Affordable Care Act

Read this if your healthcare organization cannot fill a vacancy in your compliance department or if your program needs expert consultation services. 

Healthcare organizations are currently facing growing financial challenges and experiencing high staff turnover. Recruiting a compliance officer may prove challenging due to the unavailability of experienced professionals or concerns about salary and fringe expenses. Depending on a healthcare organization’s fiscal health, consideration might be given to downsizing the compliance department. This article offers guidance to healthcare administrators as they ponder several compliance-related what-if scenarios.   

What if your compliance officer has resigned and there are no experienced applicants?   

Did you know that the pool of certified compliance professionals varies by region? In its 2024 Healthcare Chief Compliance Officer and Staff Salary Survey, the Health Care Compliance Association (HCCA) reported that the greatest proportion of Chief Compliance Officers (CCOs) in the United States are based in the South Atlantic, Mid-Atlantic, and Pacific regions. In comparison, the New England region (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont) and East South-Central region (Alabama, Kentucky, Mississippi, and Tennessee) have a smaller pool of CCOs.             

Even healthcare organizations that are based in a region with a greater supply of CCOs may face recruiting challenges. Organizations in non-urban areas, such as rural health centers and critical access hospitals, may be stymied by a qualified pool of CCO applicants who are unwilling to relocate.   

What if your compliance department is a department of one?   

If your compliance department is a department of one, then an unfilled vacancy due to a resignation or leave of absence poses significant risks. Questions to consider: 

• How will your organization handle a compliance coverage gap? 

• How will any unresolved, in-process compliance or privacy investigations be resolved? 

• Who will respond to compliance questions, calls on the compliance hotline, or a potential whistleblower? 

• Who will oversee your organization’s response to government payer audits or investigations?   

Even a fully staffed department of one may need a lifeline on occasion. The HCCA’s 2024 survey found that approximately half of their survey participants had five or fewer years of experience. A novice CCO may need to consult a trusted advisor for guidance as healthcare compliance requirements and payer audits increase in number and complexity. Even an experienced CCO in a department of one who has transferred to a new service delivery line may benefit from having an experienced compliance consultant on call. Segments of the healthcare industry that are heavily regulated, such as Federally Qualified Health Centers (FQHCs) and Certified Community Behavioral Health Clinics (CCBHCs), may be baffling to a seasoned compliance professional who is new to the setting.             

What if you can no longer budget for a full-time compliance officer or need to eliminate your compliance department? 

Salaries for CCOs depend on the healthcare organization’s number of employees, annual revenue, and the type of organization. The HCCA found that compensation increases with an organization’s staffing headcount. For example, a CCO’s salary can range from $138,783 in an organization with 100-249 employees to $163,205 in an organization with 500-999 employees. In the HCCA’s survey, the total compensation of healthcare CCOs in nonprofit organizations was $178,265, which was less than in privately held healthcare organizations ($179,553), governmental settings ($190,743), academic healthcare ($216,291), and publicly traded organizations ($286,019). 

Due to increasing costs, declining revenues, and funding challenges, perhaps your healthcare organization has had to make the difficult budgeting decision to downsize or eliminate its compliance department. If so, then your organization should consider outsourcing its compliance functions. An outsourced compliance officer can provide services that are uniquely tailored to the needs of your organization.  

Need help addressing these compliance what-if scenarios?   

BerryDunn’s healthcare compliance team offers outsourced compliance officer services and on-call consultation across the healthcare continuum. Learn more about BerryDunn’s team and services. 

CMS recently extended the deadline for the mandatory SNF provider enrollment off-cycle revalidation to January 1, 2026.  

As we wrote about previously, CMS issued a significant off-cycle mandate requiring all skilled nursing facilities (SNFs) in the US—both for-profit and nonprofit—to revalidate their Medicare provider enrollment records. Originally due by May 1, 2025, then August 1, 2025, the deadline has now been extended to January 1, 2026, giving facilities additional time to comply. This revalidation is essential to maintain Medicare billing privileges and incorporates more rigorous disclosure requirements than ever before. 

The updated process centers around expanded transparency in ownership and control structures. SNFs must report detailed information on all individuals and entities with ownership or managerial roles, including a new category called Additional Disclosable Parties (ADPs). These include anyone who exercises operational, financial, or managerial control, provides real estate, or delivers services such as consulting or accounting. CMS has updated Form CMS-855A and developed a 20-page SNF-specific attachment to capture this information, along with detailed guidance to help facilities navigate the changes. 

The scope of disclosure has also broadened to include parties with formal and informal influence over SNF operations, such as managing employees, consultants, and organizations with financial or operational oversight. Facilities must report granular data on both individuals and organizations, such as ownership percentages, tax IDs, NPIs, and the nature of their relationship to the SNF. The complexity of these requirements makes it critical for SNFs to assess their internal structures, collect necessary documentation, and continue to evaluate management and other changes on a routine basis. Among the many supporting documents required for this effort, CMS is placing a significant emphasis on an organizational chart that outlines the relationships of all organizations and individuals disclosed within the revalidation application. 

To support compliance, CMS encourages the use of its PECOS online portal for submissions and offers help through various channels. Many SNFs are also turning to legal counsel and credentialing professionals for guidance. Firms like BerryDunn have developed tools and resources to help facilities organize and track the required data. While the new January 1, 2026, deadline allows an additional runway, SNFs are encouraged to complete this recertification as soon as possible. Proactive planning and responding to any additional requests (CMS allows a 30-day window for corrections once applications are submitted) is essential to avoid disruptions in Medicare participation. 

We're here to help 

As you prepare, it can be helpful to work with an experienced team of credentialing professionals who will help you navigate the complex process of meeting the new revalidation requirements. BerryDunn’s Credentialing and Enrollment Team is available to offer guidance and support to client organizations as they collect, organize, and track ownership, control, and ADP information, and to guide them through the CMS revalidation process. Additional CMS resources are available, including a dedicated email, SNFDisclosures@cms.hhs.gov, and PECOS support, via the External User Services (EUS) Help Desk. The Help Desk can also be reached by phone at 1.866.484.8049 or email at EUS_Support@cms.hms.gov. 

This article is based on an episode of the Let's Talk Parks with BerryDunn podcast. Listen to the full episode. 

July is National Parks and Recreation Month, and it’s the perfect time to celebrate the people who transform everyday spaces into places of joy, connection, and belonging. To highlight this year’s theme, ‘Build together, play together,’ members of BerryDunn’s Parks, Recreation, and Libraries team share stories of projects that helped communities thrive—and the personal ways they embrace play in their own lives. 

From bustling cities to quiet towns, parks and recreation departments are shaping the future through thoughtful planning, conservation, and inclusive programming. Their work proves that when we invest in shared spaces, we invest in each other. We are proud to support this meaningful work and to share these successes.  

Strategic planning for community growth 

Communities across America are discovering how intentional parks and recreation planning can spark transformation. In Charles County, Maryland, a comprehensive Land Preservation Parks and Recreation Plan (LPPRP) has become a blueprint for community development. 

“Through leadership and strategic guidance, the planning process brought together various voices throughout the county,” says Lisa Wolff, senior consultant with BerryDunn’s Parks, Recreation and Libraries team. 

In Timnath, Colorado, community feedback didn’t just shape ideas—it drove action. When 95% of residents voiced support for a new recreation center, the town moved swiftly from vision to reality. Ryan Hegreness, who managed Timnath’s Parks, Recreation, and Open Space Master Plan, saw firsthand how listening to residents can accelerate change. 

Meanwhile, in Greeley, Colorado, BerryDunn Manager Nikki Ginger has been impressed with how the strategic investment in master planning and facility assessments is helping the Culture, Park, and Recreation Department strengthen diverse communities and meet evolving needs. 

Preservation and heritage 

Parks aren’t just about play—they’re about protecting what matters. In 2023 alone, Charles County preserved 1,700 acres of farmland and forest, secured $1.7 million in open space grants, and obtained over $380,000 in rural legacy funds for conservation easements. 

These efforts safeguard not only natural landscapes but cultural treasures like Mallows Bay, home to the “Ghost Fleet of the Potomac.” Designated a National Marine Sanctuary in 2019, this hauntingly beautiful spot holds nearly 200 historic shipwrecks—the largest collection in the Chesapeake Bay watershed. 

Recreation and community connection 

Park professionals don’t just build spaces—they create moments. Ryan Hegreness’ local pickup soccer group is a daily ritual that brings together teens, seniors, and everyone in between. “It’s a powerful example of how sports can bring people together—not just during your childhood, but throughout your life,” Hegreness shares. 

Lisa Wolff’s journey began as a “parks and rec kid” in Wilmington, Delaware. Today, she hikes, kayaks, and serves on her local Parks and Recreation Advisory Board. Her story reflects the countless individuals who find friendship, purpose, and joy through recreation. 

Professional impact and leadership 

The influence of parks and recreation stretches far beyond playgrounds—it’s about leadership, vision, and lifelong service. Elsa Fisher, newly elected to the Skokie Park District Board of Commissioners, brings four decades of experience to her role. “I am experiencing local parks and recreation with a new perspective,” Fisher says, highlighting her work in budgeting, park development, and community events. 

For professionals like Lisa Wolff, the work is deeply personal. “The quality of my life matters. And that’s why I celebrate Parks and Recreation Month with excitement and gratitude for a career path that really makes me smile pretty much every day.” 

Happy Parks and Recreation Month!  

From strategic planning to conservation, from pickup games to public service, parks and recreation professionals are building stronger, more connected communities. 'Build together, play together' isn’t just a theme—it’s a way of life. And this July, we honor the people who make it all possible. 

Innovative strategies for parks, recreation, and libraries 

BerryDunn's consultants work with you to improve operations, drive innovation, identify improvements to services based on community need, and elevate your brand and image―all from the perspective of our team’s combined 100 years of hands-on experience. We provide practical park solutions, recreation expertise, and library consulting. Learn more about our team and the services we offer.  

Signed into law by President Trump on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) marks a significant step forward in addressing America’s growing need for affordable housing. With the demand for low-cost units far outpacing supply nationwide, the legislation offers targeted solutions aimed at making development more feasible and sustainable.

Effective starting January 1, 2026, OBBBA enacts two major changes to the Low-Income Housing Tax Credit (LIHTC) program:

• Increases the 9% LIHTC ceiling by 12% — More tax credits will be available for states to allocate toward qualifying projects, meaning developers may have greater access to financial resources.
• Reduces the tax-exempt bond financing threshold for the 4% LIHTC credit from 50% to 25% — This change lowers a key barrier, making it easier for developers to qualify for the 4% credit without needing as much upfront bond financing.

What are the impacts on affordable housing?

These updates are expected to open the door for more developers to build affordable housing by:

• Providing greater funding opportunities, especially for projects that previously fell short of eligibility.
• Making the 4% credit more accessible, helping close the gap between available units and growing demand.
• Encouraging innovation and collaboration across the housing sector, especially at the state and local level.

If you're interested in a deeper dive into OBBBA’s tax implications, be sure to download our full summary to explore the bill’s key provisions and how they may impact your next project.

What to expect at BerryDunn

As consultants to organizations of all sizes throughout the US, our team has a clear understanding of industry best practices. We provide the vital strategic, financial, and operational support necessary to help you fulfill your missions. 

Our team has experience with affordable housing agencies subject to audits under both Financial Accounting Standards Boards and Government Accounting Standards Board. Additionally, we have experience with the various tax credits available to affordable housing agencies, HUD compliance, annual Real Estate Assessment Center (REAC) submissions, and other compliance matters. Learn more about our team and services.

On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. This article summarizes relevant key provisions that impact tax-exempt organizations. 

Expansion of §4960 excise tax 

Internal Revenue Code (IRC) Section 4960 imposes a 21% excise tax on exempt organizations that pay over $1 million in compensation to their five highest-paid employees. The provision also taxes excess parachute payments.  

For tax years beginning in 2026, under the OBBBA this excise tax now applies to all earners of a nonprofit receiving over $1 million in compensation, rather than just the five highest-paid employees. Importantly, this change is retroactive and requires organizations to look at any employee or former employee who was employed during any taxable year beginning after December 31, 2016. The exclusion from this tax for employees providing medical services continues to apply. 

Excise tax on investment income of private colleges and universities under IRC §4968 

IRC Section 4968 imposed an excise tax of 1.4% on net investment income of private colleges and universities that have at least 500 tuition-paying students and at least $500,000 in endowment assets per student. 

Under the OBBBA, for tax years beginning after December 31, 2025, a tiered tax regime has been created dependent on an institution’s “student adjusted endowment” for private colleges and universities that have at least 3,000 tuition-paying students and at least $500,000 in their student-adjusted endowment. The rates are: 

• 1.4% for endowments of at least $500,000 but less than $750,000 

• 4% for endowments of at least $750,000 but less than $2 million 

• 8% for endowments of at least $2 million per student 

Charitable giving for corporations and individuals 

The OBBBA has added several provisions in the realm of charitable contribution deductions for both corporations and individuals, which could impact amounts received by nonprofit organizations in the form of charitable giving. 

For corporations, the OBBBA establishes a 1% floor for charitable contributions, further limiting the charitable contribution deduction amount a corporation can claim for tax purposes. The 10% ceiling for these deductions remains. 

For individuals who itemize deductions, the OBBBA establishes a cap on the overall itemized deductions that can be claimed by high income taxpayers. The OBBBA also creates a 0.5% floor for charitable contribution deductions, meaning that individuals who itemize would be entitled to claim a charitable contribution deduction only if they contribute in excess of 0.5% of their charitable contribution base (AGI before deductions for charitable giving). 

For non-itemizers, the OBBBA provides a tax deduction of $1,000 for single taxpayers and $2,000 for joint filers for charitable contributions, starting in 2026. 

Additional tax changes 

• The use of funds in IRC Section 529 plans has been expanded to cover homeschooling costs, purchase of curricular and online educational materials, tutoring, standardized testing fees, and education-related therapies for students with disabilities. The measure would also cover tuition, fees, and supplies associated with obtaining postsecondary credentials through recognized vocational and certificate programs.  

• The OBBBA has made the tax treatment of moving expenses permanent. Thus, employee-incurred moving expenses are not tax-deductible, and any moving expenses reimbursed by the employer are taxable compensation to the employee. 

• The Paid Family and Medical Leave tax credit has been permanently extended, and enhancements by OBBBA have been made to the credit. 

• $5,250 (to be adjusted annually for inflation) in employer payments of student loans as educational assistance payments have been permanently extended through the OBBBA. 

There were a few proposed provisions specific to the nonprofit sector that were ultimately not included in the final version of the OBBBA, such as the revival of the UBI parking tax as well as increases in the excise tax rate on net investment income for private foundations. However, some of these provisions could potentially be reintroduced in subsequent legislation as Congress looks to find additional sources of revenue. 

BerryDunn’s team of professionals serves a range of nonprofit organizations, including but not limited to educational institutions, foundations, behavioral health organizations, community action programs, conservation organizations, and social services agencies. We provide the vital strategic, financial, and operational support necessary to help nonprofits fulfill their missions. Learn more about our team and services.