the Asset Management Project (AMP) level, due annually on April 30, throughout the seven-year period of performance. 
• The order of operating expenditures has been reaffirmed, requiring rental income to be expended before operating subsidy. 
• Monthly operating subsidy draws remain permitted, but unspent subsidy may be reported as unearned revenue until eligible costs are incurred. 
• Nonrental program income may be retained and used flexibly, including for Section 8 purposes or to benefit residents. 
• PHAs must perform annual interest calculations on federal funds, retaining up to $500 and returning excess interest to HUD. 
• Record retention and compliance requirements have expanded, with sanctions possible for noncompliance. 

Increased visibility into Operating Fund dollars for HUD 

These changes significantly expand HUD’s visibility into how Operating Fund dollars are drawn, spent, and retained over time. PHAs that do not align their accounting practices, grant tracking, and documentation with the updated SF-425 framework may face increased monitoring, reporting burdens, or enforcement actions. Early preparation can help agencies preserve liquidity, reduce compliance risk, and avoid operational disruption as HUD enhances oversight.

Action steps for PHAs 

PHAs should begin preparing now by taking the following steps: 

• Review accounting policies to ensure rental income, nonrental income, and operating subsidy are properly tracked and reported. 
• Evaluate grant tracking systems to support multiyear SF-425 reporting through the full period of performance. 
• Confirm interest calculation methodologies and establish processes to return excess interest timely. 
• Train finance and program staff on the revised order of operating expenditures and reporting requirements. 
• Assess record retention practices to ensure compliance with extended retention timelines tied to final SF-425 submission. 

BerryDunn can help 

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. We have experience with affordable housing agencies subject to audits under both FASB and GASB, as well as the various tax credits available, HUD compliance, annual Real Estate Assessment Center (REAC) submissions, and other compliance matters. Learn more about our team and services. Reach out to discuss how your organization can prepare for the upcoming changes. 

The following is the second article in a two-part series that provides a detailed examination of Form 990, Schedule A, offering practical guidance to the many organizations responsible for its complete and accurate preparation. 

To quote George R. R. Martin, “Different roads sometimes lead to the same castle.” The same can be said for Schedule A. When it comes to qualifying as a public charity, the IRS offers more than one path forward. In Part I of this series, we explored the Schedule A Part II public support test—a common route for donor‑supported organizations. In this second installment, we turn to the Schedule A Part III test, an alternative approach designed for organizations that operate under a fee‑for‑service or program‑revenue model. While the tests are different, both can ultimately lead to the same destination: public charity status. 

Who qualifies for the Part III test? 

Under Schedule A, Part I, Line 10 – Section 509 (a)(2), a qualified organization normally receives the following over a five-year computation period: 

• More than 33.33% of its support from contributions; membership fees; and gross receipts from admissions, sales of merchandise, performance of services, or furnishing of facilities in an activity that isn’t an unrelated trade or business under section 513 
• No more than 33.33% of its support must normally come from gross investment income and net unrelated business income (less section 511 tax) from businesses acquired by the organization after June 30, 1975 

How Part III differs from Part II 

1) Treatment of program revenue 
The Part III test is generally preferable for organizations that primarily generate revenue through program service activities (i.e., fee‑for‑service revenue activities), whereas Part II is generally preferable for organizations that primarily generate revenue through donations/contributions from the general public. The Part III test does take contribution income into account as part of the public support test calculation, but the Part II test specifically focuses on contribution income only and does not take into account revenues from program service activities. 

2) Exclusions from public support: Disqualified persons
The Part III test requires certain amounts to be excluded from the public support calculation. These exclusions reduce the numerator of the public support fraction and can directly affect whether an organization remains above the required 33.33% public support threshold. 

Amounts received from disqualified persons 

Any amounts of contribution income or program service revenue received from “disqualified persons” are required to be removed from the public support calculation entirely. The most common examples we see in practice are donations made to the organization by officers or other members of the organization’s board. The IRS considers disqualified persons to be “insiders” and, as such, are not considered part of the general public for purposes of the test. 

Disqualified persons include the following: 

a. Substantial contributors: Any person who has contributed more than $5,000 in total and whose contributions exceed 2% of all contributions received since the organization’s inception 

b. Foundation managers, defined as officers, directors, trustees, or individuals with power or similar authority to officers, directors, or trustees 

c. Owners of more than 20% of a corporation, partnership, trust, or other entity that is a substantial contributor to the organization 

d. Family members of any of the above, limited to spouses, ancestors, children, grandchildren, great‑grandchildren, and their spouses

Note: Because the disqualified person definition is far-reaching, it amplifies the need for organizations to have in effect sound practices, policies, and procedures concerning potential conflicts of interest. These relationships can not only affect governance issues, but compliance matters, as well. 

3) Exclusions from public support: Excess amounts from non-disqualified persons
In addition to disqualified persons, organizations may need to also exclude certain “excess amounts” received from those who are not considered disqualified persons. The exclusion applies to program revenues (not contribution income) that exceed the greater of $5,000 or 1% of the organization’s total support for the current tax year. Only the excess portion is excluded from public support. Further, it takes into account amounts that have been received on behalf of a program participant, not just amounts received directly (for example, a resident of a senior living facility whose fees are paid in whole or in part by Medicare, state funding, etc.) must also be included on a per-person basis for purposes of applying the test. 

Example: Calculating amounts received from non-disqualified persons 

Assume the 501(c)(3) organization is a senior living facility completing its Schedule A, Part III public support test. It serves approximately 100 residents.

• For purposes of the test, total support for the year is $5,000,000 
• 1% of total support is: $5,000,000 x 1% = $50,000 

Now consider two residents: 

• Resident A is a full-time private-pay resident and pays $85,000 for services rendered for the year.  
  • $35,000 ($85,000 – $50,000) is required to be excluded from the Schedule A, Part III public support test for Resident A 
• Resident B is covered by Medicare. Total revenues to the facility for the resident total $95,000. 
  • $45,000 ($95,000 – $50,000) is required to be excluded from the Schedule A, Part III public support test for Resident B

Organizations are encouraged to work with their tax advisors to maintain these internal lists supporting any amounts excluded. These lists are never filed as part of the Form 990 filing. 

4) No 10% facts-and-circumstances test
Finally, the Part III test does not have the 10% facts-and-circumstances (discussed in detail in our Part II article) to rely on if the public support percentage dips below 33.33%. 

What happens if you fail the test? 

Organizations are not locked into one test and can move between the Part II and Part III tests from year to year as long as the organization’s fact pattern supports the selection. That said, the test chosen should accurately reflect how the organization is structured and supported. 

Organizations that fail either or both of the Part II and Part III public support tests for two consecutive years statutorily lose their public charity status and automatically become a private foundation, subject to tax on net investment income and required to file Form 990-PF instead of Form 990.  

Note: This reclassification is retroactive to the beginning of Year 2, which can cause major disturbance for organizations, as well as potential donors (especially grant-makers). 

Key takeaways 

1. Know your revenue model: Are you an organization who primarily receives donations from multiple sources or do you operate under a fee‑for‑service model? The answer often determines whether Part II or Part III is a better fit. We also have an article that takes a deeper look at the Part II test. 
2. Watch for donor concentration: Large contributors, particularly those who may be disqualified people, can significantly reduce public support for purposes of the test. 
3. Monitor investment income carefully: Excessive passive income can cause an otherwise compliant organization to fail the test. 

If you have questions about which Schedule A public support test is the right fit for your organization—or if you’d like help working through the calculations—we’re always ready to support your needs. BerryDunn’s  team of professionals serves a range of nonprofit 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. 

Benjamin Franklin is attributed with having once said: “Nothing is certain but death and taxes.” While true, 501(c)(3) organizations, which are exempt from income taxes on activities related to their exempt purposes, could have a different spin on Ben Franklin’s classic line: “Nothing is certain but death, taxes, and Schedule A.” This is because any 501(c)(3) organization (or organization treated as such) claiming tax exemption as a public charity is required in one way, shape, or form to complete Schedule A. 

While at first glance the schedule seems easy enough, it is chock-full of nuances, potential limitations, and issues that can make or break a public charity’s tax-exempt status. To borrow from a somewhat less historical source, Avril Lavigne once observed, “Why’d you have to go and make things so complicated?”

This article is the first in a two-part series that provides a detailed examination of Form 990, Schedule A, offering practical guidance to the many organizations responsible for its complete and accurate preparation. Part one will focus on organizations that qualify under Part I, Line 7—509(a)(1) and the steps required to substantiate this classification through the Part II public support test.  

What is Schedule A? 

As noted above, Schedule A is required for all 501(c)(3) organizations claiming public charity status. Other tax-exempt organizations—such as 501(c)(2)s, 501(c)(4)s, 501(c)(5)s, and 501(c)(6)s—are not required to complete it. Additionally, 501(c)(3) private foundations are exempt from this requirement, as they file Form 990-PF instead.  

In simple terms, Schedule A lets the IRS confirm that an organization is truly supported by the public, which is what allows it to keep its public charity status. 

This determination begins in Schedule A, Part I, where an organization selects one of the IRS‑defined public charity categories listed on lines 1–12. Certain organizations, such as churches, schools, and hospitals, qualify automatically and are recognized as public charities without needing to demonstrate public support. 

For organizations that do not meet one of these automatic classifications, public charity status must instead be demonstrated through one of two IRS public support tests: 

• Organizations primarily supported by contributions generally rely on the Part II public support test 
• Organizations that earn most of their revenue from program service activities may qualify under the Part III public support test 

These two tests form the core framework through which many nonprofits establish and maintain public charity status. However, if an organization fails the applicable public support test for two consecutive years, it will automatically become a private foundation and face stricter rules and reporting requirements. Understanding these basics helps ensure your organization remains well‑positioned to maintain its public charity status and avoid surprises down the line. 

The basics: Understanding Schedule A, Part II 

Who qualifies? 

An organization qualifies as a public charity under Part II, over the five-year computation period, if it meets either of the following thresholds: 

• More than 33.33% of its total support is from governmental units, contributions from the general public, and contributions or grants from other public charities 
• More than 10% of its total support is from governmental units, contributions from the general public, and contributions or grants from other public charities, and the facts and circumstances indicate it is a publicly supported organization 

How is Part II different from Part III? 

1. Excess contributions 
A critical feature of the Part II public support test is how the IRS treats large contributions from a single donor. On Line 5, organizations must exclude the portion of a donor’s contributions that exceeds 2% of the organization’s total support over the five‑year computation period (the current year plus the four preceding years). 

This safeguard prevents an organization from appearing “publicly supported” merely because a few large donors provided most of its support. Instead, the Part II test is designed for organizations that maintain a diverse donor base, with many contributors giving smaller amounts rather than relying on a handful of major donors.  

It is important to recognize that certain types of support, such as contributions from governmental units or other publicly supported organizations qualifying under section 170(b)(1)(A)(vi), are not subject to exclusion under the 2% limitation rule. These sources are considered inherently public in nature and therefore always count fully toward public support, even when the amounts received are large.

Example: Calculating excess contributions 
Assume the organization has $4,000,000 in total support for the five‑year period. 

• The 2% limit is: $4,000,000 × 2% = $80,000

Now consider two donors: 

• Donor A contributes $50,000 → below the $80,000 limit 
  • None of Donor A’s contribution is an excess contribution. 
  • Full $50,000 counts as public support. 
• Donor B contributes $200,000 → above the limit 
  • Excess: $200,000 − $80,000 = $120,000 
  • Only $80,000 counts toward public support. 
  • The $120,000 excess must be reported on Line 5 and excluded from the numerator. 

Although large donations are beneficial for operations, they can hurt public support percentages if they are concentrated in a few donors. 

Key takeaway: For organizations completing the Part II test, it is essential to stay vigilant around donor concentration throughout the five-year period to ensure that the organization is not receiving the majority of their support from just a few donors. 

2. Treatment of unusual grants 
Another nuance to the Schedule A, Part II test is the treatment of unusual grants. Unusual grants are large, unexpected contributions from disinterested parties that would skew an organization’s public support percentage if treated as regular support. Because these gifts are extraordinary in size and could jeopardize an organization’s ability to meet the 33.33% public support test or the 10% facts‑and‑circumstances test, they are excluded entirely from both the numerator and denominator of the Part II calculation. This allows organizations to accept significant one‑time gifts without risking “tipping” into private‑foundation status. Organizations must report the amount only in Schedule A, Part VI, and keep internal records documenting the donor, date, and why the grant qualifies as unusual.

3. The 10% facts‑and‑circumstances test
For organizations completing Schedule A, Part II, the 10% facts‑and‑circumstances test provides a backup option for demonstrating public charity status if they fall short of the standard public support requirement. If an organization does not meet the 33.33% public support requirement under Part II, it may still qualify as a public charity as long as it still receives at least 10% public support and it can demonstrate that it truly operates for the benefit of the community.  

The IRS considers a variety of factors to determine whether an organization still functions as a public charity. This includes whether it actively fundraises from the general public, whether its board of directors reflects the community it serves, and whether its programs, services, and facilities are open and easily accessible to the general public. The IRS also looks at whether the organization receives grants or support from government agencies, which reinforces that it operates for the general public and not private benefit. 

This backup rule helps organizations maintain public charity status during years when donation patterns fluctuate—for example, when a large gift temporarily skews the support ratio or when a newer organization is still building its donor base. With good records and a clear explanation of how it serves the public, many organizations can rely on this test when their support dips below the standard threshold. 

4. The Schedule B “special rule” 
Organizations that complete and pass the Schedule A, Part II support test may also qualify for the “special rule” related to donor disclosure on Form 990, Schedule B. Under the general Schedule B rules, organizations must report any donor who contributed $5,000 or more during the year, including the donor’s name and address. However, organizations that complete and pass the Part II support test are only required to disclose donors whose contributions exceed 2% of the organization’s total contribution income for the year. This higher disclosure threshold can significantly reduce the Schedule B reporting burden, particularly for organizations that receive a substantial portion of their revenue from individual contributions. 

Pro tip: Certain organizations (namely, colleges and universities) can opt to complete the Schedule A, Part II support test in order to take advantage of this special rule as well. For additional information, please see the article, Easy ‘A’ for schools: Pass the test to reduce requirements under Schedule B. 

Now that we’ve covered how Schedule A, Part II measures public support based largely on contributions, the next step is understanding the alternative approach. In the second article in our series, we’ll explore Schedule A, Part III, which is often a better match for organizations supported primarily through program services and fees. 

We can help

BerryDunn’s team of professionals serves a range of nonprofit 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 NFPs fulfill their missions. Learn more about our team and services. 

Read this article if your role includes hiring, contracting, or credentialing licensed healthcare providers, healthcare professionals, and support staff across the healthcare spectrum, as well as those who work with interim staffing, locum agencies, and third-party healthcare vendors and suppliers. 

Exclusion screening is one of those healthcare requirements that can feel routine—until it isn’t. An essential element of credentialing, it is the process of regularly checking whether individuals or entities that are connected to your organization appear on federal exclusion lists, created and maintained by the US Department of Health & Human Services Office of the Inspector General (OIG) and the System for Award Management (SAM). Individuals or entities on the list may be prohibited from participating in federally funded healthcare programs. When a match is overlooked, the consequences can lead to financial, legal, operational, and reputational risk for an organization.

The challenges of exclusion screening 

Even the best-run organizations might let exclusion screening fall through the cracks—particularly when it is treated as a one-time onboarding step instead of a recurring monitoring process. From limited staffing to competing priorities across credentialing, compliance, medical staff offices, human resources, and operations, it’s a crucial task that needs to be owned by someone in the organization to help ensure it happens routinely. 

The consequences of missing an exclusion 

If your organization employs or contracts with an excluded individual or entity, the risk can extend well beyond initial oversight. Potential consequences may include significant civil monetary penalties, overpayment liability, required corrective actions, and reputational damage. More importantly, exclusions often relate to serious underlying issues such as healthcare fraud, patient abuse or neglect, licensing problems, financial crimes, or drug-related violations, which means missing a listing can undermine patient safety and trust. 

While most professionals act in good faith, you can’t rely on individuals or entities to self-disclose their exclusion status. In some cases, individuals might not disclose because they need the job, don’t fully understand their status, or the exclusion happened after they were screened at the point of hire.  

Ongoing exclusion screening is key 

Exclusion screening isn’t a “set it and forget it” compliance regulation. Even if there are no findings today, that does not guarantee a clean result next month. A status can change, new records could be added, or there could be a delay in reporting. That’s why it’s essential for healthcare organizations to treat exclusion training as an ongoing monitoring commitment and have a clear process for reviewing results and flagging potential findings. 

Practical guidance for exclusion screening  

• Be proactive: Understand the regulations that apply to your organization.  
• Define ownership: Assign exclusion screening oversight responsibilities to a specific role or team—and ensure there is a backup so the process happens even when someone is out.  
• Develop an internal process: Identify what cadence (monthly is recommended), which databases you check (i.e., OIG, SAM), and how to document results.  
• Use strong identifiers: Collect and maintain the necessary information to reduce false positives and confirm accurate matches.  
• Create a plan: Define a clear process for how you’ll handle a potential match, including who needs to be involved (compliance, HR, etc.) and how to investigate. 

Don’t underestimate the importance of exclusion screening or the potential consequences of missing excluded or sanctioned individuals or entities.

BerryDunn can help with exclusion screening 

Recognize when it’s time to seek help. If your team is stretched, unsure of how consistently you are screening, or investing too much time in investigating potential matches, it may be time to bring in help. 

BerryDunn’s credentialing professionals are adept at navigating the challenges providers face. As an organization certified by NCQA in Credentialing (CR) across all 11 credentialing elements, we help clients streamline processes with strict adherence to compliance and regulatory standards. We equip organizations with resources to manage credentialing and compliance risks by performing continuous monitoring of federal exclusion lists. These monitoring activities help our clients comply with federal mandates prohibiting healthcare organizations from hiring or doing business with excluded or sanctioned individuals or entities. Learn more about our team and services.