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This article is the first in a series to help employee benefit plan fiduciaries better understand their responsibilities and manage the risks of non-compliance with ERISA requirements.

Reading through the 133-page exposure draft for the Proposed Statement on Auditing Standards (SAS) Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, issued back in April 2017, and then comparing it to the final 100+ page standard approved in September 2018, may not sound like a fun way to spend a Sunday morning sipping a coffee (or three), but I disagree.

Read this if you are a not-for-profit organization. 

Due to the impacts of COVID-19, on June 3, 2020, FASB issued an Accounting Standards Update (ASU) that granted a one-year effective date delay for NFPs to adopt the new revenue recognition standards (Topic 606). The ASU permitted NFPs that had not yet applied the revenue recognition standard to do so for annual reporting periods beginning after December 15, 2019. Many NFP’s choose to take advantage of this delay. 

However, the clock is ticking on FASB’s revenue recognition changes, as most NFP’s will have to adopt the revenue recognition changes shortly. With that in mind – let’s revisit Topic 606 and what it could mean for your organization. 

The overarching goal of the changes to revenue recognition is to converge disparate standards across industries, all while making the information more useful to users. The core principle of the standard is that “the organization should recognize revenue to depict the transfer of goods or service in an amount that reflects the payment for which the organization expects to be entitled for those goods and services.” 

A five-step process and a simplified approach 

To achieve that core principle, your organization will need to apply a five-step model to some of your revenues streams:

  1. Identify the contract(s) with a customer
  2. Identify the separate performance obligations
  3. Determine the transaction price
  4. Allocate the transaction price to the separate performance obligations
  5. Recognize revenue when or as a performance obligation is satisfied

While the process can be broken down into five simple steps, the task of reviewing revenue streams and specific contracts can be quite daunting in implementation.

Additional disclosures needed

Whether your organization is currently implementing, or soon will, you will want to make sure you understand the extensive disclosures required under the standards. Annual disclosures include the following:

  • Qualitative information about how economic factors affect the nature, amount, timing, and uncertainty of revenue and cash flow
  • Opening and closing balances of contract assets, contract liabilities, and receivables from contracts with customers
  • Descriptions of performance obligations

We are here to help

We recognize the difficult task ahead for our clients in analyzing their multiple contract vehicles and revenue streams in implementing the new standards. To help our clients through the process, we are offering revenue standard workshops. This workshop can be tailored to your needs, with an in-depth meeting to review the standard, consider your significant revenue streams, and a walkthrough the five-step process. We will leave you with an easy to use template for analyzing future revenue streams along with recommendations for your current revenue recognition system and process. 

Don’t wait until the financial year has come to a close to review your processes and systems in place, we are available now to work with you to prepare for the new standard. Contact Chris Mouradian or Sarah Belliveau to find out how you can join the list of organizations getting ahead of the new standard.

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Financial Accounting Standards Board (FASB) revenue recognition changes: What it means for NFPs

Read this if your company uses QuickBooks Online.

QuickBooks Online offers numerous ways to help you track your sales, expenses, and profitability. If you’re using QuickBooks Online Plus or Advanced, you can create and assign Classes to transactions to differentiate between, for example, store departments or product lines. Some of the site’s reports are designed specifically for these tools, like sales by class and profit and loss by class. 
 
You can assign categories to products and services to gain insight into your sales and inventory. There’s a different set of categories that you’ll use when you record bills and expenses. These are important for reporting and tax purposes. You can also add a location field to sales transactions so you can track sales by stores, sales regions, or counties, for example.

What are tags and how do you use them?

Tags are fairly new to QuickBooks Online. They are customizable labels you can assign to transactions (invoices, expenses, and bills). They’re more flexible than the tools we’ve already mentioned—they allow you to track your money any way you want. They don’t affect your books, and they’re not included in the customization criteria for reports. But there are two reports specifically designed for them: profit and loss by tag group and transaction list by tag group.

Creating your own tags

Before you create a tag, you need to create a group. Groups consist of related tags that share a common theme. For example, say you do some event planning. You might have a group titled events. Individual events might read, for example, Grayson Wedding, Spring Art Show, and Hillman Conference.

To get started, click the gear icon in the upper right. Under lists, click tags to get to the tool’s home page. (You can also click on the transactions link in the toolbar, then click the tags tab.) Click new, then tag group. A vertical panel slides out from the right. Enter a name in the group name field. Click the down arrow to select a color, then click save. 

Enter your tags one by one in the fields labeled tag name. Click add after each one until your list is complete. Click the edit button to make any changes. When you’re finished, click done. The main tags page will open again, and you’ll see your new group under tags and tag groups. Repeat to add as many as you’d like, up to 300 tags.

Making the most of the tags in QuickBooks Online

 

You can add tags to any transaction that contains a field for them

Let’s look at how you’d use tags in an expense. Click the expenses link in the toolbar, then new transaction | expense in the upper right. Click the down arrow in the payee field in the upper left and select + add new. Enter Billy’s Bridal in the name field. Leave the type as vendor and click save. Back on the expense screen, select the payment account, payment date, and payment method for the expense (reference number is optional).

Directly below those fields, you’ll see the tags field. Click manage tags if you need to add or edit one; the right vertical pane you saw before will slide out. Otherwise, click in the field below tags. Your list of tags will drop down. Select Grayson Wedding to move it into the field. You can assign as many tags as you’d like to transactions, but you can only select one tag from each group. Finish the expense and save it. 

Go back to the tags home page, and you’ll see that there’s a link to one transaction in the events row. At the end of each row is the action column, where you can run a report, add a tag, and enter or delete a group. Your expense total appears in the money out (by tag) box above it. 

Tags are a great addition to the tools QuickBooks Online provides to help you track incoming and outgoing funds. If you’re not familiar with the others mentioned at the beginning of this column and want to learn how to explore them, let us know. We're here to help.

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Tag, you're it: Making the most out of QuickBooks Online tags

Read this if you are an employer with a defined contribution plan.

This article is the fourth in a series to help employee benefit plan fiduciaries better understand their responsibilities and manage the risks of non-compliance with Employee Retirement Income Security Act (ERISA) requirements. You can read the previous articles here.

One of the most common errors we identify during an audit of defined contribution plans is the definition of compensation outlined in the adoption agreement or plan document is not consistently or accurately applied by the plan sponsor. This can be a serious problem, as operational failures will require correction and those errors can become costly for plan sponsors. 

Calculation challenges and other common errors

It is important plan sponsors understand the options selected for the calculation of employee elective deferrals and employer non-elective and matching contributions into the plan. While calculating compensation sounds straightforward, it is often complicated by the fact that your adoption agreement or plan document may use different definitions of compensation for different purposes.

For example, the definition of compensation used to calculate deferrals could differ from the definition used for nondiscrimination testing and allocation purposes. Therefore, determining the correct amount of compensation requires a strong understanding of both your entity’s payroll structure and adoption agreement or plan document. Plan sponsors should work with both in-house personnel and plan administrators to ensure definitions of compensation are appropriately applied, and that any changes are quickly communicated to all involved.  

During an audit, we commonly identify pay types excluded from the definition of compensation in the adoption agreement or plan document that are incorrectly included in the compensation used in the calculation of employee deferrals and employer contributions. Taxable group term life insurance is a common example of compensation that is improperly included in the definition of compensation. Alternatively, we also identify codes for certain types of pay excluded from the calculation of employee deferrals and employer contributions that should be included based on the applicable definition of compensation. For example, retro pay, bonus payments, and manual checks are often incorrectly excluded in the definition of compensation.

Corrective actions

If errors are identified, we recommend that corrective actions including contributions, reallocation, or distributions are made in accordance with the Department of Labor regulations in a timely fashion.

If appropriate, the plan sponsor should consider amending the plan to align with the definition of plan compensation currently used in practice. We also recommend plan sponsors perform annual reviews of plan operations to ensure compliance and avoid the costs that can accompany non-compliance.

If you have questions about your specific situation, please contact our Employee Benefits consulting team. We’re here to help.

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Plan compensation and contributions: Common errors and solutions to fix them

Read this if you are a renewable energy developer, installer, or investor.

Renewable energy has what amounts to an 18-month opportunity to make major strides before the mid-term elections. During the mid-terms, all 435 seats in the United States House of Representatives and 34 of the 100 seats in the United States Senate will be contested. Thirty-nine state and territorial gubernatorial and numerous other state and local elections will also be contested. Until then, a slim majority in both the House of Representatives and the Senate looks to be favorable for the renewable energy sector. 

The Biden administration’s proposed American Jobs Plan would eliminate tax benefits for fossil fuel companies, increase the corporate income tax, and promote renewable energy investment and jobs. How does an increase in the corporate tax rate create opportunities for renewable energy? If corporations have more tax liability they’ll be more likely to invest in projects that provide investment tax credits.  

Of particular interest to the team at Berry Dunn is the proposed ten-year extension and phase down of an expanded direct-pay investment tax credit (ITC) and production tax credit (PTC) for clean energy generation and storage. While details are sparse, direct-pay sure sounds a lot like the very successful 1603 grant program that was part of the 2009 stimulus package. Direct-pay eliminates a lot of the inefficiencies and tax hoops of the flip structure now often deployed to monetize the ITC. This allows developers to benefit directly instead of having to bring in tax equity investors. The inclusion of storage is welcome as it is now a part of most renewable energy projects and is critical in overcoming the non-intermittent power arguments that the fossil fuel industry uses to differentiate themselves from renewable energy companies. 

While there is a lot of negotiation and arm wrestling ahead to turn some or all of this into law, we encourage our renewable energy clients to line up projects and employees to be ready to pounce as this opportunity could be around for a short period. Hopefully the focus on American jobs and manufacturing will give it staying power, but don’t underestimate the political power of the fossil fuel industry. Now is the time.

The American Jobs Plan Fact Sheet

Below are some of the highlights from the fact sheet that pertain to renewable energy and clean electricity. You can read the full fact sheet posted on The White House's website here

  • Reenergize America’s power infrastructure. As the recent Texas power outages demonstrated, our aging electric grid needs urgent modernization. A DOE study found that power outages cost the U.S. economy up to $70 billion annually. The President’s plan will create a more resilient grid, lower energy bills for middle class Americans, improve air quality and public health outcomes, and create good jobs, with a choice to join a union, on the path to achieving 100 percent carbon-free electricity by 2035. President Biden is calling on Congress to invest $100 billion to:
  • Build a more resilient electric transmission system. Through investments in the grid, we can move cheaper, cleaner electricity to where it is needed most. This starts with the creation of a targeted investment tax credit that incentivizes the buildout of at least 20 gigawatts of high-voltage capacity power lines and mobilizes tens of billions in private capital off the sidelines right away. In addition, President Biden’s plan will establish a new Grid Deployment Authority at the Department of Energy that allows for better leverage of existing rights-of-way—along roads and railways—and supports creative financing tools to spur additional high priority, high-voltage transmission lines. These efforts will create good-paying jobs for union laborers, line workers, and electricians, in addition to creating demand for American-made building materials and parts.
  • Spur jobs modernizing power generation and delivering clean electricity. President Biden is proposing a ten-year extension and phase down of an expanded direct-pay investment tax credit and production tax credit for clean energy generation and storage. These credits will be paired with strong labor standards to ensure the jobs created are good-quality jobs with a free and fair choice to join a union and bargain collectively. President Biden’s plan will mobilize private investment to modernize our power sector. It also will support state, local, and tribal governments choosing to accelerate this modernization through complementary policies—like clean energy block grants that can be used to support clean energy, worker empowerment, and environmental justice. 

    President Biden will establish an Energy Efficiency and Clean Electricity Standard (EECES) aimed at cutting electricity bills and electricity pollution, increasing competition in the market, incentivizing more efficient use of existing infrastructure, and continuing to leverage the carbon pollution-free energy provided by existing sources like nuclear and hydropower. All of this will be done while moving toward 100 percent carbon-pollution free power by 2035.
  • Build next generation industries in distressed communities. President Biden believes that the market-based shift toward clean energy presents enormous opportunities for the development of new markets and new industries. Jumpstart clean energy manufacturing through federal procurement. The federal government spends more than a half-a-trillion dollars buying goods and services each year. This incredible purchasing power can be used to drive innovation and clean energy production. The President is calling on Congress to enable the manufacture of electric vehicles, charging ports, electric heat pumps, and clean materials, as well as critical technologies like advanced nuclear reactors and fuel, here at home through a $46 billion investment in federal buying power, creating good-paying jobs and reinvigorating local economies, especially in rural areas.
  • Create good jobs electrifying vehicles. The President is proposing a $174 billion investment to win the EV market. His plan will enable automakers to spur domestic supply chains from raw materials to parts, retool factories to compete globally, and support American workers to make batteries and EVs. 
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Now is the time: Renewable energy opportunities before mid-term elections

Read this if you are at a state Medicaid agency.

In early March 2021, the Biden administration passed the American Rescue Plan of 2021 (H.R.1319) with the primary goal of providing emergency supplemental funding for the ongoing response to the COVID-19 pandemic. Importantly, in addition to vaccines, unemployment, and other critical developments, the plan provided a number of Medicaid opportunities for states that expand eligibility and coverage, including the following:

  • Funding increases—a new incentive to expand Medicaid eligibility through a two-year, 5% increase in the state’s base Federal Medical Assistance Percentage (FMAP).
  • Coverage—the option to extend Medicaid coverage for women up to 12 months postpartum and with full Medicaid benefits.
  • System transformation—a one-year, time-limited FMAP increase of 7.35% for states to make improvements and rate increases to Medicaid home-and-community-based services (HCBS).
  • Waiver opportunities—a new incentive (enhanced FMAP for five years through bundled payments) for state Medicaid programs’ mobile crisis intervention services for individuals experiencing a mental health or substance use disorder crisis via a state plan amendment (SPA) or 1115 waiver demonstration.

What’s next?

It seems likely that the American Rescue Plan’s Medicaid provisions signal upcoming changes and opportunities for healthcare transformation for state Medicaid programs. The administration has consistently articulated a desire to “strengthen Medicaid” and while additional legislative actions are likely coming, there are also legislative limitations that may limit or curtail the type of broad reform we’ve seen in the past. As a result, it’s likely that the vehicle the administration will use to disseminate healthcare transformation in Medicaid are administrative actions such as executive orders, regulations, and administrative rule-making through the Centers for Medicaid and Medicare Services (CMS). This is likely to result in opportunities in two areas: waivers and the funding incentives to adopt new policies.

Waivers

The best tool the administration has is also one of its oldest: demonstration waivers. As noted above, the American Rescue Plan of 2021 includes the option for states to take advantage of waivers (as well as SPAs) to exercise new flexibilities. Unlike the Affordable Care Act (ACA) which was rolled out nationally, it’s likely the administration will seek out volunteer states that are innovative and willing to collaborate. The result will be more experimentation, more tailoring of policy, and a more gradual—even organic—approach to transformation.

In the short term for state Medicaid agencies this will mean a rebalancing of pending waivers and guidance. Prior policy priorities like work requirements and aggregate enrollment caps may be revised through the regulatory process in coming months or years. It is anticipated that CMS will execute a vision with a renewed focus on expanding services or coverage, much like those seen with the opportunities already presented under the American Rescue Plan.

Funding

Budget is a consistent challenge states have faced over the past year resulting largely from the COVID-19 pandemic. Even with recent aid to states and local governments there is likely to be uncertainty for the immediate future. The American Rescue Plan, like the ACA before it, finds mechanisms and incentives to raise the FMAP for states and potentially ease the state’s portion of Medicaid funding, particularly in the short term. Fitting with the theme of states as active partners, going forward there will likely be opportunities to maintain some type of increase to the FMAP. Beyond direct funding, opportunities like the recent CMS guidance on social determinants of heath, value-based payments, and models like the Community Health Access and Rural Transformation (CHART) hint at a continued focus on payment reform. States looking to lower costs and/or increase the quality of care will have ample opportunities to undertake projects in these areas.

State considerations

Regardless of next steps, states should expect both compliance needs and opportunities. States should begin to consider strategy, resources, and their priorities now. This process begins with knowing your agency’s strengths and potential limitations. Once states set their policy priorities and are ready to get underway with the business of transformation, time and resource constraints will likely be common barriers. Having a mature, flexible, and capable project management office, the right subject matter knowledge, and prequalified vendor lists to assist with Medicaid transformation can go a long way towards addressing time and resource constraints—making state Medicaid agencies agile in their response to the unique opportunities in the coming years.

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What's past is prologue: How the American Rescue Plan shows us what's next for Medicaid