Skip to Main Content

insightsarticles

COVID-
19 and the e-commerce explosion

05.13.21

Read this if you work in an alcohol control capacity for state government.

The COVID-19 outbreak has changed the alcoholic beverage industry significantly over the last 14 months. Restrictions forced people to stay at home, limiting their travel to restaurants, bars, and even some stores to purchase their favorite spirits. In at least 32 states, new legislation allowed consumers the option to buy to-go cocktails as a way to help these establishments stay in business. As a result, consumers took advantage of alcohol delivery services. 

There were two large shifts in consumer purchasing for the alcoholic beverage industry in 2020. The first was a shift from on-premise to off-premise purchasing (for example, more takeaway beverages from bars, breweries, and other establishments). The second was the explosion of e-commerce sales for curbside pickup and home delivery. A study by IWSR, an alcoholic beverage market research firm, stated that alcohol e-commerce sales grew 42% in 2020. The head of consumer insights for the online alcoholic beverage delivery service, Drizly, attributes this growth to the “increased consumer awareness of alcohol delivery as a legal option, as well as an overall shift in consumer purchasing behavior toward online ordering and delivery”. 

How state agencies responded

The move to an e-commerce model has impacted state agencies who regulate the distribution and/or sale of alcohol. States such as Oklahoma, Alabama, and Georgia recently passed legislation allowing alcohol delivery to consumers’ homes. In alcoholic beverage control states, where the state controls the sale of alcohol at the wholesale level, curbside pickup programs (New Hampshire) were implemented, while others started online home delivery services (Pennsylvania). 

In a fluid legislative environment, states agencies are working to meet consumer needs in a very competitive marketplace, while fulfilling their regulatory obligation to the health and safety of their constituents.

How alcoholic beverage control states can adapt

Now is an opportune time for control state agencies to keep pace with consumer demand for more flexible purchasing options, such as buying online with home delivery, or some form of curbside and/or in-store pickup programs. Every one of the 17 alcoholic beverage control states has passed legislation to allow the delivery of either beer, wine, and/or distilled spirits in some form, with some limitations.

While for some the COVID-19 outbreak has necessitated these more distant shopping experiences, the option of these sales channels has brought consumers flexibility they will expect going forward. This calls for control state agencies to act on this changing consumer demand. By prioritizing investing in and taking ownership of new sales channels, such as e-commerce and curbside pickup, control state agencies’ technology and logistics teams can develop strategies and tools to effectively adapt to this new demand. 

Adapting technology and logistics

Through technology, control state agencies can take advantage of e-commerce and curbside pickup sales channels, to drive more revenue. We recommend control states consider the following: 

Define the current capabilities to support an online sales strategy

An important first step is to define how to address constituents’ evolving needs as compared to the current e-commerce capabilities control state agencies can support. Considerations include:

  • Are current staff capable of developing and supporting new website capabilities to meet the increased demand on the website?  
  • How will the current customer support team(s) expand to support concerns from the new channels?
  • How will new e-commerce order volume be fulfilled for home delivery (including order errors, breakage, returns, etc.)?   

Control state agencies should complete current and future state assessments in each area above to confirm what capabilities they have today and which they would like to have in the future; which will allow for an accurate gap analysis and comparison to their future state needs. Once the current state assessment, future state strategy, and gap analysis are complete, control state agencies can define the projects required to support the future state requirements. 

Reevaluate existing fulfillment, inventory, and distribution processes

Each control state has existing product fulfillment, inventory and distribution processes, and information technology (IT) tools for delivering alcohol, to their own or licensed retail stores and businesses. These current processes and IT systems should be assessed as part of the current state capabilities assessment mentioned above, to help define the level of change needed to support the control state agency’s future needs in the e-commerce channel. Key assessment questions control state agencies should ask themselves include: 

  • Can the current IT systems (e.g., inventory management, customer relationship management [CRM], customer support/call center, financial, point of sale [POS], and website infrastructure) support required upgrades?
  • Can retail teams and today’s infrastructure support order taking, inventory, fulfillment, and buy online pickup in store programs?
  • How will warehouse and retail stores track and manage the e-commerce shipments and returns related to this channel?
  • If home delivery is part of the strategy, define how the delivery logistics will be met through state or vendor resources.
  • What staffing model and skill sets will support future business needs?
  • What is the total cost of ownership for these new e-commerce capabilities so that the short and long-term costs and profits can be accurately estimated? 

The answers to these questions will help to inform a future e-commerce strategy and accommodate the cost and staff impacts. 

Bring in online retail expertise

It is important to ensure that the control state agency has website and mobile capabilities to support today’s consumer needs. This includes the ability to order a wide range of products online for either home delivery or buy online pickup in store. The design of the website and mobile transactional capabilities is critically important to the success of this channel, the true growth in revenues. Being marketing focused (e.g., allowing consumers to view and order products, save items for later, and see similar products) will help drive traffic and sales on this upgraded channel. 

For control state agencies with a more static product website, consider purchasing a commercial off-the-shelf (COTS) e-commerce product with existing retail-focused website features, or contract with a vendor to build a website that meets more unique needs. The control state agency should bring in at least one online retail subject matter expert vendor to help set the direction, design the upgrades or new site, manage the project(s) needed to implement the online capabilities, and potentially manage the operational support of the website and mobile solution.

BerryDunn provides state alcoholic beverage control boards and commissions with many services along the IT system acquisition lifecycle, including planning, needs assessment, business process analysis, request for proposal (RFP) development, requirements development, technology contract development, and project management services. 

For the full list of steps to consider and to learn more about how you can successfully position your control state agency to adapt to the changing alcoholic beverage landscape, contact us.
 

Related Industries

Related Professionals

Principals

BerryDunn experts and consultants

Read this if you are a community bank.

The Federal Deposit Insurance Corporation (FDIC) recently issued its second quarter 2021 Quarterly Banking Profile. The report provides financial information based on Call Reports filed by 4,951 FDIC-insured commercial banks and savings institutions. The report also contains a section specific to community bank performance. In second quarter 2021, this section included the financial information of 4,490 FDIC-insured community banks. BerryDunn’s key takeaways from the community bank section of the report are as follows:

  • There was a $1.9 billion increase in quarterly net income from a year prior despite continued net interest margin (NIM) compression. This increase was mainly due to higher net interest income and lower provision expenses. Net interest income had increased $1.4 billion due to 1) lower interest expense, 2) higher commercial and industrial (C&I) loan interest income, and 3) loan fees earned through the payoff and forgiveness of Paycheck Protection Program (PPP) loans. Provision expense decreased $2.3 billion from second quarter 2020. However, it remained positive at $46.1 million. For non-community banks, provision expense was negative $10.8 billion for second quarter 2021.
  • Quarterly NIM declined 26 basis points from second quarter 2020 to 3.25%. The average yield on earning assets fell 57 basis points to 3.57% while the average funding cost fell 31 basis points to 0.32%. Both of which are record lows.
  • Net operating revenue (net interest income plus non-interest income) increased by $1.6 billion from second quarter 2020, a 6.5% increase. This increase is attributable to higher revenue from service charges on deposit accounts (increased $134.8 million, or 23.5%, during the year ending second quarter 2021) and an increase in “all other noninterest income,” including, but not limited to, bankcard and credit card interchange fees, income and fees from wire transfers, and income and fees from automated teller machines (up $203.6 million, or 9.3%, during the year ending second quarter 2021).
  • Non-interest expense increased 7.8% from second quarter 2020. This increase was mainly attributable to salary and benefit expenses, which saw an increase of $688.2 million (7.8%). That being said, average assets per employee increased 8.4% from second quarter 2020. Non-interest expense as a percentage of average assets declined 18 basis points from second quarter 2020.
  • Noncurrent loan balances (loans 90 days or more past due or in nonaccrual status) declined by $894.6 million, or 7.1%, from first quarter 2021. The noncurrent rate improved 5 basis points to 0.68% from first quarter 2021.
  • The coverage ratio (allowance for loan and lease losses as a percentage of loans that are 90 days or more past due or in nonaccrual status) increased 39.8 percentage points year-over-year to 191.7%, a record high, due to declines in noncurrent loans. This ratio is well above the financial crisis average of 64.5%. The coverage ratio for community banks is 15.4 percentage points above the coverage ratio for non-community banks.
  • Eighty-eight community banks had adopted current expected credit loss (CECL) accounting as of second quarter. Community bank CECL adopters reported negative provision expense of $208.3 million in the second quarter compared to positive $254.5 million for community banks that have not yet adopted CECL.
  • Net charge-offs declined 8 basis points from second quarter 2020 to 0.05%. The net charge-off rate for consumer loans declined most among major loan categories, having decreased 51 basis points.
  • Trends in loans and leases showed a slight decrease from first quarter 2021, decreasing by 0.5%. This decrease was mainly seen in the C&I loan category, which was driven by a $38.3 billion decrease in PPP loan balances. The decrease in PPP loans was driven by the payoff and forgiveness of such loans. Despite the decrease in loans quarter-over-quarter, total loans and leases increased by $5.7 billion (0.3%) from second quarter 2020. The majority of growth was seen in commercial real estate portfolios (up $61.7 billion, or 8.9%), which helped to offset the decline in C&I, agricultural production, and 1-4 family mortgage loans during the year.
  • Two-thirds of community banks reported an increase in deposit volume during the second quarter. Growth in deposits above the insurance limit, $250,000, increased by $47.8 billion, or 4.7%, while alternative funding sources, such as brokered deposits, declined by $3.8 billion, or 6.7%, from first quarter 2021. 
  • The average community bank leverage ratio (CBLR) for the 1,789 banks that elected to use the CBLR framework was 11%.
  • The number of community banks declined by 38 to 4,490 from first quarter 2021. This change includes two new community banks, 12 banks transitioning from community to non-community banks, one bank transitioning from non-community to community bank, 27 community bank mergers or consolidations, and two community bank self-liquidations.

Second quarter 2021 was another strong quarter for community banks, as evidenced by the increase in year-over-year quarterly net income of 28.7% ($1.9 billion). However, tightening NIMs will force community banks to find creative ways to increase their NIM, grow their earning asset bases, or find ways to continue to increase non-interest income to maintain current net income levels. Some community banks have already started dedicating more time to non-traditional income streams, as evidenced by a 4.3% year-over-year increase in quarterly non-interest income. The importance of the efficiency ratio (non-interest expense as a percentage of total revenue) is also magnified as community banks attempt to manage their non-interest expenses in light of declining NIMs. Banks appear to be strongly focusing on non-interest expense management, as seen by the 18 basis point decline from second quarter 2020 in non-interest expense as a percentage of average assets, although inflated balance sheets may have something to do with the decrease in the percentage.

Furthermore, much uncertainty still exists. For instance, although significant charge-offs have not yet materialized, the financial picture for many borrowers remains uncertain. And, payment deferrals have made some credit quality indicators, such as past due status, less reliable. Payment deferrals for many borrowers are coming to a halt. So, the true financial picture of these borrowers may start to come into focus. The ability of community banks to maintain relationships with their borrowers and remain apprised of the results of their borrowers’ operations has never been more important. This monitoring will become increasingly important as we transition into a post-pandemic economy. For seasonal borrowers, current indications, such as the most recent results from the Federal Reserve’s Beige Book, show that economic activity was relatively strong over the summer of 2021. However, supply chain pressures and labor shortages could put a damper on the uptick in economic activity for these borrowers, making a successful transition into the “off-season” months that much more important. 

Also, as offices start to open, employers will start to reassess their office needs. Many employers have either created or revised remote working policies due to changing employee behavior. If remote working schedules persist, whether it be full-time or hybrid, the demand for office space may decline, causing instability for commercial real estate borrowers. Recent inflation concerns have also created uncertainty surrounding future Federal Reserve monetary policy. If an increase in the federal funds target rate is used to combat inflation, community banks could see their NIMs in another transitory stage.

As always, please don’t hesitate to reach out to BerryDunn’s Financial Services team if you have any questions.

Article
FDIC Issues its Second Quarter 2021 Quarterly Banking Profile

Read this if you are at a financial institution that uses FedLine® Solutions.

In response to an evolving security threat landscape, the Federal Reserve Bank has implemented a Security and Resiliency Assurance Program (“Assurance Program”). Financial institutions that use FedLine® Solutions will need to take action before year-end to comply with Assurance Program requirements. Here’s what you need to know.

Required assessment to be completed annually

Financial institutions are already required to implement, maintain, and assess technical and procedural security controls to safeguard their FedLine® connections. Starting in 2021, financial institutions must conduct an assessment of their compliance with the Federal Reserve Bank's FedLine® security requirements and submit an attestation that they have completed the assessment. The deadline for submitting the first attestation is December 31, 2021. Moving forward, this assessment and attestation must be completed annually.

This assessment can be performed internally by an independent internal department/function such as an internal audit or compliance department. The Federal Reserve Bank may, in its discretion, require the assessment be conducted or reviewed by an independent third party. End User Authorization Contacts (EUAC) for each organization were sent an Assurance Program kick-off packet with requirements and instructions in January 2021 to assist with the process. 

Immediate action 

Evaluate the requirements for your financial institution’s Assurance Program assessment as soon as possible. Planning for the 2021 assessment should be well underway. If you would like to discuss the Assurance Program requirements or you’ve been notified that your financial institution needs an independent third party review, contact us today.

Article
The Federal Reserve's FedLine® Solutions Security and Resiliency Assurance Program

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer.

Hurray! The in-person Medicaid Enterprise Systems Conference (MESC) was successfully held! It was a wonderful and true reunion for all those who attended the conference in Boston this year. Hats off to MESC’s sponsoring organization, NESCSO, for holding a hybrid in-person/virtual event. Although there were some minor technological glitches at the start, MESC went very smoothly. The curriculum, good planning, and hard work prevailed and led to a very successful conference.

Before highlighting the session content and conference themes, I must mention what first occurred upon arrival: We were able to greet our colleagues, partners, and vendor teams. How wonderful it was to be together with some colleagues who I had not seen for over two years! We all had stories and pictures that video conferencing just can’t convey, and being able to share them, face-fo-face (and tear-to-tear), was the highlight for me. Who cried when Shivane Pratap and Laura Licata played cello and violin Bach pieces for us? That would be me. 

Our Medicaid Practice Group team was not able to get to our agendas until checking in with each other. The joy of seeing people, hugging people, shaking hands, or bumping elbows or fists underscored the value of being able to utilize all our senses when we meet with people—after all, we are in a people industry, and it was amazing to see the care we have for each other, and it was a reminder that that care is the foundation of what we strive to deliver to the Medicaid population each and every day through our work.

What an amazing 18 months we’ve been through—hearing that the Medicaid population is now over 80 million, and that it exceeds the Medicare population is hard to fathom, and this means that the Medicaid population is 25% of our overall population, and Medicaid and Medicare populations combined are half of our population. I think the growth in Medicaid of 10 million members in just a few years is a reflection of the pandemic and hardships our nation is currently enduring.

In the midst of the loss endured as COVID-19 waves continue to seep through this world, we have accomplished much. I’m not sure if these gains seem bigger because it’s been two years since we last gathered, the appreciation of being able to get anything accomplished other than respond to the pandemic, or maybe we really have hit our goals out of the ballpark (most likely a mixture of all three).

Significant achievements of the past two years

Items of significant accomplishment and change since our last MESC in-person conference include:

  • A new administration and CMS Senior Leadership, Deputy Administrator and Director, Daniel Tsai
  • System and policy changes to accommodate needs driven by COVID-19, the substance use epidemic, and other hardships
  • Continued modular implementations, piloting of Outcomes-Based Certification and a focus on the Medicaid problems we are trying to solve
  • Steady progress on Medicaid Enterprise Systems modernization
  • Human-centered design focus
  • States seem to be striving to be more proactive and set up project management offices to help them be more efficient (great to hear attitudes like Kentucky’s, “If you can measure it, you can improve it.”). Examining the root cause with good planning helps reduce “reacting”
  • Agency collaboration and improvements in interoperability as well as collaboration with our federal CMS partners
  • Improved tools and monitoring tools (how about Tennessee’s dashboard demo!)

Challenges ahead that were raised in sessions and conversations during MESC include:

  • Public health emergency “unwinding” – lots of rule changes, potential re-enrollment for up to 80 million members
  • Coverage and access – healthcare is at a tipping point, and the future is a connected healthcare system
  • Equity and patient access
  • Whole person care innovation, delivery system reform, putting patients at the center
  • Managing data and data exchanges
  • Focus on Fast Healthcare Interoperability Resources (FHIR)—a progressive change

Inspiration to continue moving forward

Concepts of inspiration that I carry with me from this conference and will help me continue moving forward:

  • Many responses to the pandemic began organically with only a few, which grew to hundreds of thousands, showing us that a “few” (i.e., us) can lead to meaningful and impactful solutions.
  • Medicaid is about the people it’s serving, not the technology.
  • Everyone is born with creativity and the importance of curiosity as a form of listening
  • Collaboration is about peer respect—we need to understand what everyone is excellent at so we can count on them (thank you Michael Hendrix!)
  • Embrace change as a healthy way of being

We all know there is a lot going on right now and there is more to come—at work, in our lives, in our country, and on this planet. Our state partners need help as they are continually asked to do more (effectively) with less. States’ Medicaid members need help, and our state partners need help. Examining how we are structured, what tools and organizational and project management approaches we can leverage, and how we care for ourselves and our teams so we can be there for our citizens, will take us a long way towards a successful outcome. We are all in this together. Let’s dare to be bold, be creative, be innovative, be intentional—let’s lead the way to fulfil our vision and our mission!

Article
MESC 2021 reflections 

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on State Medicaid Enterprise System (MES) certification or modernization efforts.

As states transition to the Centers for Medicare & Medicaid Services' (CMS) Outcomes-Based Certification (OBC), many jurisdictions are also implementing (or considering implementation of) an Integrated Eligibility System (IES). Federal certification for a standalone Medicaid Enterprise System (MES) comes with its own challenges, especially as states navigate the recent shift to OBC for Medicaid Eligibility and Enrollment (E&E) services. Certification in the context of an IES creates a whole new set of considerations for states, as Medicaid eligibility overlaps with that of benefit programs like the Supplemental Nutrition Assistant Program (SNAP), Temporary Assistance for Needy Families (TANF), and others. We’ve identified the following areas for consideration in your own state's IES implementation: 

  • Modernizing MES 
    It's likely your state has considered the pros and cons of implementing an IES, since CMS' announcement of increased federal funds for states committed to building new and/or enhanced Medicaid systems. Determining whether an IES is the right solution is no small undertaking. From coordinating on user design to system security, development of an IES requires buy-in across a wider range of programs and stakeholders. Certification will look different from that of a standalone MES. For example, your state will not only need to ensure compliance with CMS' Minimum Acceptable Risk Standards for Exchanges (MARS-E), but also account for sensitive data, such as medical information, across program interfaces and integration. 

    BerryDunn recommends one of the first steps states take in the planning phase of their IES implementation is to identify how they will define their certification team. Federal certification itself does not yet reflect the level of integration states want to achieve with an IES, and will require as much subject matter expertise per program included in the IES as it requires an understanding of your state's targeted integration outcomes and desired overlap among programs.
  • Scale and scope of requirements
    Once your agency commits to designing an IES, the scope of its solution becomes much broader. With this comes a wider range of contract requirements. Requirements can be program-specific (e.g., relevant only to Medicaid) or program-agnostic (e.g., general technical, "look-and-feel", and security requirements that apply throughout the solution). Common requirements across certain programs (e.g., certain eligibility criteria) will also need to be determined. Requirements validation and the development of Requirements Traceability Matrixes (RTM) per program are critical parts of the development phase of an IES implementation.

    BerryDunn recommends a comprehensive mapping process of requirements to OBC and other federal certification criteria, to ensure system design is in compliance with federal guidance prior to entering go/no-go for system testing phases.
  • Outcomes as they apply across programs
    CMS' transition to OBC changed the way states define their Medicaid program outcomes. Under this new definition outcomes are the value-add, or the end result, a state wishes to achieve as the result of its Medicaid eligibility solution enhancements. In the context of an IES, Medicaid outcomes have to be considered in terms of their relation to other programs. For example, presumptive eligibility (PE) between SNAP and Medicaid and/or cross-program referrals might become more direct outcomes when there is an immediate data exchange between and among programs.

    BerryDunn recommends consideration of what you hope to achieve with your IES implementation. Is it simply an upgrade to an antiquated legacy system(s), or is the goal ultimately to improve data sharing and coordination across benefit programs? While certification documentation is submitted to individual federal agencies, cross-program outcomes can be worked into your contract requirements to ensure they are included in IES business rules and design.
  • Cost allocation
    In the planning phase of any Design, Development, and Implementation (DDI) project, states submit an Advance Planning Document (APD) to formally request Federal Financial Participation (FFP), pending certification review and approval. This APD process becomes more complex in an IES, as states need to account for FFP from federal programs in addition to CMS as well as develop a weighted cost allocation methodology to distribute shares equitably across benefit programs.

    BerryDunn recommends States utilize the U.S. Department of Health & Human Services (HHS), Administration for Children & Families (ACF), Office of Child Support Enforcement's (OCSE) Cost Allocation Methodologies (CAM) Toolkit to inform your cost allocation model across benefit programs, as part of the APD development process
  • Timeline
    A traditional MES implementation timeline accounts for project stages such as configuration sessions, requirement mapping, design validation, testing, CMS' Operational Readiness Review (ORR), etc. The project schedule for an IES is dependent on additional factors and variables. Scheduling of federal certification reviews for OBC and/or other programs might be held up by project delays in another area of the implementation, and project teams must be agile enough to navigate such changes

    BerryDunn recommends development of a thoughtful, comprehensive project schedule allowing ample time for each project phase across programs. We also recommend states cultivate relationships with federal partners including, but not limited to, CMS, to communicate when a development delay is anticipated. Engaging federal partners throughout the DDI phases will be a critical part of your IES implementation.

In theory, an IES benefits stakeholders on both sides of the system. Caseworkers avoid duplication of efforts, reduce administrative costs, and ensure program integrity, while individuals and families on the receiving end of public benefit programs experience a more efficient, streamlined application process. In practice, the development of a comprehensive business rules, case management, and workflow system across human services programs can prove to be a heavy lift for states, including but not limited to considerations around certification to secure FFP. Planning for the implications of an IES implementation ahead of time will go a long way in preparing your agency and state for this comprehensive certification effort.
 
For further reading
Keep an eye out for the next blog in this series, highlighting certification guidelines across an IES implementation (for CMS and other Federal programs). You can read more on OBC here

If you have questions about your specific situation, please contact the Medicaid Consulting team. We’re here to help. 

Article
States transition to Outcomes-Based Certification: Considerations and recommendations

Read this if you are a timber harvester, hauler, or timberland owner.

The USDA recently announced its Pandemic Assistance for Timber Harvesters and Haulers (PATHH) initiative to provide financial assistance to timber harvesting and hauling businesses as a result of the pandemic. Businesses may be eligible for up to $125,000 in financial assistance through this initiative. 

Who qualifies for the assistance?

To qualify for assistance under PATHH, the business must have experienced a loss of at least 10% of gross revenue from January, 1, 2020 through December 1, 2020 as compared to the same period in 2019. Also, individuals or legal entities must be a timber harvesting or timber hauling businesses where 50% or more of its revenue is derived from one of the following:

  • Cutting timber
  • Transporting timber
  • Processing wood on-site on the forest land

What is the timeline for applying for the assistance?

Timber harvesting or timber hauling businesses can apply for financial assistance through the USDA from July 22, 2021 through October 15, 2021

Visit the USDA website for more information on the program, requirements, and how to apply.
If you have any questions about your specific situation, please contact our Natural Resources team. We’re here to help. 

Article
Temporary USDA assistance program for timber harvesters and haulers

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on a State Medicaid Enterprise System (MES) certification or modernization efforts.

You can listen to the companion podcast to this article, Organization development: Shortcuts for states to consider, here: 

Over the last two years, the Centers for Medicare and Medicaid Services (CMS) has undertaken an effort to streamline MES certification. During this time, we have been fortunate enough to be a trusted partner in several states working to evolve the certification process. Through this collaboration with CMS and state partners, we have been in front of recent certification trends. The content we are covering is based on our experience supporting states with efforts related to CMS certification. We do not speak for CMS, nor do we have the authority to do so.

What organization development (OD) shortcuts can state Medicaid agencies consider when faced with competing priorities and challenges such as Medicaid modernization projects in flight, staffing shortages, and a retiring workforce?

The shortcuts include rapid development and understanding of the “why”. This requires the courage to challenge assumptions, especially around transparency, to allow for a consistent understanding of the needs, data, environment, and staff members’ role in impacting the health of the people served by a state’s Medicaid program. To rapidly gain an understanding of the “why”, state Medicaid agencies should:

  1. Accelerate the transparency of information and use of data in ways that lead to a collective understanding of the “why”. Accelerating a collective understanding of the why requires improved communication mechanisms. 
  2. Invest time to connect with staff. The insistence, persistence, and consistency of leaders to stay connected to their workforce will help keep the focus on the “why” and build a shared sense of connection and purpose among teams.
  3. Create the standard that planning involves all stakeholders (e.g., policy, operations, systems staff, etc.) and focus on building consensus and alignment throughout the organization. During planning, identify answers to the following questions: What are we trying to achieve, what are the outcomes, and what is the vision for what we are trying to do?
  4. Question any fragmentation. For example, if there is a hiring freeze, several staff are retiring, and demand is increasing, it is a good idea to think about how the organization manages people. Question boundaries related to your staff and the business processes they perform (e.g., some staff can only complete a portion of a business process because of a job classification). Look at ways to broaden the expectations of staff, eliminate unnecessary handoffs, and expect development. Leaders and teams work together to build a culture that is vision-driven, data-informed, and values-based.

What are some considerations when organizations are defining program outcomes and the “why” behind what they are doing? 

Keep in mind that designing system requirements is not the same as designing program outcomes. System requirements need to be able to deliver the outcomes and the information the organization needs. With something like a Medicaid Enterprise System (MES) modernization project, outcomes are what follow because of a successful project or series of projects. For example, a state Medicaid agency looking to improve access to care might develop an outcome focused on enabling the timely and accurate screening and revalidation for Medicaid providers. 

Next, keeping with the improving access to care example, state Medicaid agencies should define and communicate the roles technology and staff play in helping achieve the desired outcome and continue communicating and helping staff understand the “why”. In Medicaid we impact people’s lives, and that makes it easy to find the heart. Helping staff connect their own motivation and find meaning in achieving an outcome is key to help ensure project success and realize desired outcomes. 

Program outcomes represents one of the six major categories related to organizational health: 

  1. Leadership
  2. Strategy
  3. Workforce
  4. Operations and process improvement 
  5. Person-centered service
  6. Program outcomes

Focusing on these six key areas during the analysis, planning, development, and integration will help organizations improve performance, increase their impact, and achieve program outcomes. Reach out to the BerryDunn’s Medicaid and Organization Development consulting team for more information about how organization develop can help your Medicaid agency.
 

Article
Outcomes and organization development, part II

Read this if your facility or organization has received Provider Relief Funds.

The rules over the use of the HHS Provider Relief Funds (PRF) have been in a constant state of flux and interpretation since the funds started to show up in your bank accounts back in April. Here is a summary of where we are as of June 14, 2021 on HHS’ reporting requirements. Key highlights:

These requirements apply to:

  • PRF General and Targeted Distributions
  • the Skilled Nursing Facilities (SNF) and Nursing Home Infection Control Distribution
  • and exclude:
    • the Rural Health Clinic COVID-19 Testing Program
    • claims reimbursements from HRSA COVID-19 Uninsured Program and the HRSA COVID-19 Coverage Assistance Fund (CAF)

This notice supersedes the January 15, 2021 reporting requirements.
Deadline for Use of Funds:

Payment Received Period

Deadline to Use Funds

Reporting Time Period

Period 1

4/10/20-6/30/20

6/30/21

7/1/21-9/30/21

Period 2

7/1/20-12/31/20

12/31/21

1/1/22-3/31/22

Period 3

1/1/21-6/30/21

6/30/22

7/1/22-9/30/22

Period 4

7/1/21-12/31/21

12/31/22

1/1/21-3/31/23

Recipients who received one or more payments exceeding $10,000 in the aggregate during each Payment Received Period above (rather than the previous $10,000 cumulative across all PRF payments) are subject to the above reporting requirements 

Responsibility for reporting:

  • The Reporting Entity is the entity that registers its Tax Identification Number (TIN) and reports payments received by that TIN and its subsidiary TINs.
  • For Targeted Distributions, the Reporting Entity is always the original recipient; a parent entity cannot report on the subsidiary’s behalf and regardless of transfer of payment.

Steps for reporting use of funds:

  1. Interest earned on PRF payments
  2. Other assistance received
  3. Use of SNF and Nursing Home Control Distribution Payments if applicable (any interest earned reported here instead), with expenses by CY quarter
  4. Use of General and Other Targeted Distribution Payments, with expenses by CY quarter
  5. Net unreimbursed expenses attributable to Coronavirus, net after other assistance and PRF payments by quarter
  6. Lost revenues reimbursement (not applicable to PRF recipients that received only SNF and Nursing Home Infection Control Distribution payments)

PORTAL WILL OPEN ON JULY 1, 2021!

Access the full update from HHS: Provider Post-Payment Notice of Reporting Requirements.

Article
Provider Relief Funds: HHS Post-Payment Notice of Reporting Requirements

Read this if you are a community bank.

The Federal Deposit Insurance Corporation (FDIC) recently issued its first quarter 2021 Quarterly Banking Profile. The report provides financial information based on Call Reports filed by 4,978 FDIC-insured commercial banks and savings institutions. The report also contains a section specific to community bank performance. In first quarter 2021, this section included the financial information of 4,531 FDIC-insured community banks. Here are our key takeaways from the community bank section of the report:

  • There was a $3.7 billion increase in quarterly net income from a year prior despite continued net interest margin (NIM) compression. This increase was mainly due to higher noninterest income and lower provision expenses. Provision expense decreased $1.4 billion from first quarter 2020. However, it remained positive at $390.1 million. For non-community banks, provision expense was negative $14.9 billion for the first quarter 2021.
  • Quarterly NIM declined 28 basis points from first quarter 2020 to 3.26%. The average yield on earning assets fell 76 basis points to 3.64%, while the average funding cost fell 48 basis points to 0.37%.
  • Net operating revenue increased by $3.9 billion from first quarter 2020, a 17.1% increase. This increase is attributable to higher revenue from loan sales (increased $1.3 billion, or 126.4%) and an increase in net interest income (up $1.8 billion from first quarter 2020).
  • Non-interest expense increased 7.6% from first quarter 2020. This increase was mainly attributable to salary and benefit expenses, which saw an increase of $838.1 million (9.6%). That being said, average assets per employee increased 18.5% from first quarter 2020.
  • Noncurrent loan balances (loans 90 days or more past due or in nonaccrual status) remained relatively stable from a year ago having slightly increased by $19.3 million, or 0.2%. However, despite the slight increase in noncurrent loan balances, the noncurrent rate decreased 8 basis points from first quarter 2020 due to strong year-over-year loan growth.
  • The coverage ratio (allowance for loan and lease losses as a percentage of loans that are 90 days or more past due or in nonaccrual status) increased 30 percentage points year-over-year to 180%, a 14-year high.
  • Net charge-offs declined 7 basis points from first quarter 2020 to 0.04%, a record low. The net charge-off rate for consumer loans declined most among major loan categories, having decreased 41 basis points.
  • Trends in loans and leases showed a moderate increase from fourth quarter 2020, increasing by 1.4%. This increase was mainly seen in the commercial and industrial (C&I) loan category, which was driven by an increase in Paycheck Protection Program (PPP) loan balances. Total loans and leases increased by 10.8% from first quarter 2020. The majority of growth was seen in C&I loans, which accounted for approximately three-quarters of the year-over-year increase in loans and leases. However, keep in mind C&I loans include PPP loans that were originated in the first half of 2020, with additional funding provided by the Consolidated Appropriations Act in December 2020.
  • Nearly all community banks reported an increase in deposit volume during the year. Growth in deposits above the insurance limit drove the annual increase while alternative funding sources, such as brokered deposits, declined. However, even when doing a quarter-to-quarter comparison, deposits were up from fourth quarter 2020 by 5.6%.
  • The average community bank leverage ratio (CBLR) for the 1,845 banks that elected to use the CBLR framework was 11.15%.
  • The number of community banks declined by 29 to 4,531 from fourth quarter 2020. This change includes two new community banks, five banks transitioning from community to non-community banks, 24 community bank mergers or consolidations, and two community bank self-liquidations.

First quarter 2021 was a strong quarter for community banks, as evidenced by the increase in year-over-year quarterly net income of 77.5% ($3.7 billion). However, tightening NIMs will force community banks to either find creative ways to increase their NIM, grow their earning asset bases, or find ways to continue to increase non-interest income to maintain current net income levels. Some community banks have already started dedicating more time to non-traditional income streams, as evidenced by a 45% year-over-year increase in quarterly non-interest income. The importance of the efficiency ratio (non-interest expense as a percentage of total revenue) is also magnified as community banks attempt to manage their non-interest expenses in light of declining NIMs.

Despite the strong first quarter, there is still uncertainty in many areas. For instance, although significant charge-offs have not yet materialized, the financial picture for many borrowers remains uncertain, and payment deferrals have made some credit quality indicators, such as past due status, less reliable. The ability of community banks to maintain relationships with their borrowers and remain apprised of the results of their borrowers’ operations has never been more important. This monitoring will become increasingly important as we transition into a post-pandemic economy. For seasonal borrowers, this summer could be a “make-or-break” point. If strong demand does not materialize, the economic consequences of the pandemic may not be reversible. 

Additionally, as offices start to open employers will start to reassess their office needs. Many employers have either created or revised remote working policies due to changing employee behavior. If remote working schedules persist, whether it be full-time or hybrid, the demand for office space may decline, causing instability for commercial real estate borrowers. Recent inflation concerns have also created uncertainty surrounding future Federal Reserve monetary policy. If an increase in the federal funds target rate is used to combat inflation, community banks could see their NIMs in another transitory stage. As always, please don’t hesitate to reach out to BerryDunn’s Financial Services team if you have any questions.

Article
FDIC Issues its First Quarter 2021 Quarterly Banking Profile