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FY 2022 Prospective Payment System (PPS) and Consolidated Billing for Skilled Nursing Facilities (SNFs) Final Rule

01.03.22

The Centers for Medicare & Medicaid Services (CMS) issued the final rule for the PPS and consolidated billing for SNFs for FY 2022 (published in the Federal Register on August 4, 2021). The rule:

  • Updates the PPS payment rates for SNFs for FY 2022 using the market basket update and budget neutrality factors effective October 1, 2021.
  • Makes changes based on Section 134 of the Consolidated Appropriations Act, 2021—New Blood Clotting Factor Exclusion from SNF Consolidated Billing.
  • Updates the SNF Quality Reporting Program (QRP).
  • Makes changes to the SNF Value-Based Purchasing (VBP) program due to the public health emergency (PHE).
  • Adopts changes in Patient Driven Payment Model (PDPM) International Classification of Diseases, Version 10 (ICD-10) code mappings.
  • Updates the methodology for recalibrating the PDPM parity adjustment.

2022 PPS rate calculations

CMS rebased and revised the SNF market basket index to improve payment accuracy under the SNF PPS by using 2018 Medicare–allowable total cost data to update the PPS payment rates, instead of 2014 data. The final rule includes:

  • A 1.2% net market basket increase based on a 2.7% SNF market basket update, less a 0.8 percentage point forecast error adjustment and a 0.7 percentage point productivity adjustment.
  • A budget neutrality factor of 1.0006.
  • A decrease in the labor-related weight from 71.3% for FY 2021 to 70.4% for FY 2022.

CMS projects an overall impact of this final rule to be an estimated increase of $410 million in aggregate payments to SNFs during FY 2022. This reflects a $411 million increase from the update to the payment rates and a $1.2 million decrease due to the reduction to rates to account for the excluded blood-clotting factors. 

The final rule also estimates an increase in costs to SNFs of $6.63 million related to the FY 2022 SNF QRP changes and an estimated reduction of $191.64 million in aggregate payments to SNFs during FY 2022 as a result of the changes to the SNF VBP Program.

The projected overall impact to providers in urban and rural areas is an average increase of 1.1% and 1.6%, respectively, with a low of .2% for rural New England providers and a high of 2.6% for rural South Atlantic providers―actual impact will vary. 

The applicable wage index continues to be based on the hospital wage data, unadjusted for occupational mix, rural floor, or outmigration adjustment (from FY 2018) in the absence of SNF specific data.

Section 134 of the Consolidated Appropriations Act, 2021—New Blood Clotting Factor Exclusion from SNF Consolidated Billing

Section 134 in Division CC of the Consolidated Appropriations Act, 2021 added blood clotting factors used for the treatment of patients with hemophilia and other bleeding disorders and items and services related to the furnishing of such factors under section 1842(o)(5)(C) to the list of items and services excluded from the consolidated billing requirements under the SNF PPS effective for items and services furnished on or after October 1, 2021.

CMS is finalizing a reduction in the SNF rates to account for this new exclusion. This methodology will result in a proportional reduction of $0.02 in the unadjusted urban and rural rates which equates to an estimated decrease of approximately $1.2 million in aggregate Part A SNF spending to offset the increase in Part B spending that will occur due to these items and services being excluded from SNF consolidated billing.

SNF QRP update

CMS adopted two new measures beginning with FY2023; the SNF Healthcare-Associated Infections Requiring Hospitalization measure (SNF HAI) and the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, and updated the calculation for another measure, the Transfer of Health (TOH) Information to the Patient—Post-Acute Care (PAC) measure. In addition, CMS made a modification to revise the number of quarters used for publicly reporting certain SNF quality measures due to the PHE. 

SNF VBP Program

CMS will suppress the SNF readmission measure for scoring and payment adjustment purposes for the FY 2022 SNF VBP Program Year because circumstances caused by the PHE for COVID-19 have significantly affected the measure and the ability to make fair, national comparisons of SNFs’ performance scores. As part of a special scoring policy for FY 2022, CMS will assign a performance score of zero to all participating SNFs, irrespective of how they perform using the previously finalized scoring methodology, to mitigate the effect that PHE-impacted measure results would otherwise have on SNF performance scores and incentive payment multipliers. CMS will also reduce the adjusted Federal per diem rate for each SNF by 2% and award SNFs 60% of that withhold, resulting in a 1.2% payback percentage for FY2022. Finally, SNFs that qualify for the low-volume adjustment will continue to receive 100% of that 2% withhold.

Finally, CMS revised the performance period for the FY 2022 SNF VBP program and finalized the performance period for the FY 2023 and FY 2024 SNF VBP Program.

BerryDunn created an interactive rate calculator to assist you with the calculation of your PPS rates for FY 2022, which has been updated and now reflects VBP adjustments. You can access the PPS interactive rate calculator now.

Download the 2022 SNF PPS Rate Calculator

If you have any specific questions about the Final Rule or how it might impact your facility, please contact Ashley Tkowski or Melissa Baez.

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Read this if you are involved with PPS and work at a SNF.

The Centers for Medicare & Medicaid Services (CMS) issued the final rule for the PPS and consolidated billing for SNFs for FY 2021 (published in the Federal Register on August 5, 2020). The final rule also updates the SNF Value-Based Purchasing (VBP) Program. The rule:

  • Updates the PPS payment rates for SNFs for FY 2021 using the market basket update and budget neutrality factors effective October 1, 2020.
  • Makes revisions to the International Classification of Diseases, Version 10 (ICD-10) code mappings used under SNF PPS to classify patients into case-mix groups.
  • Adopts the recent revisions in Office of Management and Budget (OMB) statistical area delineations used to identify a facility’s status as urban or rural and calculate the wage index. 
  • Updates the SNF VBP Program, including a 30-day Phase One Review and Correction deadline for the baseline period quality measure report.

2021 PPS rate calculations
The final rule includes:

  • A 2.2% net market basket increase. As the forecasted error adjustment did not exceed the 0.5% threshold, there is no multifactor productivity adjustment for FY 2021. 
  • A budget neutrality factor of .9992.
  • An increase in the labor-related weight from 70.9% for FY 2020 to 71.3% for FY 2021.

CMS projects aggregate payments in FY 2021 to SNFs will increase $750 million. In addition, CMS projects the overall impact of the SNF VBP to be a reduction of $199.54 million in aggregate payments to SNFs during FY 2021, for an estimated net increase of $550.46 million. 

The projected overall impact to providers in urban and rural areas is an average increase of 2.2% and 2.4%, respectively, with a low of 1% for urban New England providers and a high of 3.2% for urban Middle Atlantic providers―actual impact will vary depending on the provider’s CBSA. These estimated payment increases include the impact of the Patient Driven Payment Model (PDPM), updated wage data, the net market basket increase for FY 2021, and updated OMB statistical area delineations; but does not reflect the impact of SNF VBP, which as previously noted is estimated to total $199.54 million in FY 2021. 

The applicable wage index continues to be based on the hospital wage data, unadjusted for occupational mix, rural floor, or outmigration adjustment (from FY 2017) in the absence of SNF specific data.

ICD-10 code mapping changes
Each year the ICD-10 Coordination and Maintenance Committee publishes updates to the ICD-10 medical code data sets. In the final rule several changes to the PDPM ICD-10 code mappings and lists were finalized. The updated FY 2021 PDPM ICD-10 Code Mappings as reported on the CMS website can be found here

Core-Based Statistical Areas (CBSA) changes 
On September 14, 2018, OMB issued OMB bulletin No. 18-04, which established revised statistical area delineations. The final rule includes implementation of the delineations effective October 1, 2020. The revisions adopted resulted in 34 urban counties becoming rural, 47 rural countries becoming urban, some urban CBSAs undergoing a change to the CBSA name and/or number only, and some urban counties moving to another newly established or modified urban CBSA under the revised delineations as detailed in the federal register. 

As a result of these changes, CMS is including a one-year transition for FY 2021 under which a 5% cap on any decrease in a wage index compared to that of the prior fiscal year will be applied.

Click here to be taken to the Federal Register to see if your county is one that is impacted by the changes which are located in Tables 11, 12, 13 and 14. 

VBP program
The final rule includes a 30-Day Phase One Review and Correction deadline applied to the baseline period quality measure report. This was done in order to align the Phase One Review and Correction deadlines for the quarterly reports that contain the underlying claims and measure rate information for the baseline period or performance period. SNFs will now have 30 days following the issuance of those reports to review the underlying claims, measure rate information, and submit a correction request, if any of the information is thought to be inaccurate. 

CMS also published the FY 2023 performance standards based on the baseline period of FY 2019, finalized a policy to codify the data suppression policy, and finalized a policy to amend the regulations to reflect that they will publicly report SNF performance information on the Nursing Home Compare website or a successor website.

Finally, CMS adopted a policy changing the name of the SNF 30-Day Potentially Preventable Readmission Measure (SNFPPR) to SNF Potentially Preventable Readmission after Hospital Discharge. Consistent with this finalized policy, the FY 2021 final rule includes the amended definition of SNF Readmission Measure to reflect the updated SNF Potentially Preventable Readmission after Hospital Discharge measure name. The final rule also amends the definition of performance standards to reflect their ability to update the numerical values of performance standards if they determine there is an error that affects the achievement threshold or benchmark.

COVID-19
The final rule did not address any PDPM COVID-19 related payment policy changes. Regarding SNF consolidated billing, several commenters cited the COVID-19 Public Health Emergency (PHE) as justification for excluding services from consolidated billing that would not otherwise qualify for such exclusion. However, CMS stated that while they recognize the unique circumstances excluding services under SNF consolidated billing that would not otherwise meet the statutory conditions for exclusion would require congressional action.

BerryDunn created an interactive rate calculator to assist you with the calculation of your PDPM rates for FY 2021. You can access the PPS rate calculator now.

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If you have any specific questions about the Final Rule or how it might impact your facility, please contact Ashley Tkowski or Kevin Ware.

Article
FY 2021 Prospective Payment System (PPS) and consolidated billing for Skilled Nursing Facilities (SNFs) final rule

Rates, Patient Driven Payment Model, Value-Based Purchasing, and much more!

CMS has issued the final rule for the Prospective Payment System (PPS) and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2020 (published in the Federal Register on August 7, 2019). Here is what you need to know. The rule:

  • Updates the PPS payment rates for SNFs for FY 2020 effective October 1, 2019.
  • Finalizes minor revisions to the regulation text to reflect the revised assessment schedule under the Patient Driven Payment Model (PDPM) which replaces the current Resource Utilization Groups, Version IV (RUG-IV) model beginning on October 1, 2019. Specifically, to revise the prescribed PPS assessment schedule to reflect the elimination of all scheduled assessments after the initial assessment which is due no later than the 8th day of post hospital SNF care and to allow for any such interim payment assessments as the SNF determines are necessary to account for changes in patient care needs.  
  • Finalizes revisions to the definition of group therapy under the SNF PPS, to state qualified rehabilitation therapist or therapy assistant treating two to six patients at the same time who are performing the same or similar activities. 
  • Finalizes implementation of a subregulatory process for updating the code lists (International Classification of Diseases, Tenth Version (ICD-10) codes) used under PDPM beginning with the updates for FY 2020. The subregulatory process will consist of posting updated code mappings and lists on the PDPM website. More specifically, nonsubstantive changes to the codes included on code mappings and lists under PDPM will be applied through the subregulatory process and substantive revisions to the codes on the code mappings and lists used under PDPM will be proposed and finalized through notice and comment rulemaking.
  • Finalizes updates to the requirements for the SNF Quality Reporting Program (SNF QRP) as follows:
    • Adopts two Transfer of Health Information quality measures; Transfer of Health Information to the Provider-Post-Acute Care and Transfer of Health Information to the Patient-Post-Acute Care.
    • Updates the specifications for the Discharge to Community Measure to exclude baseline nursing facility residents from the measure.
    • Adopts the standardized patient assessment data elements that SNFs will be required to begin reporting with respect to admissions and discharges that occur on or after October 1, 2020, to begin collection in FY 2022, in satisfaction of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). 
    • Adopts public display of the quality measure, Drug Regimen Review Conducted with Follow-Up for Identified Issues-Post Acute Care Skilled Nursing Facility Quality Reporting Program.
    • Revises references in regulation text to reflect enhancements to the system user for submission of data.
  • Finalizes updates to certain policies for the SNF Value-Based Purchasing Program (SNF VBP) which implemented a 2% withhold to SNF Part A payments that can be earned back based on a SNF’s rehospitalization rate and level of improvement in FY 2019 as follows: 
    • Changes the name of the Skilled Nursing Facility 30-Day Potentially Preventable Readmission Measure to the Skilled Nursing Facility Potentially Preventable Readmissions after Hospital Discharge.
    • Adopts FY 2020 as the performance period for the FY 2022 program year and FY 2018 as the baseline period. 
    • Published numerical values for performance standards.
    • Suppresses the SNF information available for public display on the Nursing Home Compare website as follows:
      • SNFs with fewer than 25 eligible stays during the baseline period for a Program year will not have the baseline Risk-Standardized Readmission Rate (RSRR) or improvement score displayed, though the performance period RSRR, achievement score and total performance score will be displayed if the SNF had sufficient data during the performance period.
      • SNFs with fewer than 25 eligible stays during the performance period for a Program year and receives an assigned SNF performance score as a result, will report the assigned SNF performance score and not display the performance period RSRR, the achievement score or improvement score.
      • SNFs with zero eligible cases during the performance period for a Program year will not display any information.
    • Adopts a 30-day deadline for Phase One correction requests.

2020 PPS rate calculations
CMS projects that aggregate payments in FY 2020 to SNFs will increase $851 million. In addition, CMS projects the overall impact of the SNF VBP as a reduction of $527.4 million (which is prior to the redistribution of incentive payments) in aggregate payments to SNFs during FY 2020. The projected overall impact to providers in urban and rural areas is an average increase of 1.7% and 6.2%, respectively, in estimated payments compared with FY 2019. Providers in rural New England will experience an estimated increase in payments of approximately 6.3% while urban New England providers will experience an estimated increase in payments of 4.0%. Providers in rural Middle Atlantic will experience an estimated increase in payments of approximately 4.8% while urban Middle Atlantic providers will experience the largest estimated decrease of .8% (actual impact will vary depending on the provider’s CBSA). 

The updated rates reflect:

  • A 2.4% net market basket increase for FY 2020―results from a 2.8% market basket increase reduced by the multifactor productivity adjustment of 0.4%. This is not adjusted to account for the forecast error correction as the difference between the estimated and actual amount of change in the market basket index does not exceed the 0.5 percentage point threshold.  
  • An increase in the labor-related weight from 70.5% for FY 2019 to 70.9% for FY 2020.
  • Implementation of the new case-mix classification system called PDPM.

The applicable wage index continues to be based on the hospital wage data, unadjusted for occupational mix and rural floor, (from FY 2016) in the absence of SNF specific data.

Patient Driven Payment Model
As discussed in the FY 2019 SNF PPS final rule, PDPM will completely replace RUGs for Medicare Part A Fee-For-Service payment to SNFs effective October 1, 2019. The implementation of PDPM was finalized in a budget neutral manner. Payment will be based on patient characteristics associated with six care components (five case-mix adjusted: physical therapy, occupational therapy, speech language pathology, nursing and non-therapy ancillaries; and one non-case-mix adjusted component), using clinical data from the MDS to assign case-mix classifiers to each patient that are then used to calculate a per diem payment under the SNF PPS. 

BerryDunn has calculated the FY 2020 SNF Medicare PPS rates under PDPM based on the final rule for urban and rural areas of all 50 states and US territories. 

Access the PPS rate calculator now.

Download the 2020 PPS Rates and Calculator

If you have any specific questions about the final rule or how it might impact your facility, please contact Kevin Ware or Ashley Tkowski.

Article
Final rule for FY 2020 SNF PPS and consolidated billing

2019 SNF PPS Final Rule: Rates and so much more

CMS has issued the final rule for the Prospective Payment System (PPS) and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2019 (scheduled to be published in the Federal Register on August 8, 2018). The rule:

  • Updates the PPS payment rates for SNFs for FY 2019 effective October 1, 2018.
  • Finalizes the payment system called the Patient-Driven Payment Model (PDPM) to replace the current Resource Utilization Groups, Version IV (RUG-IV) model beginning on October 1, 2019.
  • Finalizes revisions to the regulation text that describes a beneficiary’s SNF “resident” status under the consolidated billing provision and the required content of the SNF level of care certification.
  • Finalizes several operational aspects of the SNF Quality Reporting Program (QRP), which implements a 2% reduction to the SNF market basket percentage for that fiscal year to SNFs that do not satisfy reporting requirements.
  • Finalizes changes to the SNF Value Based Purchasing Program (VBP), which implements a 2% withhold to SNF Part A payments that can be earned back, based on a SNFs rehospitalization rate and level of improvement, as follows:
    • The 2% reductions and the SNF specific value-based incentive payment adjustment to SNF claims will occur simultaneously,
    • Continuation of the achievement and benchmark threshold rates as previously finalized in the FY 2018 SNF PPS final rule for FY 2020 and finalized the numerical values for FY 2021 based on the FY 2017 baseline period,
    • Adopted FY 2019 as the performance period for the FY 2021 SNF VBP program year and FY 2017 hospital discharges as the baseline period for the FY 2021 SNF VBP program year, 
    • Beginning with the FY 2022 program year and for subsequent program years adoption of a performance period and baseline period that is the 1-year period following the performance and baseline period for the previous program year,
    • SNFs with insufficient baseline period data will be scored based only on their achievement during the performance period, 
    • Low-volume SNFs, with less than 25 eligible stays during a performance period for a program year, will be assigned a performance score based on the average of all SNF performance scores, 
    • SNFs with observed readmission rates of zero may receive risk-standardized readmission rates that are greater than zero, and 
    • Adopted an Extraordinary Circumstances Exceptions policy that will exclude from the calculation of  the measure rate for the applicable baseline and performance periods the calendar months during which the SNF was affected by the extraordinary circumstance.

FY 2019 PPS rate calculations - CORRECTION

CMS issued a correction notice to the 2019 SNF PPS Final Rule on October 3, 2018.

The Interactive Rate Calculator incorporates provider-specific Value Based Purchasing (VBP) adjustments. Enter your facility’s provider number, to calculate your provider-specific VBP adjusted rates. 

Our senior living experts have calculated the FY 2019 SNF Medicare PPS rates based on the final rule for urban and rural areas of Maine, Massachusetts, New Hampshire, and Vermont. CMS projects that aggregate payments in FY 2019 to SNFs will increase $820 million, a 2.4% increase as required by the Bipartisan Budget Act of 2018. Absent this statutory requirement, the FY 2019 market basket update factor would have been 2%, a market basket index of 2.8% reduced by the multifactor productivity adjustment of 0.8%.

In addition to the estimated increase in Medicare payments to SNF’s of $820 million, CMS projects the overall impact of the SNF VBP as a reduction of $211 million in aggregate payments to SNFs during FY 2019, for an estimated net increase of $609 million.

The projected overall impact to providers in urban and rural areas is an average increase of 2.4% and 2.5%, respectively, in estimated payments compared with FY 2018. Providers in rural New England will experience an estimated increase in payments of approximately 1.6% while urban New England providers will experience an estimated increase in payments of 1.7% – actual impact will vary depending on the provider’s CBSA.

The updated rates reflect:

  • A 2.4% net market basket increase for FY 2019—the maximum market basket update allowed as a result of the Bipartisan Budget Act of 2018 which establishes a special rule for FY 2019 that requires the market basket percentage, after the application of the productivity adjustment, to be 2.4%.
  • A decrease in the labor-related weight from 70.8% for FY 2018 to 70.5% for FY 2019.

The applicable wage index continues to be based on the hospital wage data (from FY 2015) in the absence of SNF specific data.

BerryDunn has provided an interactive rate calculator to assist with the calculation of applicable rates and projected Medicare revenues for FY 2019. To access the interactive rate calculator click here.

Please note errors have been identified in the case-mix adjusted rates of the final rule; we believe our interactive rate calculator has corrected these errors; however, if CMS proposes any corrections to these rates, BerryDunn will update the interactive rate calculator as necessary.

Patient-Driven Payment Model

The final rule establishes a new classification system, the Patient-Driven Payment Model (PDPM), which ties SNF payments to patient conditions and care needs rather than volume of services provided to replace the current RUG-IV model. The new classification system is an updated version of the 2017 Advanced Notice of Proposed Rulemaking Resident Classification System Version 1 (RCS-1).

The implementation date for the final system is October 1, 2019 (FY 2020). The PDPM would completely replace RUGs for Medicare Part A Fee-For-Service payment to SNFs. Payment will be based on patient characteristics associated with care components. CMS finalized several core PDPM elements:

  • Payments will be the sum of five independently-determined, case-mix adjusted payment components plus a non-case-mix component (CMG).
  • Therapy minutes are no longer relevant in determining payment, rather patients are assigned to a CMG for each component using clinical information which differs by component.
  • A variable payment schedule was finalized in which payments will taper for physical therapy, occupational therapy and nontherapy ancillary services and will begin on different days for each component.
  • Elimination of multiple mandatory SNF PPS Assessments. PDPM requires only an admission and a discharge assessment and would permit an optional interim payment assessment which is intended to allow SNFs to reclassify patients into CMGs based on changes in condition.
  • Requirement to use ICD-10 diagnosis codes on the admission MDS and as part of physical therapy, occupational therapy, and nontherapy ancillary services classification into a CMG. ICD-10 coding on claims will now drive payment by assigning a diagnosis at admission and a CMG.
  • Combined limit on group and concurrent therapy of up to 25% of a resident’s treatment time per discipline per stay.

If you have any specific questions about the final rule or how it might impact your facility, please contact Tammy Brunetti or Kevin Ware.

Article
Final rule for FY 2019 SNF PPS and consolidated billing

Read is you use QuickBooks Online.

Your customers are your company’s lifeblood. Make sure their records are thorough and up-to-date.

When companies buy other companies, the customer list is often considered the most critical asset. When a business is damaged and data possibly lost, the customer list is the set of records do they most hope to recover.

You probably spend most of your time in QuickBooks Online working with transactions and reports, but your customer records deserve equal time. If they’re incomplete or otherwise not well maintained, you lose time filling in the blanks when you’re trying to complete a task that requires complete customer profiles. Your searches and reports may not tell the whole picture. Your relationships can suffer, and you may miss out on sales opportunities.

QuickBooks Online provides excellent tools for creating and maintaining comprehensive customer and sub-customer records. Here’s a look at how it all works.

Moving your customer data in

There are two ways to create customer records in QuickBooks Online. If you have an existing database in Outlook, Excel, Gmail, or Google Sheets, you can import it. This will save you an enormous amount of time, but it’s a challenging process. You select the file you want to import, and then you have to “map” it by matching the fields in your database to fields in QuickBooks Online. You’ll likely need our help with this.


To import a customer file into QuickBooks Online, you’ll have to “map” its fields. We can help you with this.

Your other option is to enter records manually. This is time-consuming, but the more information you can include about your customers from the start, the better. You can always edit your records to add, delete, or modify what you originally entered.

To get started, hover over Sales in the toolbar and click on Customers. Then click on New Customer in the upper right corner to open the Customer information window. The only field you’re required to complete is Display name as. You may want to do this if you have a new customer on the phone and you want to concentrate on the conversation. You can take notes about their contact information and fill in the record later, when you’re off the phone.

But wherever possible, as we’ve already said, complete as many fields as you can. You’ll enter name and billing and shipping address and phone number(s) on the opening screen. You can also supply contact details like fax number and website. 

Creating sub-customers

You’ll notice a checkbox that says Is sub-customer. QuickBooks Online lets you “nest” related records under the “parent” record. This can be an actual customer, but many people use it to document jobs they’re doing for the customer. So if you’re a contractor, for example, you might have sub-customers like Sun deck and Spa

If you want to set up such a record, enter the job name and click in the box next to Is sub-customer. Two fields will open below that allow you to select the parent customer and to indicate the sub-customer’s billing status. The remainder of the fields will automatically fill in with the parent customer’s contact information.


You can set up jobs as sub-customers in QuickBooks Online. 

Supplying details

When you’re setting up individual customers, you should add as much detail as you possibly can to each record, beyond basic contact information. QuickBooks Online’s record templates display a number of tabs running horizontally across the window. The most important of these are:

  • Tax info. Are the customers taxable or exempt? If taxable, what is his or her Default tax code? (If you haven’t set up sales taxes yet and need to, please let us help. It’s complicated.)
  • Payment and billing. Do they have preferred payment and/or delivery methods? Will you be assigning default payment terms, like Net 30 or Due on receipt? What is their Opening balance? If they’re brand-new customers who have never ordered from you, this will be $0.00. If they’re existing, active customers, enter any outstanding balance they have with you as of the date that you enter. This must be correct, to avoid any problems with the customers’ ongoing balances. Questions? Ask us.

Other tabs here are self-explanatory. When you’ve entered everything you can, click Save. The new record will now appear in the Customers list and will be available to select from the drop-down list in transactions.

There will be times when you have to refer back to these forms to answer questions. By maintaining detailed, accurate customer records, you’ll be ready to respond. If you have questions about any of the information requested, or about other elements of QuickBooks Online that are puzzling you, please contact our Outsourced Accounting team. so we can set up a consultation.

Article
How to maintain customer records in QuickBooks Online

Read this if you use QuickBooks Online.

Are you finding that you need more flexibility in an area of QuickBooks Online? Maybe it’s time to try an integrated app.

When you first started using QuickBooks Online, you probably found it supplied the tools you needed to manage your accounting—and then some. But as your business grows or becomes more complex, you may need more functionality and flexibility in one or more areas, like time tracking and billing.

There are hundreds of add-on applications that integrate well with QuickBooks Online in the QuickBooks Apps store, which you can find here. Many of these apps are free, but most have subscription fees. They’re designed to amplify the power of QuickBooks Online’s own features. The site will remain your home base, but you’ll have to learn enough about the add-on apps to understand how they work and how they integrate with QuickBooks Online. Here are some of the most popular add-on solutions from the QuickBooks Apps site.

Expensify

QuickBooks Online allows you to record expenses. Its thorough form templates ask you for numerous details, like the vendor, product or service, amount, and billable status. Completed expenses appear in a table. You can run any of several related reports, like Expenses by Vendor Summary. If you use the QuickBooks Online mobile app, you can snap photos of receipts that are turned into expense forms by QuickBooks Online and partially completed with the receipt data.

Using the QuickBooks Online mobile app, you can snap photos of receipts and complete the expense forms provided.

But Expensify ($5-9 per month for one user) does more. It’s a robust expense management system that handles everything from receipt processing to next-day reimbursement. Where QuickBooks Online only supports basic expense tracking, Expensify allows you to create expense reports and follow them through multi-level approvals. It features automatic credit card reconciliation and expense policy enforcement, as well as bill pay and invoices/payments. Two-way synchronization with QuickBooks Online means you can work in either application and your data will be replicated in the other, as is the case with all of these integrated solutions.

QuickBooks Time

Formerly known as TSheets, this powerful time-tracking application builds on QuickBooks Online’s time management and payroll features. QuickBooks Time ($8-10 per user per month plus $20-40 monthly base fee) is now owned by Intuit, so it’s embedded directly in QuickBooks Online. 

Your employees can track their hours on any device, from any location, and they will instantly be available in QuickBooks Online so managers can review, edit, and approve timesheets. That data can then be used in areas like invoicing, job costing, and payroll. Advanced features include scheduling capabilities, overtime monitoring, GPS tracking, and real-time reports. The Who’s Working window shows you where your staff members are working and what they’re doing, in real time. 

Method:CRM

QuickBooks Online does a good job of helping you create profiles of customers and storing them for quick retrieval. But some businesses need more than that. They need true Customer Relationship Management (CRM). Method:CRM ($28-49 per month per user; discounts for annual subscriptions) is an excellent partner for QuickBooks Online in this area.

You can record and store customer details in QuickBooks Online, but Method:CRM adds true Customer Relationship management to the site.

When you integrate Method:CRM with QuickBooks Online, you no longer have to do duplicate data entry to keep track of your customers and their sales profiles and histories. You get a shared lead list and activity tracking (emails and phone calls), and your customer records contain the information a sales team needs, like customer details, interaction, transactions, and services performed. Leads are stored in Method:CRM until they’re customers, and you can track sales opportunities from a customer’s initial interest through the final sale. 

Two more advanced integrated apps

QuickBooks Online provides basic inventory-tracking capabilities, but if your business has more complex needs, an integrated application like SOS Inventory ($49.95-149.95 per user per month) should be able to meet them. Built for QuickBooks Online from the ground up, the application offers advanced features like sales orders and order management, assemblies, serial inventory, and multiple locations. And if you need more sophisticated bill pay, invoicing, and payment processing (with multiple automated approval levels) than QuickBooks Online offers, you might look into the highly-regarded Bill.com ($39-69 per user per month).

Growth Is good, but challenging

We wanted to introduce you to a few of the hundreds of integrated apps available for QuickBooks Online because you should know that there are options for expanding on the site’s built-in capabilities. As your business grows, so does your need for more sophisticated accounting. QuickBooks Online may still be able to serve you well with the help of one or more of these add-ons.

You may also want to explore the possibility of upgrading your version of QuickBooks Online. We encourage you to consult with us if you’re outgrowing QuickBooks Online. We can help you explore the options so you can spend your time planning for your company’s future instead of wrestling with your accounting application. Please contact our Outsourced Accounting team

Article
Expand QuickBooks Online's features: Use integrated apps

Read this if you are an employee benefit plan fiduciary.

Fiduciary risk management

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

If, as part of your involvement with an employee benefit plan, you have decision-making ability; you advise those with decision-making ability; or someone tasks you with decision-making related to the plan, you are more likely than not, a fiduciary. As discussed in the first article of the series, this status comes with responsibilities and, therefore, risks and consequences.

The general approach to handling risk is a cycle of identifying, assessing, controlling, and reviewing controls over risks. Based on the assessment of a given risk, there are four ways to manage it: you can avoid, reduce, transfer, or accept the risk. 

Identifying and assessing fiduciary risk1 

The risks facing a plan fiduciary include, but are not limited to, the following:

Removal of fiduciary

In appropriate cases, a fiduciary may be removed and permanently prohibited from acting as a fiduciary or from providing services to ERISA plans.

Civil penalties

Among other penalties, the DOL may assess a civil penalty equal to 20% of the amounts recovered for the plan through litigation or settlement.

Criminal prosecution

Upon a conviction for a willful violation of ERISA’s reporting and disclosure requirements, a fiduciary may be subject to fines and/or imprisonment for not more than ten years. There is also a provision in ERISA that applies to any person, not just ERISA fiduciaries, that makes coercive interference with ERISA rights a criminal offense punishable by fines and/or imprisonment for up to ten years. In addition, outside of ERISA, there are a number of criminal statutes that apply to any person, not just ERISA fiduciaries, including criminal statutes for embezzling from an ERISA plan, making false statements in ERISA documents, and taking illegal kickbacks in connection with an ERISA plan.

Participant lawsuits

Additionally, plan participants may file a lawsuit against the fiduciary for breach of their fiduciary duty. Over the past few years, this has become more common and has generally been related to the fiduciary’s failure to adequately negotiate and monitor plan fees. 

Co-fiduciary liability

ERISA's unique co-fiduciary liability provisions make each fiduciary responsible for the actions of the other plan fiduciaries but only under certain circumstances. As a general rule, fiduciaries aren’t responsible for the breach of another fiduciary unless:

  • They participate knowingly in, or knowingly undertake to conceal, an act or omission of such other fiduciary, knowing such act or omission is a breach;
  • Their failure to be prudent in the administration of their own fiduciary responsibilities enables the other fiduciary to commit a breach; or
  • They have knowledge of a breach by such other fiduciary and don’t make reasonable efforts under the circumstances to remedy the breach.

Controlling fiduciary risk

There are several ways to effectively manage fiduciary risk. When used together, they give you solid controls to greatly reduce your level of risk.

Plan documentation

A fiduciary and/or plan sponsor should reduce their exposure to the risks identified above and their first line of defense is through plan documentation (discussed in depth here). Broadly speaking, the organizers and fiduciaries of the plan should ensure that policies and procedures are laid out to ensure proper oversight and internal controls are in place to prevent any voluntary or involuntary noncompliance with ERISA and the DOL.

Oversight

Fiduciaries should meet formally on a regular basis to review the plan’s offerings, service providers, fees, and other issues that may affect the plan. A single individual who is the sole fiduciary for a plan may not have the knowledge or bandwidth to appropriately fulfill the responsibilities of the plan. Additionally, having an auditor come in and audit the plan can help identify some of the risks identified above, although an audit of the plan does not reduce your responsibility to monitor and review the plan’s activity on an ongoing basis.

Third Party Administrators (TPA) & recordkeepers

Fiduciaries may also be able to mitigate some of the risks identified above through use of a TPA and/or recordkeeper. While TPAs and recordkeepers are not generally considered fiduciaries or co-fiduciaries, TPAs have varying service offerings, including recordkeeping, that are powerful tools to plan administrators to review and operate the plan. For example, depending on the plan sponsor’s existing payroll and HR structure, inclusive of TPAs and recordkeepers, fiduciaries may be able to automate the transfer of contributions to ensure timeliness of deposits. The plan may also be able to add another layer of internal controls by incorporating the TPA’s or recordkeeper’s internal controls into the plan’s control environment assuming the fiduciary has gained an understanding and comfort around the controls present at the TPA and/or recordkeeper.

Professional investment advisors and co-fiduciaries

Employee benefit plans must meet certain requirements with regard to their investment offerings. For instance, the plan must allow participants to invest in a diversified portfolio. The plan may try to transfer some of these risks and employ the help of a professional investment advisor to help ensure the plan’s investment offerings meet such criteria. This could involve hiring either an ERISA 3(21) fiduciary or an ERISA 3(38) fiduciary. The former serves as an advisor and a co-fiduciary, but does not have any authority by themselves, while the latter is an investment manager and therefore authorized to select investments for the plan. Doing so may help demonstrate to regulators that a fiduciary has fulfilled their duty in this regard. Alternatively, a plan may hire a 3(16) Fiduciary. 3(16) Fiduciaries are individuals or organizations that are charged with running plans as the plan administrator. A company may be able to shift most of their fiduciary risk to such a fiduciary. 

In any case, the plan fiduciary must continue to monitor a 3(16), 3(21) or 3(38) advisor to make sure it is still prudent to use that advisor.

Bonding and fiduciary liability insurance

Bonding is required for most EB plans and does not protect the fiduciary from any risk. It does however protect the plan from fraud or dishonesty. On the other hand, fiduciary liability insurance can protect the fiduciary in the case of breach of fiduciary duty. This type of insurance is not required but is another option to transfer fiduciary risk.

As mentioned in our second article, much like owning a car, regular preventative maintenance can help you avoid the need for costly repairs. Plan fiduciaries should periodically refresh their understanding of ERISA requirements and re-evaluate their current and future business activities on an ongoing basis. Doing so will help mitigate any risks associated with non-compliance with the DOL and IRS and keep the plan running smoothly. 

Need help navigating the fiduciary road? Reach out to the BerryDunn employee benefit consulting team today.

1From Fidelity’s Plan Sponsor Webstation: Consequences of breach of fiduciary duties 

Article
Fiduciary risk: Five ways to control and reduce it

Read this if you are working on ESG initiatives at your organization.

Whether you are a director or an executive well into the journey of developing and communicating your company’s strategic sustainability plans or in early stages, the rising public demand for environmental, social, and governance (ESG) reporting is becoming a force that cannot be ignored by boards and management teams.

ESG overview: reminders and FAQs

What does ESG information comprise? The term “ESG” reporting, used broadly, covers qualitative discussions of topics and quantitative metrics used to measure a company’s performance against ESG risks, opportunities, and related strategies. ESG, sustainability, and corporate social responsibility are terms often used interchangeably to describe nonfinancial reporting being shared publicly by companies. Such information is not currently subject to a singular authoritative set of standards.

What are examples of ESG and sustainability information? The following do not represent all-inclusive lists and, while some ESG information may be measured quantitatively, there are often many means to calculate metrics or information that may be difficult to quantify and therefore may be expressed qualitatively and described as such: 

As corporate ESG activities increase in relevance and importance to stakeholders, companies are seeking to both understand the complex landscape of ESG disclosure and reporting and determine the best path forward. This includes identifying, collecting, sharing, and improving upon qualitative and quantitative metrics reflecting long-term, strategic ESG value creation.

Organizations are in various stages of readiness to report on such decision-useful information. Currently, a myriad of reporting frameworks and wide variations in how companies choose to publicly share ESG information exist, making the ESG landscape complex to navigate. However, two things are certain:

  1. The pressure for companies to publicly disclose their approach to sustainability and ESG reporting continues to mount from a broad variety of stakeholders, and 
  2. ESG is rapidly rising to the forefront of boardroom agendas.

We have prepared the following to provide useful reminders, FAQs, and insights for those charged with governance as they consider the rapidly changing current ESG reporting landscape and evolving regulatory developments.

Is there a single authoritative set of ESG reporting standards? 

There are currently several frameworks and standards in use globally by companies to report on ESG, many of which may be complementary and used in combination for external reporting. Some of the more commonly used frameworks are: Sustainability Accounting Standards Board (SASB); Global Reporting Initiative (GRI); Task Force on Climate-Related Financial Disclosures (TCFD); International Integrated Reporting Council (IIRC); and Climate Disclosures Standards Board (CDSB). While many of these may already be complementary to each other, there is also growing support for a singular, global set of reporting standards for ESG, though the timing to achieve the necessary convergence remains uncertain.

Are U.S. companies required to disclose ESG information? 

Outside of certain industry regulators, such as required reporting by the Environmental Protection Agency on greenhouse gas emissions, implementation by U.S. companies remains voluntary. However, pressure from institutional investors—BlackRock, State Street and Vanguard—is mounting in support of companies providing ESG disclosures that align with both the SASB and TCFD frameworks. Additionally, sustainability risk issues are increasingly integrated into organizational risk frameworks such as COSO’s Enterprise Risk Management (ERM) framework.

Companies must also assess whether other ESG information, such as climate risk disclosures, are required under current MD&A disclosure rules. For example, if the risk represents a known trend or uncertainty the company reasonably expects will have a material impact on the company’s results of operations or capital resources, additional disclosure would be required.

What companies are reporting, and what information are they reporting? 

ESG disclosures vary significantly depending on the nature of the business, geography, industry, and stakeholder base, as well as available resources to devote to ESG. The largest global public companies have led the way in external ESG reporting and engagement, but this reporting is rapidly expanding to encompass smaller public entities and private entities. Companies of all sizes are both feeling the pressure to produce ESG reporting and identifying it as a means to differentiate themselves in the market by proactively conveying their corporate stories and strategies.

As noted in a recent White & Case study of proxy statements and filed 10-Ks for the top 50 companies by revenue in the Fortune 100, the following ESG categories showed the most significant increase in disclosures from the prior year:

  • Human capital management (HCM)
  • Environmental
  • Corporate culture
  • Ethical business practices
  • Board oversight of environment & social (E&S) issues
  • Social impact/community
  • E&S issues in shareholder engagement

The study noted that a majority of E&S disclosures in the SEC filings were qualitative and did not provide quantitative metrics. However, disclosures pertaining to environmental, HCM, and E&S goals, along with social impact and community relations were more likely to contain quantitative metrics.

Where do companies report ESG information? The most common places companies are providing public ESG disclosures include:

  • Standalone reports including corporate social responsibility (CSR)/sustainability reports
  • Company websites and marketing materials
  • MD&A sections of annual and quarterly reports
  • Earnings calls
  • Proxy statements and 8-Ks

Evolving auditor ESG attestation

Many of the metrics and qualitative disclosures around ESG information are not “governed” by an established framework such as generally accepted accounting principles (GAAP), and thus, may not be subject to the same rigor of processes and controls over such processes to ensure the integrity and accuracy of the underlying data and the appropriateness of the decisions and judgments being made by management in reporting on such information. For example, the fear of corporate “green or impact washing”—the incentive to make stakeholders believe that a company is doing more to promote ESG activities, particularly environmental protections, than it actually is—has left many stakeholders questioning the reliability, consistency, and accuracy of company ESG reporting. As ESG reporting continues to evolve and become a significant consideration for boards, investors, employees, suppliers, lenders, regulators, and others in making business decisions, there is a growing focus on the value of assurance on such information provided by independent third parties.

Type of attestation services to be provided

Determining the scope and level of assurance to be provided will vary based on company objectives in presenting ESG information, management’s readiness, and intended users and uses of ESG information. Attest services may include:

  • Examination: Consists of an examination performed by an auditor resulting in an independent opinion indicating whether the ESG information is in accordance with the agreed upon criteria, in all material respects. An examination engagement is the closest equivalent to the reasonable assurance obtained in an audit of financial statements.
  • Review: Consists of limited procedures, performed by an auditor, that result in limited assurance. The objective of a review engagement is for the auditor to express a conclusion about whether any material modifications should be made to the ESG information in order for it to be in accordance with the agreed upon criteria. Review engagements are substantially less in scope than examination engagements.


The ESG journey: first steps for boards just beginning the ESG reporting journey

The AICPA and Center for Audit Quality (CAQ) have issued a roadmap for audit practitioners laying out initial steps for those organizations and their boards who are in the beginning phases of the ESG reporting journey:

  • Conduct a materiality or risk assessment to determine which ESG topics are prioritized as important or “material” to the organization, its investors and other stakeholders
  • Implement appropriate board oversight of material ESG matters
  • Integrate/align material ESG topics into the ERM process
  • Integrate ESG matters into the overall company strategy
  • Implement effective internal control over ESG data collection, processing, and reporting


For boards considering an attestation engagement

The CAQ has further prepared the following questions boards may consider for companies that have already started reporting on ESG and may be considering an attestation engagement:

  • What is the purpose and objective of the attestation engagement on ESG information?
  • Who are the intended users of the ESG information and related attestation report?
  • Why do the intended users want or need an attestation report on the ESG information?
  • What are the potential risks associated with a misstatement or omission in the ESG information?
  • Does the company have a clear understanding what ESG information the intended users want or need to be in the scope of the attestation engagement?
  • What level of attestation service (examination or review engagement) will help the company achieve its objective?

Additional questions for board members to consider regarding their company’s preparedness for reporting include:

  • Does management have well established controls, policies, and procedures for the collection of and disclosure of ESG information? Are there gaps to be addressed?
  • Has the board, along with management, set specific objectives and goals for external reporting of ESG information?
  • Is the information disclosed by the company consistent across its various communication channels?
  • Are the ESG responsibilities at the board level clearly defined among appropriate committees and are those responsibilities directly linked to corporate strategic ESG goals and external reporting needs?
  • Have the right advisors been identified to assist in preparing for reporting and/or to attest to the quality of reporting?

Next steps

We encourage management, audit committees, and other board members to continue to educate themselves on the evolving landscape of ESG and carefully consider the needs of various stakeholders broadly when mapping out their ESG reporting needs. Particular attention should be paid to regulatory developments in this area.

Article
ESG reporting: Considerations for boards and those charged with governance