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Using process redesign to align with new CYSHCN standards

By:

Danni Ricks is a Consultant with the Government Consulting Group, specializing in Public Health. She is a Prosci® Certified Change Management Practitioner and experienced in process redesign, vendor management, and RFQ/RFP development.

Danni Ricks
11.12.20

CYSHCN programs have new care coordination standards―how does your agency measure up?

On October 15, 2020, the National Academy for State Health Policy (NASHP) released new care coordination standards for Children and Youth with Special Health Care Needs (CYSHCN) programs. The National Care Coordination Standards supplement the National Standards for Systems of Care, helping to ensure that children and youth with special health care needs receive the high-quality care coordination needed to address their specific health conditions.

The standards also set requirements for screening, identification, and assessment, a comprehensive shared plan of care, coordinated team-based communication, development of child and family empowerment skills, a well-trained care coordination workforce, and smooth care transitions. 

What do the standards mean for CYSHCN programs

The National Care Coordination Standards are more than guidelines for CYSHCN programs; aligning with the standards can lead to operational efficiencies, greater program capacity, and improved health outcomes. The standards can serve as a lens for continuous improvement, highlighting where programs can make changes that reduce the burden on care coordinators and program administrators.

However, striving to meet the standards can be challenging for many programs—as the standards develop and evolve over time, many programs struggle to keep up with the work required to update processes and retrain staff. Assessing a CYSHCN program’s processes and procedures takes time and resources that many state agencies do not have available. Despite the challenge, when state agencies are the most strapped is often when making change is the most needed. A shrinking public health workforce and growing population of CYSHCN means smooth processes are essential. To take steps towards National Care Coordination Standards alignment, BerryDunn recommends the following approach: 

A proven methodology for national standards alignment

There are many ways you can align with the standards. Here are three areas to focus on that can help you guide your agency to successful alignment. 

  1. Know your program
    It can be easy for processes to deteriorate over time. Process mapping is an effective way to shed light on current work flows and begin to determine holes in the processes. Conducting fact-finding sessions to map out exactly how your program functions can help pinpoint areas of strength―and areas where there is room for improvement.
  2. Compare to the national standards
    Identify the gaps with a cross-walk of your program’s current procedures with the National Care Coordination Standards. We assess your alignment through a gap analysis of the process, highlighting how your program lines up with the new standards.
  3. Adopt the changes and reap the benefits
    Process redesign can help implement the standards, and even small adjustments to processes can lead to better outcomes. Additionally, you can deploy proven change management methodologies programs that ease staff into new processes to produce real results.

Meeting national standards doesn’t have to be complicated. Our team partners with state public health agencies, helping to meet best practices without adding additional burden to program staff. We can help you take the moving pieces and complex tasks and funnel them into a streamlined process that gives your state’s children and youth the best care coordination. 

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Read this if you are a Maine business or pay taxes in Maine.

Maine Revenue Services has created the new Maine Tax Portal, which makes paying, filing, and managing your state taxes faster, more efficient, convenient, and accessible. The portal replaces a number of outdated services and can be used for a number of tax filings, including:

  • Corporate income tax
  • Estate tax
  • Healthcare provider tax
  • Insurance premium tax
  • Withholding
  • Sales and use tax
  • Service provider tax
  • Pass-through entity withholding
  • BETR

The Maine Tax Portal is being rolled out in four phases, with two of the four phases already completed. Most tax filings for both businesses and individuals are now available. A complete listing can be found on maine.gov. Instructional videos and FAQs can also be found on this site.

In an effort to educate businesses and individuals on the use of the new portal, Maine Revenue Services has been hosting various training sessions. The upcoming schedule can be found on maine.gov

Article
New Maine Tax Portal: What you need to know

On November 8, 2022, Massachusetts voters approved a constitutional amendment to alter the state’s flat 5% income tax to add a 4% surtax on annual income exceeding $1 million. The so-called “millionaires tax,” also referred to as the “Fair Share Amendment,” is effective for tax years beginning on or after Jan. 1, 2023. The annual income level subject to the surtax would be adjusted yearly to reflect increases in the cost of living.

This measure is expected to bring in revenue of between $1.2 and $2 billion annually. The proceeds from the increased tax collections will support state budgets in the areas of education, roads, bridges, and public transportation. The measure passed with 52% voter support and is the sixth attempt to change the state’s flat income tax rate since 1962. This amendment is expected to affect about 0.6% of the state’s population, or about 20,000 taxpayers.

If you expect your income to exceed $1 million in 2023 and have questions regarding the recent legislation, please contact a member of our state and local tax team.

Article
Massachusetts voters pass "Millionaires tax"

Read this if you are responsible for cybersecurity or are a member of a board of directors.

The board’s role in the oversight of organizational risk is increasingly complicated by cybersecurity concerns. Cybersecurity risk is pervasive and will affect companies in a variety of ways. The responsibility for detailed cyber risk oversight within the board should be well documented and communicated, and may often touch various committees across the board, including but not limited to risk, audit, and compliance. With the increasing complexity surrounding cybersecurity, it is also important for the board to evaluate existing experience and skills, identify gaps, and address those gaps through succession planning or leveraging advisors.

Additionally, all directors need to maintain continual knowledge about evolving cyber issues and management’s plans for allocating resources with respect to the preparedness in responding to cyber risks. Such knowledge helps boards assess the priority-driven and investment decisions put forth by management needed in critical areas.

Here are some critical questions that boards and management should be considering with respect to mitigating cyber security risk for their organizations. They may be useful as a starting point for boards to use in their discussions and as a guide when looking at their oversight of management’s plans for addressing potential cyber risks.

General

  • What is the threat profile and risk tolerance of our organization based on our business model and the type of data our organization holds?
  • Is the cyber risk management plan documented, including the identification, protection, and disposal of data?
  • Has the cyber risk management plan been tested?
  • Does our organization’s cybersecurity strategy align with our threat profile and risk tolerance?
  • Is our cybersecurity risk viewed as an enterprise-wide issue and incorporated into our overall risk identification, management, and mitigation process?
  • What percentage of our IT budget is dedicated to cybersecurity?
  • Does that allocation conform to industry standards?
  • Is it adequate based on our threat profile?
  • What are stakeholder demands and priorities for cybersecurity? Data privacy? Data governance? What interactions has the company or board had with shareholders regarding cybersecurity?
  • What is the interaction model between senior management and the board for communications regarding cybersecurity?
  • Has the regulatory focus on the board’s cybersecurity responsibility been increasing? If so, what is driving that focus?

Board cybersecurity oversight

  • How is oversight of cybersecurity structured (committee vs. full board) and why? Is this structure well documented in the appropriate governance charters?
  • Is cybersecurity an area considered and reported as a director competency? If so, have skill/experience gaps been identified together with plans to resolve those gaps?
  • Is there a cybersecurity expert on the board?

Overall cybersecurity strategy

  • Does the board play an active part in determining an organization’s cybersecurity strategy?
  • What are the key elements of a good cybersecurity strategy?
  • Is the organization’s cybersecurity preparedness receiving the appropriate level of time and attention from management and the board (or appropriate board committee)?
  • How do management and the board (or appropriate board committee) make this process part of the organization’s enterprise-wide governance framework?
  • How do management and the board (or appropriate board committee) support improvements to the organization’s process for conducting a cybersecurity assessment?

Risk assessment: risk profile

  • What are the potential cyber threats to the organization?
  • Who is responsible for management oversight of cyber risk?
  • Has a formal cyber assessment been performed? Does it need to be updated?
  • Do management and the board understand the organization’s vulnerabilities and how it may be targeted for cyber-attacks?
  • What do the results of the cybersecurity assessment mean to the organization as it looks at its overall risk profile?
  • Is management regularly updating the organization’s inherent risk profile to reflect changes in activities, services, and products?

Risk assessment: cyber maturity oversight

  • Who is accountable for assessing, managing, and monitoring the risks posed by changes to the business strategy or technology and are those individuals empowered to carry out those responsibilities?
  • Is there someone dedicated full-time to our cybersecurity mission and function, such as a Chief Information Security Officer (CISO)?
  • Is our cybersecurity function properly aligned within the organization? (Aligning the CISO under the CIO may not always be the best model as it may present a conflict. Many organizations align this function under the risk, compliance, audit, or legal functions, while others with a direct or “dotted line” reporting to the CEO.)
  • Do the inherent risk profile and cybersecurity maturity levels meet risk management expectations from management, the board, and shareholders? If there is misalignment, what are the proposed plans to bring them into alignment?

 Cybersecurity controls

  • Do the organization’s policies and procedures demonstrate management’s commitment to sustaining appropriate cybersecurity maturity levels?
  • What is the ongoing practice for gathering, monitoring, analyzing, and reporting risks?
  • How effective are the organization’s risk management activities and controls identified in the assessment?
  • Are there more efficient or effective means for achieving or improving the organization’s risk management and control objectives?
  • Are there controls in place to ensure adequate, accurate and timely reporting of cybersecurity related content?
  • How does the company remain apprised of laws and regulations and ensure compliance?
  • What cloud services does our organization use and how risky are they?
  • How are we protecting sensitive data?

Threat intelligence and collaboration

  • What is the process for gathering and validating inherent risk profile and cybersecurity maturity information?
  • Does our organization share threat intelligence with law enforcement?
  • What third parties does the organization rely on to support critical activities and does the organization regularly audit their level of access?
  • What is the process to oversee third parties and understand their inherent risks and cybersecurity maturity?

Cybersecurity metrics

  • Have we defined appropriate cybersecurity metrics, the format, and who should be reporting to the board?
  • How regularly should a board obtain IT metric information?
  • Is the information meaningful in a way that invokes a reaction and provides a clear understanding of the level of risk willing to be accepted, transferred, or mitigated?
  • How is the board actively monitoring progress or lack of progress and holding management accountable?

Cyber incident management and resilience

  • How does management validate the type and volume of cyber-attacks?
  • Does the organization have a comprehensive cyber incident response and recovery plan? Does it involve all key stakeholders—both internal and external? Does it include a business disaster recovery communication process?
  • How does an incident response and recovery plan fit into the overall cybersecurity strategy?
  • Is the board’s response role clearly defined?
  • Is the cyber incident response reviewed and rehearsed at least annually? Do rehearsals include cyber incident exercises?
  • Is there a culture of cyber awareness and reporting at all levels of the company?
  • Is the company adequately insured and is coverage reviewed at least annually?

Cybersecurity education

  • How does the board remain current on cybersecurity developments in the market and the regulatory environment?
  • Currently, how does the board evaluate directors' knowledge of the current cyber environment and cybersecurity issues impacting their organizations?
  • Do boards currently have the skill sets necessary to adequately oversee cybersecurity? How is the board identifying and evaluating the necessary director skills and experience in this area?
  • Are directors provided with educational opportunities in this area?
  • Is regular cybersecurity education provided to the entire organization?

Cybersecurity disclosure

  • Has oversight of cybersecurity reporting been defined for management and the board?
  • Are company policies and procedures to identify and manage cybersecurity risk, management’s role in implementing cybersecurity policies and procedures, board of directors’ cybersecurity expertise and its oversight of cybersecurity risk, being included within the financial statement and proxy disclosures?
  • Does the company have a mechanism for timely reporting of material cybersecurity incidents?
  • Have updates about previously reported material cybersecurity threats and incidents been included in the financial statements?

If you have any questions about cybersecurity programs, communicating with your board about cybersecurity, or have a specific question about your company or organization, please contact our IT security experts. We're here to help. 

Article
Board oversight of cybersecurity: Questions to ask

Thanks to a little-known law, eligible Massachusetts taxpayers will receive a tax credit in the form of a refund this fall—just in time for holiday shopping. Chapter 62F of the Massachusetts General Laws, a voter passed initiative from 1986, states that if state tax revenue collections exceed a cap tied to wage and salary growth, the surplus must be returned to the taxpayers. This tax credit was only triggered once before – 35 years ago.

According to the Mass.gov website, in Fiscal Year 2022, state tax revenues exceeded the cap by $2.941 billion—the sum of which will be returned to taxpayers by check or direct deposit in the coming months.

Governor Baker stated that a preliminary estimate of the refunds will be approximately 13% of the taxpayer’s personal income tax liability in 2021, though they will update that estimate in late October, once all 2021 tax returns have been filed.

More details on the tax refund:

  • Taxpayers, both resident and non-resident, who have filed a 2021 state tax return on or before September 15, 2023, are eligible for the refund.
  • The expected time frame for the issuance of refunds is expected to begin November 2022.
  • Individual refunds may be reduced by refund intercepts, such as unpaid child support or unpaid tax liability.
  • Massachusetts taxpayers can use this online refund estimator to calculate their estimated refund using information from their 2021 tax returns.

If you have questions, please contact a member of our state and local tax team.

Article
Chapter 62F law to give Massachusetts taxpayers a bonus refund

Read this if you use QuickBooks Online.

Let's talk about where records for products and services are used in QuickBooks Online.

To create a product or service record, you hover your mouse over Sales in the left vertical pane on the main page and click Products and services. Click New in the upper right corner and open a blank record for an Inventory or Non-inventory part, a Service, or a Bundle (assembly). Once you complete a record and save it, it will appear in the list back on the Product and services page.

Working with products and services

That’s where we’ll start today, on the Products and services screen. This is a comprehensive table, a dashboard (or home page) for your products and services. It displays real-time information about your items’ pricing and inventory levels, as well as their type and tax status. At the top of the page, you’ll see big, colorful buttons that provide a total of the number of items that are low on stock or out of stock. When you click on one, a list of those products appears.

QuickBooks Online’s Products and services page displays inventory levels and warns you when your stock is low and at zero.

Each row on this screen contains details about the item listed there, like Description, Sales Price and Cost, and Qty On Hand. If you look down at the end of the row, you’ll see options for several types of Actions: Edit, Make inactive, Run report, and Duplicate. Click the gear icon above the table to modify the columns in the table. 

The More menu at the top of the screen contains more options: Manage categories, Run reports, and Price rules. If you want to know what actions you can take on multiple items simultaneously, check the box in front of each and click the Batch actions menu, over to the right (Adjust quantity, Reorder, etc.).

Warning: Be very careful using the Adjust quantity option. There are legitimate reasons for employing it, but you need to make very sure that you understand how this will affect other areas of your accounting. Please ask us if you’re unsure.

Using products and services in transactions

Once you start using product and service records in transactions, you’ll see why we suggested that you create those early on and make them as comprehensive as possible. While you can add products and services in the process of creating an invoice, for example, it’s much easier if you have them ready to go.

Let’s look at a sales receipt to see how this works. Click +New in the upper right corner and select Sales receipt. Select a Customer in the first field and verify that the related fields on the form were filled out correctly. Check and make any changes necessary in the Sales receipt date, Payment method, and Deposit to fields. 

Once you’ve built up a list of products and services, they’ll be available when you create transactions.

Enter the Service Date, and then click the down arrow in the field under Product/Service. The top of the list has an entry labeled +Add new. Click it if you need to add a product or service on the fly, or just select the existing one that you want. QuickBooks Online will fill in the Rate, Amount, and Tax (status). You only have to enter the Qty (quantity) that you’re selling. 

If you have more items or services to add, you can do so on the next line(s). When you’re done, check the numbers in the lower right and save the transaction. QuickBooks Online will adjust your inventory to account for any items you just sold. You can see this change by going back to the Products and Services screen. Or you can run reports, including:

  • Sales by Product/Service
  • Product/Service List
  • Inventory Valuation Detail
  • Physical Inventory Worksheet

Supply chain woes?

It seems that the serious supply chain problems we were experiencing in previous months have eased up some, but you may still be having trouble stocking some items. We hope this isn’t affecting you too much. 

QuickBooks Online, though, can help ensure that you know ahead of time when you must reorder. Its inventory-tracking capabilities can also alert you to items that aren’t selling well, so you don’t get overstocked on anything. And the ability to pull up product and service records when you’re creating transactions saves time and keeps your inventory levels accurate. Please let the Outsourced Accounting team know if you need assistance with this element of your accounting or any of QuickBooks Online’s other tools.

Article
How QuickBooks Online tracks products and services

Read this if you are responsible for cybersecurity at your organization.

Cybersecurity threats aren’t just increasing in number—they’re also becoming more dangerous and expensive. Cyberattacks affect organizations around the globe, but the most expensive attacks occur in the US, where the average cost of a data breach is $9.44 million, according to IBM’s 2022 Cost of a Data Breach Report. The same report shows that the cost of a breach is $10.10 million in the healthcare industry, $5.97 million in the financial industry, $5.01 million in the pharmaceuticals industry, and $4.97 million in the technology industry.

Cyber threat actors are a serious danger to your company, and your customers, stakeholders, and shareholders know this. They expect you to be prepared to defend against and manage cybersecurity threats. How can you demonstrate your cybersecurity controls are up to par? By obtaining a SOC for cybersecurity report.

What is a SOC for cybersecurity report?

It provides an independent assessment of an organization’s cybersecurity risk management program. Specifically, it determines how effectively the organization’s internal controls monitor, prevent, and address cybersecurity threats.

What’s included in a SOC for cybersecurity report?

The report is made up of three key components:

  1. Management’s description of their cybersecurity risk management program, aligned with a control framework (more on that below) and 19 description criteria laid out by the AICPA.
  2. Management’s assertion that controls are effective to achieve cybersecurity objectives.
  3. Service auditor’s opinion on both management’s description and management’s assertion.

Why should you consider a SOC for cybersecurity report?

A SOC for cybersecurity report offers several important benefits for your organization, which include:

  • Align with evolving regulatory requirements. The cybersecurity regulatory environment is constantly evolving. In particular, the SEC’s cybersecurity guidelines are becoming stricter over time. A SOC for cybersecurity report can demonstrate you’re aligned with these guidelines. If you’re a public company or are considering going public in the future, you need to be prepared to meet not just the SEC’s guidelines of today, but their evolved guidelines in the future.
  • Keep your board of directors informed. Your board is responsible for ensuring the business is effectively addressing and mitigating risks—and that includes cyber risk. A SOC for cybersecurity report offers your board a clear and practical illustration of your organization’s cybersecurity risk management controls.
  • Attract and retain more customers. It’s becoming increasingly common for companies to require that their vendors have a SOC for cybersecurity report. Even for companies that don’t require such a report, it’s important to know their vendors are keeping their data safe. Having this report differentiates you from vendors who have not prepared one.
  • Improve your cybersecurity posture. A SOC for cybersecurity report can identify current gaps in your cybersecurity risk management program. Once you’ve addressed these gaps, you can show your customers, stakeholders, and shareholders that you’re continuously improving and evolving your cybersecurity risk management approach.

How do I prepare for my SOC for cybersecurity assessment?

There are several steps you should take to prepare for your assessment.

  1. Choose your control framework. You have several options, including the NIST Cybersecurity Framework, ISO 27002, and the Secure Controls Framework (SCF). There are multiple online resources to help you choose the framework that’s right for your organization.
  2. Determine who your key internal stakeholders are for your cybersecurity risk management program. You’ll need to select a point person to be responsible for ensuring the independent services auditor has all the documentation they need to complete their assessment and act as liaison across internal and external stakeholders.
  3. Collect all cybersecurity-related documentation in one location. Make sure you have an organizational system that makes sense to your point person so it’s easy for them to pull the appropriate materials to give to the independent services auditor.
  4. Conduct a readiness assessment. You can work with an independent services auditor to conduct such an assessment which will identify gaps you can address before performing the attestation.
  5. Select an independent services auditor to perform the attestation. SOC for cybersecurity services are provided by independent CPAs approved by the AICPA. Ideally, you’ll want to select a firm that is experienced in your industry, has a diverse and robust team of cybersecurity professionals, and is accessible when and where you need them.

As always, if you have questions about your specific situation or would like more information about SOC for cybersecurity services, please contact our IT security experts. We’re here to help.

Article
Yes, you need a SOC for cybersecurity report—here's why

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

With autumn now in full swing the NFP tax team finds itself in the calm before the storm with the 990 filing deadline on August 15 firmly in the rearview mirror and the November 15 deadline looming—much like winter. This brief lull between deadlines allows for a period of reflection. I myself have been reflecting on some of the issues I’ve seen over the past filing season on Form 990s, which I felt compelled to share. Here is my top five list of observations of this year's Form 990 filings.

Schedule B reporting

By now, most are familiar with Schedule B of Form 990. One of the lone holdouts from the pre-2008 “old” Form 990 (back when we only had Schedules A & B, now Schedules A all the way to R), Schedule B generally requires organizations to list out any donor who contributed $5,000 or more to the organization during the year.

While the disclosure appears straightforward, one of the variables that did change back in 2008 was that Schedule B is now required to be reported on the same accounting method as the organization’s books and records, and not exclusively on a cash basis, as was the requirement under the old rules.

Often-times we find that certain sections of the 990 information request are divvied up and completed by different organizational departments, with Schedule B often being tasked to the folks in the organization’s development/fundraising department. Because of this, we sometimes receive back information that is not reported correctly.

Unfortunately, the only way we know if there’s any issue is if total contribution income on the financial statements is less than is what is being reported to us on the Schedule B worksheet. Almost always, we find there’s a donor (or two) making payments on an amount previously pledged and the amount of cash received in the current year is being disclosed on Schedule B, which is incorrect. 

(Note: the example above implies the organization is on the accrual method of accounting, therefore the amount pledged was recorded as revenue when pledged. Subsequent payments on said pledge would not be recorded as revenue, causing the disconnect between contribution income for financial statement purposes and what is reported as contributions on Schedule B).

The rule of thumb is that organizations should follow what was recorded as contribution revenue during the year on the books (whether on a cash or accrual method of accounting) and then compile your list of donors from there. We could debate all day the somewhat intrusiveness of the Schedule B disclosure requirements, so we only want to disclose those that must be shown.


Conflicts of interest

It’s considered a best practice for all NFPs to check for any conflicts of interest (specifically with members of governance and management) at least annually. While most organizations do this diligently and far more often than once a year, I want to point out that the 990 has an entire schedule devoted to reporting of “interested persons”—that being Schedule L. Interested persons go beyond just corporate officers and members of the board; they also can be family members as well as business entities that are more than 35% owned or controlled by any of the above. Your organization may want to review your procedures as to how you identify potential conflicts to make sure you are also capturing these sorts of relationships.

Reporting thresholds for Schedule L disclosure can vary. If, for example, a board member’s child works for the organization and is paid more than $10,000, they are required to be disclosed and the board member is not considered to be independent by the IRS. Transactions with a business entity owned or controlled by an interested person has reporting thresholds of $10,000 for a single transaction, or $100,000 over the course of the year.

We offer a detailed conflict of interest survey that addresses these questions and more. If interested to learn more about this, please speak to your engagement principal.

Compensation to unrelated organizations

It seems more and more each year we hear some variation of the following: “X sits on our board and works here at the organization, but we don’t pay him/her directly—we pay their company.”

It’s important to know the IRS closed up this reporting loophole long ago and requires organizations to report the amounts paid to an unrelated organization for services they render as if you paid the individual directly. A narrative is also required on Schedule J explaining the arrangement. We find in most cases the organization may not be aware of what exactly X receives for compensation, which is perfectly fine. The narrative on Schedule J can explain this and that what’s being reported as compensation to X is the amount paid to the unrelated organization, and not necessarily what X’s compensation is. In any event, it is not appropriate to say that X receives nothing.

Fundraising events

COVID-19 certainly put a damper on most, if not all fundraising events over the past few years, but we’ve started to see some of events come back on the calendar recently, which is a great sign! Just a friendly reminder that if the price of admission to the event is $75 or more, it is necessary to note what items of value a participant is receiving in exchange for the amount of money they pay to attend so they can determine what amount, if any, of their entrance fee is tax deductible.

For example: An organization hosts a golf tournament and charges $100 per person to play. In exchange, the person gets use of a golf cart, a round of golf, and some food/drink on hole 19. The fair market value of everything per person totals $85. In this case, only $15 is tax deductible as a charitable contribution ($100 paid minus $85 value received) and the $85 of value received must be relayed to the attendee.

Should you have any questions as you begin to plan your next round of events, please do not hesitate to reach out to us.

Alternative Investments and Unrelated Business Income (UBI)

What top five list would be complete without at least a mention of UBI? During the pandemic, we saw many clients get more creative in terms of generating revenue sources, particularly in terms of alternative investments that typically come in the form of a partnership interest and can carry with them significant tax consequences, which are not always brought to the forefront at the time the investment is made. More than a few clients have been more than surprised (and less than impressed) to receive a Schedule K-1 at the end of year which not only contains UBI, but UBI that is spread over six different states, some, or all of which may require you to file tax returns. If the alternative investment happens to be domiciled overseas, that can bring with it its own set of obligations. You can read more about this here

It is vital for all organizations to be engaged in open and frequent communication with their investment managers and advisors (both within and outside the organization) to help ensure a full understanding of what sorts of obligations may stem from an investment. Organizations are strongly encouraged to review and share all relevant investment documentation and subsequent information (i.e., prospectus and any other offering materials) with its finance/accounting department, as well as its tax advisors prior to making the investment.

Just some things for you to think about as the next 990 filing deadline will be here before you know it. I hope you all enjoy the cooler temperatures and colorful foliage, and you all find some time to do whatever it is that brings you joy and peace. As for me, I think it’s time to get a hobby! 

If you have any questions about your specific situation, please feel free to contact our not-for-profit tax team.

Article
990 filing: Considerations for not-for-profit organizations

Read this if you are at a Medicaid agency.

After attending this year’s NASHP Conference, I realized Seattle wasn’t the only gem I found. The city welcomed a record number of NASHP attendees, including many first timers, who brought with them a passion for the vital work they do to support Medicaid and health and human services agencies across the nation. Executive Director Tewarson led her first conference with finesse, and the entire conference exemplified her team’s passion and dedication to state health policy. 
 
The 35th annual conference was full of fresh ideas and a collaborative spirit. As I reflect over the three days of the conference, some ideas I am taking back to my team include:

  • Workforce challenges are here to stay—and are only becoming more severe, requiring states to rethink hiring, training, and staffing among healthcare providers at all levels. Actions to consider:
    • Work to help ensure we allocate appropriate funding for behavioral health and clinical staff. 
    • Encourage more diversity in the field. This means having more representation in the workforce for new hires to identify with, including recruiting and training staff, so they feel welcome and encouraged to join.
    • Increase support for highly skilled jobs like CNAs and childcare workers. Our system cannot work without these staff, and the skills they bring to the table are crucial to the field, developed over time, and indispensable.
    • Start planning now to address the potential loss of childcare dollars to avoid exacerbating the workforce shortage challenges.
    • Identify other ways to help the workforce with benefits and support that can go a long way toward recruiting and retaining experienced caregivers. 
  • Disparities in health equity were always there, and the pandemic laid them bare. 
    • We need to assess the impact of all initiatives to help ensure they aren’t creating additional health inequities and develop strategies to rectify existing barriers.
    • We should bring those experiencing health inequities to the table, listen to their struggles, and let them lead us to solutions.
    • We need to build a diverse workforce that will bring more voices and ideas into the room in this arena.
  • There is a lot of innovative work going on in child behavioral health that can impact outcomes:
    • Providing youth mental health first-aid training and trauma-informed training to school-based, nonclinical staff is crucial to addressing the children’s behavioral health crisis. Children spend so much time at school and build trust in teachers, bus drivers, custodians, and administrative staff.
    • Training school staff on the use of mobile crisis units to avoid children inappropriately becoming involved in the juvenile justice system or being treated in emergency rooms.
    • Putting clinical staff in schools, even via telehealth or part-time, has shown positive outcomes for child behavioral health.
  • We may not know when the Public Health Emergency will end. Still, we can spend this time developing and improving our plans for unwinding, setting consistent expectations with our members and meeting them where they are, developing strategies to make successful emergency provisions permanent, and engaging our legislatures now to prepare for the upcoming federal funding gap.
  • The most significant success factor in every session I attended was breaking down silos across health and human services agencies. We need to continue working across programs, agencies, and states to help ensure we are innovating, growing, and providing the best care for those our policies and programs serve.
  • Lastly, as a foster-adopt mom, I was heartened to hear the speakers consistently bring the topic back to focus on some of our most vulnerable youth: children in foster and kinship care and our justice-involved youth. The call to collaboration and partnerships across child welfare, juvenile justice, public health, county health departments, and Medicaid agencies to impact change was not lost on me, and I found my passion for improving our foster care system invigorated by the passion of those around me.

I am thankful for organizations like NASHP that help us come together to innovate and collaborate on the biggest problems facing our industry today. NASHP’s mission to support the development of policies that promote and sustain healthy people and communities, advance high-quality and affordable health care, and address health equity is needed now more than ever. The 2022 conference allowed us to collaborate and share innovations that can be used to help propel us in our essential work to improve the health and lives of the individuals we serve.
 
My biggest takeaway was that we are stronger when we work together. I’m excited to hear what your biggest takeaways were this year. It has energized me to continue this critical work to help Medicaid agencies improve the health and lives of our residents. I do not doubt that this group will take back all the lessons and work to improve the lives of the residents of their states, and we will all gather in Boston next year, excited to hear of all the new successes. See you next year!

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NASHP meets the Emerald City

Read this if you are at a state agency looking to implement or improve your 988 Suicide & Crisis Lifeline. 

Between 2015 and 2020, one in four fatal police shootings involved a person with a mental illness, and an estimated 44% of people incarcerated in jail and 37% of people incarcerated in prison had a mental health condition. In addition, the recent COVID-19 pandemic has adversely impacted the mental health situation in the country. 

Many people experiencing mental health distress call 911 because it is a widely known emergency number and easy to use. Recent data has shown that people using 911 to get help with serious mental illness do not get the right care at the right time and some even end up in law enforcement custody, rather than being seen by a mental health professional.

The 988 Suicide & Crisis Lifeline (formerly known as the National Suicide Prevention Lifeline) is the new three-digit, nationwide phone number that is locally operated and offers 24/7 access via call, text, and chat to trained crisis counselors who can help individuals experiencing mental health-related distress. Mental health-related distress can include substance use crisis, suicidal thoughts, depression, or any emotional distress. The 988 Suicide & Crisis Lifeline is also available for individuals worried about a loved one who might need crisis support services. Its goal is to provide accessible and immediate crisis intervention and support to every individual in need. 

988 state implementation and top challenges

As of August 2022, 23 states have passed legislation to facilitate the implementation of the 988 Suicide & Crisis Lifeline. Colorado, Nevada, and Washington enacted legislation with user fees to support 988 operations and provide financial sustainability for the system. Several states have established advisory groups or planning committees with representatives from state agencies, health providers, law enforcement, emergency medical services, and other partners to better coordinate the system and identify policy levers. 

Implementing a three-digit number for behavioral health emergencies in every state and providing 24/7 primary coverage through in-state call centers have presented certain challenges to states across the nation. As states prepare to launch the 988 hotlines, they have encountered key issues around infrastructure, workforce, 911 integration, readiness of the crisis care continuum, cultural competence, and performance management.  

Solutions for state agencies

To address these key issues, states should consider the following to aid in the successful implementation of the 988 Suicide & Crisis Lifeline:

Assess the states’ needs to successfully implement the 988 Suicide & Crisis Lifeline

Despite meeting baseline requirements for the implementation of the 988 Suicide & Crisis Lifeline, state agencies are struggling to implement the 988 Suicide & Crisis Lifeline. 

By performing a structured needs assessment, state agencies can evaluate their infrastructure, policies and procedures, funding, and workforce needs to better understand their readiness to implement and capability to sustain the 988 Suicide & Crisis Lifeline. This assessment provides insight for state agencies to understand their strengths, challenges, and areas of opportunity, and it should evaluate: 

  • State infrastructure
    Behavioral health leaders acknowledge that infrastructure supports are necessary to make the 988 Suicide & Crisis Lifeline work across the continuum of care. It is important to assess the infrastructure across the crisis care continuum to help ensure a smooth transition for individuals who need care quickly. Successful implementation should take certain considerations into account during the planning process, such as including all the interested parties representing diverse populations.
  • Workforce
    In the current labor market, workforce availability and retention are top concerns for sustainable and effective 988 Suicide & Crisis Lifeline operations. States are struggling to hire the extra staff needed to launch the 988 Suicide & Crisis Lifeline as well as to recruit qualified persons. To realistically implement the system, innovative workforce development and supporting wages to recruit and retain a specialized workforce are critical considerations for the states. Critical components to include in the assessment should include, but are not limited to:
    • Training
      Staff training and proper supervision will be crucial to effectively manage the 988 Suicide & Crisis Lifeline, and states need best practices models for how to best train crisis responders and the call center staff. States should assess the existing training infrastructure to identify ways early on to support the mental health of their 988 Suicide & Crisis Lifeline counselors to reduce the risk for burnout and post-traumatic stress disorder. 
    • Capacity
      Adequate capacity is a key factor to workforce. The assessment should identify the number of qualified workforce available for in-person staffing. In the current labor market, it will also be important to consider including the identification of the number of qualified staff able to work remotely. If states would like to consider remote capabilities for the call centers, it will also be important to assess the available technology necessary, as well as the development of standards and expectations, including strong communication. 
  • Readiness of the crisis care continuum
    Apprehension about the readiness of the crisis care continuum (e.g., mobile crisis teams through diversion services and lower levels of care) exist. Federal officials have stated they expect up to 12 million calls/texts/chats in the first year of the 988 Suicide & Crisis Lifeline, and research suggests approximately 20% of those calls/texts/chats will require some level of in-person response. States are questioning whether mobile crisis teams are prepared for the increased demand while also identifying connections and access to upstream services. In addition, states can consider the needs and experiences of the system’s end users to help address equity. The assessment can help to assess the readiness of the various components across the crisis care continuum.

Establish a strategic plan of action to implement the 988 Suicide & Crisis Lifeline 

With the implementation of the 988 Suicide & Crisis Lifeline, state agencies have an opportunity to strengthen crisis care. The best way to begin strengthening crisis care is to develop and implement strategic plans that optimize the 988 Suicide & Crisis Lifeline and the following services. Building on the strengths and opportunities identified in the needs assessment and the associated recommendations, strategic plans can establish priorities and identify sustainable solutions that build capacity, promote equitable access to care, and promote continuous quality improvement. Collaborating with key stakeholders to develop a strategic plan can help identify a roadmap for how the state should approach the implementation, maintenance, and sustainability of the 988 Suicide & Crisis Lifeline, including, but not limited to, the following areas:

  • Data and performance management
  • Stakeholder engagement
  • Health equity
  • Voice of the customer
  • Financial sustainability

Maximize available funding streams

Historically, behavioral health has not had sufficient funding to adequately address mental health and substance use disorder prevention, treatment, and recovery services across the continuum of care. The COVID-19 pandemic exacerbated behavioral health challenges for many individuals struggling and highlighted the challenges with the infrastructure and workforce. In the last couple of years, the federal administration has continued to allocate additional funding to supplement existing and ongoing federal funding. States should begin by evaluating the existing federal funding opportunities to support the implementation of the 988 Suicide & Crisis Lifeline. According to the Substance Abuse and Mental Health Services Administration’s (SAMHSA) 988 Convening Playbook for States, Territories, and Tribes, below are a few examples of funding sources that can be leveraged for the implementation of the 988 Suicide & Crisis Lifeline. 

  • SAMHSA 
    • Transformation Transfer Initiative
    • Community Mental Health Services Block Grant
    • Substance Abuse and Treatment Block Grant
    • Mental Health Block Grant Set-aside
    • State Opioid Response Grant
    • Tribal Opioid Response Grants
  • American Rescue Plan Act (ARPA) of 2021—for Mobile Crisis and Crisis Line Services
  • Medicaid
    • Early, Periodic, Screening, Diagnosis, and Treatment (known as EPSDT)
    • 1915(a) waivers
    • 1915(b) waivers
    • 1115 SMI/SED Service Delivery Waiver

The implementation of the 988 Suicide & Crisis Lifeline is critical to supporting the community and meeting their needs at a time where they need community support the most. If you have any questions, please contact BerryDunn’s behavioral health consulting team. We’re here to help.

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Components of successful implementation of the 988 Suicide & Crisis Lifeline