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The FDIC has proposed raising several key regulatory thresholds, including those that determine which institutions must comply with Part 363’s audit and internal control requirements. The primary driver behind these proposed changes is the growth experienced by institutions since the original thresholds were set decades ago. Due to inflation, the proposal aims to cover a similar number of institutions as when the thresholds were originally set. For example, the proposed increase to $5 billion for the Internal Control over Financial Reporting (ICFR) threshold, as described below, would still cover approximately 75% of institutions today.  

In addition to increasing these thresholds, the proposal also recommends that the thresholds be automatically adjusted based on some inflationary factors going forward. While the changes are designed to ease compliance burdens for smaller institutions, they also come with a cautionary tale—they would reduce regulatory requirements, but not the risk. 

What the FDIC proposal means 

Under the proposal: 

• Approximately 800 institutions may find themselves newly exempt from Part 363 compliance due to changes in 24 regulatory asset thresholds. The following items are the most likely to be relevant for community banks:

  • Banks under $1 billion in total assets would no longer be required to: 

    • Create a separate audit committee as part of the institution’s board of directors

    • File annual reports 

  • Banks under $5 billion would no longer need to: 

    • Include management assessments or auditor attestations on ICFR 

    • Require the audit committee directors to be independent from management 

    • Require the audit committee directors to include members with banking or related financial management expertise, have access to its own outside counsel, or exclude large customers of the institution 

  • Audit committee independence criteria would increase from $100,000 to a $120,000 compensation threshold. This threshold would not be indexed against inflation as it is meant to align with the listing standards of national securities exchanges. 

• Parts 303, 335, 340, 347, and 380 would also have changes if this proposal is enacted: 

• Part 303 – de minimis thresholds: 

• Increased from $1,000 to $1,225 and from $2,500 to $3,500 for certain criminal offenses 

• Part 335 – Insider loan disclosures: 

• Raised the threshold from $5 million to $10 million 

• Parts 340 & 380 – Asset sales restrictions: 

• Raised the “substantial loss” threshold from $50,000 to $100,000, which could allow an increase in potential bidders who are eligible to purchase failed institution assets 

• Part 347 – International banking: 

• Raised limits for foreign underwriting and dealing from $60M to $120M and from $30M to $60M. This is less likely to have an impact unless you have foreign operations. 

Why ICFR still matters for community banks 

Even without a federal mandate, effective ICFR offers tangible benefits: 

1. Fraud prevention: Segregation of duties, account reconciliations, and control monitoring are critical to detecting and preventing fraud—especially in lean staffing environments. 

2. Operational efficiency and reducing material misstatements: ICFR can help identify process inefficiencies and reduce errors. It can also help with training, as processes tend to be more clearly documented when they are being tested on an ongoing basis. 

3. Regulatory confidence: Examiners still expect clear documentation of key controls and risk assessments—even if an ICFR opinion is no longer required. 

4. Merger and acquisition readiness: Strong internal controls enhance bank value in due diligence settings, especially in today’s consolidation-driven environment. 

5. Board-level accountability: Internal controls provide visibility into operational risk that supports informed governance and oversight. 

6. Preparing for the next threshold: Many hours have been spent getting your documentation ready for audits, including creating, updating, and monitoring your internal controls. Walking away from the effort already put forth would mean a significant amount of time and resources to re-establish your documentation and controls as you prepare for the next threshold. Keeping your current internal practices in place with annual updates and regular monitoring will help make that next transition as smooth as possible. 

What we recommend 

For banks that would be newly exempt under the FDIC’s proposed changes, we suggest a right-sized, risk-based approach: 

• Maintain documentation of your key accounting controls and processes, including reconciliations, journal entries, and credit loss provisioning. This documentation should be updated at least annually by control owners. 

• Conduct periodic walkthroughs of high-risk processes (e.g., wire transfers, loan approvals) to identify gaps, inefficiencies, and areas of documentation that need to be updated. 

• Leverage internal or outsourced testing of controls. The frequency of this testing will likely be dependent on your institution’s risk assessment of each operational area. 

• Educate your board on how ICFR practices support accountability, even without formal reporting requirements. 

• Create a compliance checklist related to threshold changes to stay up-to-date with compliance requirements going forward: 

• Indexing monitoring plan 

• Establish a process to track inflation-based threshold changes: 

• Every 2 years, or 

• More frequently if the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) rises above 8%. Thresholds will not be reduced in deflationary periods. 

• Assign responsibility for monitoring CPI-W and updating compliance scope 

• Governance and board oversight 

• Reassess audit committee composition and independence under new thresholds 

• Review director compensation against the $120,000 independence threshold 

• Document any changes to board and/or audit committee structure or oversight responsibilities 

• Audit planning adjustments 

• Revise audit scope and frequency based on updated regulatory requirements 

• Coordinate with external auditors to align expectations and engagement terms 

• Adjust risk assessments to reflect changes in compliance burden and oversight 

• Reporting and documentation 

• Ensure proper documentation of decisions not to file Section 19 applications due to new thresholds 

• Maintain records of threshold applicability reviews and indexing updates 

• Prepare for potential regulatory inquiries regarding compliance scope changes 

• Stakeholder communication 

• Brief the board on regulatory changes, compliance impacts, and audit committee implications 

• Provide training or guidance to relevant teams (e.g., HR, compliance, finance) 

Final thoughts 

We understand the burden of ICFR compliance—and for many small banks, the relief reduces their already heavy regulatory burden. However, a move to step away from a well-established control environment has the potential to create downstream issues you might not see until it’s too late. 

Strong internal controls are not just a box to check for regulators and auditors—they're a tool for protecting your institution, your people, and your reputation. Regulators, investors, and auditors still care about the strength of your bank’s control environment—whether or not it's required by regulation. 

Maintaining strong internal controls remains a best practice—and a strategic imperative. Both are essential to your bank’s resilience, integrity, and long-term success. 

Let’s talk 

If your bank is approaching a new threshold or deciding whether to scale back ICFR documentation, we’d love to help you build a right-sized internal control approach that matches your risk profile. Reach out to our team with questions. 

Changes are brewing in the healthcare industry due to far-reaching federal reforms. With the One Big Beautiful Bill Act (OBBBA) now signed into law—alongside Executive Orders (EO), judicial rulings, and other federal actions—providers are facing a wave of new requirements and opportunities. This article highlights some of the changes affecting the industry and offers a comprehensive, downloadable summary for a closer look at key impacts. 

Overview of OBBBA impacts 

• A new Rural Health Transformation Program has been created to address anticipated losses faced by rural health providers due to the cuts to Medicaid. 

• Significant changes to Medicaid, including:  

• New work requirements 

• Increased eligibility redetermination requirements

• Provider taxes 

• State-directed payments 

• Physician fee schedule 

• Affordable Care Act: Enhanced advanced premium tax credits will expire December 31, 2025.  

Other federal reforms impacting healthcare 

• Tariffs: Expected to increase costs for medical devices and pharmaceuticals made in Mexico, Canada, China, and other nations facing double-digit tariffs. 

• Pharmacy Benefit Manager (PBM)/Pharmacy ownership: Federal court blocked an Arkansas law that called for an end to PBM vertical integration. 

• US Department of Health and Human Services layoffs: The US Preventive Services Task Force is being considered for potential layoffs. 

• Health insurance premiums: Commercial health insurance companies are seeking double-digit increases for premiums for the upcoming year, as well as assessing the viability of their governmental plan offerings. 

For an in-depth look at the impacts of the OBBBA, EOs, and other federal government and judicial actions affecting the healthcare industry, we encourage you to download this full summary created by BerryDunn's industry experts. 

Our healthcare team will continue to monitor developments and offer guidance to help you navigate the changes.  

About BerryDunn 

From labor shortages to regulatory changes, today’s healthcare organizations face greater challenges than ever. Our audit, tax, clinical, and consulting professionals, focused on specific healthcare industry areas, understand these challenges and are committed to helping you meet and exceed regulatory requirements, maximize your revenue, minimize your risk, improve your operations—and most importantly—facilitate positive outcomes. Learn more about our team and services. 

Imagine this: You’re at a family reunion and Uncle Bob decides to use the college fund to pay for a bouncy castle “because the kids looked bored.” Sure, it worked, but now the college fund is short—and Bob’s in hot water. That’s essentially what the US Department of Housing and Urban Development’s (HUD) PIH Notice 2025-14 is trying to stop (minus the bouncy castle). 

In its newly released PIH Notice 2025-14, HUD lays out clear guidance for Public Housing Agencies (PHA) on how to properly manage, report, and safeguard Operating Funds—especially when using centralized accounts like PayMaster or Revolving Fund Accounts. Think of this as the rulebook that keeps Uncle Bob from dipping into the wrong piggy bank. 

This article will share the main takeaways from the Notice. 

What is PIH Notice 2025-14 about? 

The notice is aimed at PHAs managing public housing funds, including those in the Moving to Work (MTW) program. It provides detailed instructions on the acceptable use of Operating Funds, how to structure centralized accounts, and how to avoid misusing restricted funds. 

Key highlights 

• Operating Funds are sacred (and restricted): These federal dollars must only be used for eligible public housing expenses. No crossing the streams with other programs unless HUD explicitly says it's okay. 
• Centralized accounts need guardrails: While PHAs can use pooled bank accounts to streamline spending, they must track every dollar, making sure each program’s money is spent correctly and reported cleanly. 
• New rules for Financial Data Schedule (FDS) reporting: 
  • Certain line items (e.g., Lines 144, 172, 347, 352) now have updated definitions and require justifications if classified as long-term. 
  • Inter-program balances must be settled to avoid being misreported as cash. 
  • Misuse or reclassification of restricted funds could lead to program noncompliance and penalties. 

Best practices required 

To stay compliant, PHAs must adopt strong internal controls and financial management practices. This includes regular reconciliation of accounts, clear documentation for centralized payer accounts, and ensuring that all transactions are authorized, compliant, and properly recorded. Think of it like running your own business—you wouldn’t want your intern paying the electric bill with Monopoly money, right?  

Common pitfalls to avoid 

HUD is clear about what not to do. PHAs should never use Public Housing funds to cover other programs—even temporarily. Advancing funds beyond the allowed expenditure rate is also off-limits. Long-term balances must be documented and justified, and inter-program debts should not be written off without HUD’s explicit approval. 

Consequences 

Noncompliance with these guidelines can lead to serious consequences, including sanctions, repayment obligations, or direct HUD intervention under the US Housing Act. In other words: if you mess up the books, HUD might just shut the whole party down. 

In summary 

PIH Notice 2025-14 is HUD’s reminder that good accounting isn’t optional—it’s essential. By setting firm expectations for how Operating Funds can be used and reported, HUD aims to keep PHAs transparent, compliant, and financially healthy. 

So, before you let Uncle Bob anywhere near your budget spreadsheets, give this notice a thorough read. 

At BerryDunn, we understand that affordable housing organizations are unique and dynamic organizations with specific challenges and opportunities. Our commitment to specialization provides our clients with a team of specialists who understand the complex accounting, regulatory, and tax issues of affordable housing organizations. Learn more about our services and team.  

Read this if you are involved in preparing or reviewing government financial statements or capital asset disclosures. 

In today’s governmental accounting space, transparency isn’t just a best practice; it’s expected. Internal and external users rely on financial statements not just for numbers, but for a clear and concise picture of how a government is managing its assets and planning for the future. To support this level of clarity, the Governmental Accounting Standards Board (GASB) released Statement No. 104, Disclosure of Certain Capital Assets, in September 2024. 

This new standard doesn’t alter how capital assets are measured or recorded, but it raises the bar on how governments disclose them, specifically when it comes to leases, Subscription-Based Information Technology Agreements (SBITAs), intangible assets, and assets that are being considered for sale. Whether you are involved in governmental accounting, policy setting, or audit, GASB 104 is a standard that deserves your attention.    

A unified framework for disclosing assets 

Over the last decade, GASB issued several new standards like GASB 87 on leases, GASB 94 on public-private partnerships, and GASB 96 on SBITAs that brought right-to-use assets into the spotlight. However, until now, there hasn't been a unified framework for how to disclose these newer types of assets in the capital assets footnote. In addition, guidance around capital assets held for sale was missing. Governments often hold buildings, land, or equipment for sale, but users of the financial statements rarely saw this activity clearly disclosed. This made it difficult for financial statement readers to assess liquidity, asset management, and overall long-term financial health. GASB 104 closes those gaps. It enhances the capital asset disclosures required by GASB 34 and adds new rules for how to handle assets that are expected to be sold. 

GASB 104 requirements 

Here’s a breakdown of what the standard requires governments to do: 

• Disclose lease assets under GASB 87 separately, by major class of the underlying asset. 

• Disclose right-to-use assets related to public-private or public-public partnerships under GASB 94 separately.

• Disclose subscription-based IT assets under GASB 96 distinctly from other capital assets. 

• Break out other intangible assets (i.e., software, trademarks, licenses) by major class. 

• Disclose information about capital assets held for sale, including their cost, depreciation, and whether they’re pledged as collateral. 

To be considered “held for sale,” an asset must meet two criteria: 

1. The government has decided to sell it. 

2. It is probable the sale will happen within one year of the financial statement date. 

If those criteria are met, the asset must be disclosed in the notes; however, it should still be classified under its original capital asset category.  

Key considerations 

As your organization prepares for implementation, here are things to keep in mind: 

• Right-to-use vs. owned assets: Users analyze these differently. Leased or subscription-based assets may not carry the same risks or benefits as owned assets, and that distinction matters to financial statement users. 

• Classifying intangible assets: Intangible capital assets should not be grouped with physical ones. Governments need to carefully categorize and disclose each major type separately. 

• Evaluating assets held for sale: Determining “probability of sale within one year” requires professional judgment. Consider legal approvals, marketing activity, and market conditions when making this decision. 

• Debt collateral: If a capital asset held for sale is tied to outstanding debt, that linkage must be disclosed. This helps users understand which future asset sales are already marked for debt repayment. 

Real-world examples 

GASB provided examples to illustrate certain requirements of this Statement. According to GASB: 

• “The examples are illustrative only and are not intended to modify or limit the requirements of this Statement or to indicate the Board’s endorsement of the policies or practices shown.” 

• “The examples are nonauthoritative and no inferences about determining materiality should be drawn from them.” 

Example 1: Capital assets note disclosure

This example illustrates how a government might present its capital assets note disclosure for governmental activities, reflecting some of the key requirements outlined in this Statement. Alternative formats may also meet the disclosure requirements. 

Example 2: Capital assets held for sale disclosure 

Among the capital assets reported under governmental activities are buildings classified as held for sale. These buildings have a combined historical cost of $8.0 million and accumulated depreciation of $5.0 million. Additionally, they are pledged as collateral for outstanding debt totaling $1.5 million. 

Implementation considerations 

Since GASB 104 is primarily a disclosure standard, it does not affect the recognition or measurement for assets held for sale. That said, there are a few things you’ll want to be mindful of: 

• Inventory your assets: You’ll need to identify lease, subscription, and partnership assets early, especially if they haven’t been disaggregated in past reports. 

• Update templates: Capital asset note disclosures will need formatting changes to accommodate the new categories and detail requirements. 

• Evaluate sale activity regularly: GASB 104 requires you to assess assets held for sale at every reporting period, not just year-end. 

• Coordinate across departments: Accounting may need input from legal, facilities, and IT to assess which assets fall under GASB 104’s scope. 

Essential items to share 

If you’re preparing for a board or council meeting or even speaking with an audit committee, here are some points worth sharing: 

• Why this matters: GASB 104 promotes transparency and improves comparability across governments. It aligns financial reporting with modern practices. 

• What's changing: Disclosures will become more detailed. Expect to see new categories in capital asset notes and clearer reporting around assets planned for sale. 

• Strategic value: These changes aren’t just for compliance. They tell a better story about how your government is managing its resources and planning for the future. 

• No budget impact: This is not a change to how assets are valued or expensed. It’s about giving users better information in the notes. 

  This is also a good time to emphasize that implementation planning is underway and that the organization is aiming for smooth adoption. 

Effective date 

The requirements of GASB 104 take effect for fiscal years beginning after June 15, 2025. Earlier application is encouraged. Governments are also expected to apply the standard retroactively, if practicable. That means adjusting prior-period financial statements to reflect the new disclosures, unless doing so is not feasible. If prior-period restatement isn’t possible, that must be disclosed in the notes. 

Final thoughts 

GASB 104 marks a shift in how governments report their capital assets. It reflects how operations have evolved, especially with the rise of leased assets, cloud-based arrangements, and asset sales as part of an overall financial strategy. While the new disclosure requirements may take some effort to implement, they ultimately serve the broader goal of improving accountability and decision-making. Financial statement users will have better visibility into the types of assets a government controls, how those assets are used, and what the government’s long-term plans look like. 

How BerryDunn can help 

Implementing GASB 104 can be complex, requiring a careful approach to help ensure both compliance and transparency in financial reporting. BerryDunn’s team of governmental professionals iswell well-versed in helping entities evaluate their capital asset disclosures, apply the latest reporting requirements, and prepare clear, accurate financial statements. From assisting with the classification of intangible assets to analyzing assets held for sale and developing updated note disclosures, we offer customized support to meet your needs. Learn more about our team and services. 

Each time I leave another Medicaid Enterprise Systems Conference (MESC), I’m struck again by how impactful this gathering is—both personally and professionally. It’s often said that “if you’ve seen one Medicaid program, then you’ve seen one Medicaid program.” It’s a phrase that gets trotted out now and then to highlight how unique and nuanced these programs are across each of the states and territories. While that’s true to a certain extent, we have so much more in common than we have differences.

There’s something both comforting and energizing about spending a week surrounded by thousands of people (over 2,100 this year!) who share the same commitment to the future of Medicaid. It reminds us that we are not alone. We may all come at this from different perspectives and backgrounds, but the sense of solidarity and camaraderie is a welcome respite in a world of constant change and shifting values.

As many speakers mentioned in varied (and occasionally colorful) language throughout the week, this work we do is hard! It challenges us from all directions and requires us to continuously cultivate resilience, creativity, and a willingness to reimagine what’s possible. That resilience requires us all to balance the demands of this work with time for reflection and self-care.

Continuing the trend we’ve seen in past years, the New England States Consortium Systems Organization (NESCSO) thoughtfully incorporated the theme of balance and wellness throughout the week’s activities. In addition to morning yoga, massages, and a sunrise fun run along the Milwaukee waterfront, this theme shone through in the keynote plenary session that kicked off the week. Dan Harris, retired journalist and author of 10% Happier, set the tone with a candidly heartfelt discussion on the importance of protecting our mental well-being in a high-stress environment. His introduction to the value of meditation was delivered with a great blend of humor and practicality that resonated with this crowd. One of his final points struck me as especially relevant when he reminded us all that “action absorbs anxiety.” Those three words became my mantra for the week and helped me focus my energy as I attended sessions and engaged with various states, territories, and vendors.

With this year’s conference coming directly on the heels of major new legislation impacting Medicaid (HR-1) and recent CMS guidance (SHO #25-003), attendees were understandably focused on topics like looming community engagement requirements, funding changes, and expanded leverage and reuse expectations. As we were reminded in both the keynote and the welcoming remarks from David Huffman, NESCSO’s Executive Director, this is a human program. Everyone needs healthcare, and we must keep those we serve front of mind as we move forward in the coming years. Wisconsin’s Medicaid Director, Bill Hanna, echoed this sentiment when he encouraged participants to be guided by the core values of our respective programs.

This tone of person-centric design and value-driven decision-making carried through many of the sessions. As states and territories discussed leverage and reuse opportunities, there was also a focus on the relationship-building required to make these partnerships successful. As programs shared their approaches to developing and managing MES Advanced Planning Documents (APDs) in response to SHO #23-003, there was a continued emphasis on outcomes and user experience as key performance metrics. This balance—between meeting evolving legislative requirements and focusing on the people at the core of Medicaid (both recipients and the workforce that supports them)—felt like an organic and collective response to the current pressures facing state and territorial programs.

It was exciting to see so many bright and creative program leaders rising up in a proactive, rather than reactive, way to meet the demands placed on us this year. This solution-focused and innovative mindset will be what guides states and territories in the future. CMS shared this sentiment during the closing plenary, voicing appreciation for all the effort shown by states, territories, and their partners to make this program successful. They also acknowledged again that this work is hard.

That truth keeps circling in my mind as I travel home—this work is hard. It’s complicated. It’s occasional fodder for political headlines. It’s also vital and absolutely necessary. Medicaid covers roughly one in five people in the U.S. I think about that as I stand in line at the TSA checkpoint for my flight home and wait in baggage claim to gather my belongings. The people around us in our everyday lives are the people we serve. We all owe it to them to continue working hard to make this program as good as it can be. After this past week, I feel a renewed sense of pride and optimism, having seen all the bright and dedicated people who are working tirelessly to keep Medicaid strong into the future.

Well done, Milwaukee. I—and the rest of the BerryDunn team—can’t wait to see you all next year in Portland, Oregon!