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The Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) 2025-08 in November 2025 to address stakeholder concerns regarding the accounting for acquired financial assets under current US GAAP. This update specifically amends the guidance for purchased loans, aiming to improve comparability, consistency, and decision usefulness in financial reporting.

Key differences from current US GAAP  

Under existing US GAAP (Topic 326), acquired financial assets are classified as either:  

  • Purchased Credit Deteriorated (PCD) assets: Accounted for using the “gross-up approach,” which recognizes an allowance for expected credit losses (ACL) at acquisition, offset by a gross-up adjustment to the purchase price.
  • Non-PCD assets: Recognized at fair value with an ACL charged to credit loss expense, which is seen as double counting expected credit losses.  

ASU 2025-08 expands the use of the gross-up approach to a broader population of acquired loans, specifically “purchased seasoned loans.” These are defined as loans (excluding credit cards) acquired without significant credit deterioration and deemed “seasoned”—either obtained in a business combination or purchased at least 90 days after origination, provided the acquirer was not involved in the origination.  

This change eliminates much of the complexity and subjectivity in distinguishing between PCD and non-PCD assets and reduces the risk of double counting expected credit losses that are already reflected in fair value measurements determined at the time of acquiring the financial assets. 

Effective date for ASU 2025-08 

ASU 2025-08 is effective for all entities for annual reporting periods beginning after December 15, 2026, and interim periods within those annual periods. Early adoption is allowed.  

Transition methods 

The amendments must be applied prospectively to loans acquired on or after the initial application date. Early adoption is permitted for interim or annual reporting periods in which financial statements have not yet been issued or made available for issuance. If adopted in an interim period, the amendments should be applied as of the beginning of that interim period or the annual period that includes it.  

Rationale and benefits 

The FASB’s post-implementation review revealed that the dual approach for PCD and non-PCD assets under current US GAAP created unnecessary complexity, reduced comparability, and did not accurately reflect the economics of acquired financial assets. The gross-up approach, now expanded to purchased seasoned loans, better aligns accounting with the economic reality that the fair value of acquired assets already incorporates expected credit losses. This method:  

  • Enhances comparability and consistency across entities.  
  • Reduces complexity and subjectivity in acquisition accounting.  
  • Minimizes the “double count” of expected credit losses, improving the usefulness of financial information for investors and other stakeholders.  
  • Is expected to reduce costs and operational burdens associated with the previous model. 

Journal entry examples 

The following journal entries are meant to display the differences in accounting for acquired loans as a result of ASU 2025-08. Thus, this is a simplified example. Acquisition accounting, particularly for business combinations, tends to be much more complex. Stay tuned for additional resources on acquisition accounting. 

Before ASU 2025-08 (current US GAAP)  
 

A. Purchased Credit Deteriorated (PCD) loan (gross-up approach)  

At acquisition: 

  • Record the loan at purchase price (fair value).  
  • Recognize an ACL.  
  • Increase the fair value by the ACL.   

Journal Entry: 

Dr. Loan Receivable                                          $1,000,000 
          Cr. Cash                                                                        $950,000 
          Cr. Allowance for Credit Losses                                    $  50,000 

(Assume purchase price is $950,000 and ACL is $50,000) 

B. Non-PCD loan (day-one expense approach)

At acquisition: 

  • Record the loan at purchase price (fair value).  
  • Recognize an ACL with a charge to credit loss expense.  

Journal Entry: 

Dr. Loan Receivable                                    $950,000 
Dr. Credit Loss Expense                              $  50,000 
             Cr. Cash                                                                      $950,000
             Cr. Allowance for Credit Losses                                  $  50,000 

(Here, the ACL is recognized as an expense, not as a gross-up to the loan balance.)   

After ASU 2025-08 (for purchased seasoned loans) 
 

All purchased seasoned loans (excluding credit cards) are accounted for using the gross-up approach, regardless of credit deterioration. 

At acquisition: 

  • Record the loan at purchase price (fair value).  
  • Recognize an ACL.  
  • Increase the fair value by the ACL.    

Journal Entry: 

Dr. Loan Receivable                                           $1,000,000 
                 Cr. Cash                                                                  $950,000 
                 Cr. Allowance for Credit Losses                              $  50,000   

(Same as the PCD approach but now applied to a broader population of acquired loans.)  

Improvement in accounting for acquired loans


In summary, ASU 2025-08 represents a significant improvement in the accounting for acquired loans, providing more meaningful and decision-useful financial reporting while streamlining the application of credit loss standards. Although not seen as a cost-burdensome ASU to adopt, as most information needed to adopt the ASU should be readily available, the ASU does introduce a new concept, namely, purchased seasoned loans. Thus, those impacted by the ASU should start assessing its impact now, especially given early adoption may be seen as favorable since the ASU is expected to reduce complexity compared to current US GAAP.  

As always, your BerryDunn team is here to help. Learn more about our team and services, and reach out with questions on the ASU or acquisition accounting. 

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How purchased seasoned loans & ASU 2025-08 impact acquisition accounting

On November 5, 2025, the US Supreme Court heard arguments in Learning Resources, Inc. v. Trump, a case that challenges President Trump’s authority to impose tariffs under the International Emergency Economic Powers Act (IEEPA). If the presidential power to impose tariffs is ruled unconstitutional, importers could qualify for duty refunds and must act fast. A decision is anticipated in late 2025 or early 2026. 

Background 

Under IEEPA, the President may act to address any unusual or extraordinary foreign threat that endangers national security, foreign policy, or the economy in the US. This authority applies only if the President declares a national emergency. Trump declared such an emergency on April 2, 2025, citing the trade deficit and illegal immigration. Since February 2025, the Administration has imposed significant tariffs under IEEPA, including: 

  • 10% minimum tariff on most imports 
  • 50% tariff on copper, steel, and aluminum 
  • 20 – 40% tariffs on most goods from Brazil, India, Canada, Mexico, and China 

President Trump’s use of IEEPA to impose tariffs has raised constitutional concerns. Challengers to this authority argue that IEEPA does not authorize the imposition of tariffs and that only Congress may regulate foreign commerce. 

Key actions for importers 

If the Court finds the presidential power to impose tariffs unconstitutional, importers may be eligible for refunds of duties already paid. However, refund eligibility will depend on timely administrative actions. To prepare, importers should: 

1. Review import activity 
     Identify entries that were subject to IEEPA tariffs. 

2. File administrative protests
    
Submit CBP Form 19 protests within 180 days of each entry’s liquidation. 

3. Prepare for possible litigation 
     If protests are denied, consider filing suit with the US Court of International Trade. 

How BerryDunn can help

Our dedicated audit, tax, and consulting professionals understand the impact of tariffs and can assist with developing strategies for refunds as they become available. Learn more about our team and services.  

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Supreme Court reviews presidential tariff authority: Insights for importers

Read this if you are a CEO, CFO, controller, or finance team leader in the manufacturing industry. 

In a time when operational efficiency and sustainability are more critical than ever, small- and medium-sized manufacturers (SMMs) face a unique challenge—how to modernize without breaking the bank. Fortunately, the US Department of Energy (DOE) offers a solution through its Industrial Assessment Centers (IACs) Program—an initiative that combines expert guidance with financial support to help manufacturers thrive. 

What are IACs? 

IACs are university-based teams that provide free, in-depth energy assessments to eligible manufacturers. These assessments are conducted by engineering faculty and students, typically over a one- or two-day site visit, and include: 

  • Engineering measurements 

  • Detailed process analysis 

  • Specific recommendations with cost, performance, and payback estimates  

After the assessment, companies receive a report with recommendations from the assessment team. 

DOE energy-saving implementation grants 

The DOE’s IAC Implementation Grants Program (also known as the Industrial Training and Assessment Center Implementation Grant Program) offers up to $300,000 per qualified recommendation to help SMMs implement energy-saving projects. These grants cover up to 50% of implementation costs. 

Who qualifies for IAC services and grants? 

Manufacturers must meet eligibility criteria to receive IAC services and grants, including:  

  • Annual revenue: Under $100 million 

  • Energy bills: Annual energy bills between $100,000 and $3,500,000 

  • Workforce: Fewer than 500 employees at the assessed plant site 

  • Ownership: Must have majority domestic ownership and control  
     

BerryDunn can help uncover federal grant opportunities 

At BerryDunn, we help clients uncover opportunities that foster growth. The IAC Program is one such opportunity, especially for companies unfamiliar with federal energy initiatives. The program operates on a rolling basis with relevant deadlines outlined on its website. Whether you're looking to modernize operations or simply improve margins, this program offers a compelling path forward.  

BerryDunn’s team of manufacturing industry professionals offers clients access to global industry knowledge and tailored, practical solutions that address complex operational, investment, risk management, and compliance challenges. We work collaboratively with each client, engaging in close communication to understand current practices and build actionable strategies for short- and long-term success. Learn more about our services and team.  

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Unlocking efficiency: How DOE grants can transform your operations

H.R. 1, previously titled the “One Big Beautiful Bill Act”, represents one of the most comprehensive federal policy changes in recent decades. It touches healthcare, taxes, and social programs, shifting financing and administrative responsibilities across federal, state, and local governments. The Congressional Budget Office (CBO) estimates it will reduce federal Medicaid spending by roughly $0.9 to 1 trillion over ten years and lead to about 16 million fewer people with coverage, split between Medicaid (~7.8 million) and the Affordable Care Act (ACA) Marketplaces (~8.2 million) over the same period. This overview summarizes H.R. 1’s key provisions and their implications for states, consumers, providers, and payers.

Medicaid: Financing and administrative changes

Work requirements. Most adults ages 19–64 must now document at least 80 hours per month of work or a qualifying activity to maintain Medicaid coverage. Individuals who do not verify compliance lose eligibility for both Medicaid and ACA Marketplace premium tax credits. Exemptions apply for pregnant people, caregivers, and those recently released from incarceration, among others. Research shows most adults on Medicaid already work or qualify for an exemption; KFF estimates that in 2023, 64% were employed and over 90% were either working or exempt.

Faster renewals and more verification. Expansion adults must now renew eligibility every six months, and states are required to conduct additional verification and interstate data-matching. These steps are intended to strengthen program integrity by improving the accuracy of eligibility determinations and reducing improper payments. They may also add administrative complexity and raise the risk of coverage loss for eligible individuals—particularly those with unstable housing, limited internet access, or language barriers.

Provider taxes. The federal “safe harbor” cap on provider taxes will decrease from 6% to 3.5%. States have historically relied on these taxes to generate federal matching funds—accounting for about 17% of non-federal Medicaid financing in 2018, or 28% when including local contributions (MACPAC). The lower cap may prompt states to reassess Medicaid financing strategies and weigh trade-offs in how programs are structured.

State Directed Payments (SDPs) and rural care. Beginning in FY 2028, SDP limits will be tied to Medicare rates, reducing states’ flexibility to supplement managed care payments. With roughly $110 billion in annual SDP spending, largely financed through provider taxes and intergovernmental transfers, this change could constrain a key tool states use to support provider networks in underserved areas. Federal Medicaid spending in rural communities is projected to decline by $155 billion over ten years. A new $50 billion Rural Health Transformation Program aims to offset some of these reductions, with impacts dependent upon state capacity and program decisions.

ACA Marketplaces: Subsidies and enrollment

Stricter verification. Consumers must now fully verify income, immigration status, residency, and family size before receiving premium tax credits (PTCs) or cost-sharing reductions (CSRs). Roughly one in five HealthCare.gov enrollments occur through “passive” renewal; ending automatic re-enrollment for individuals with incomplete verification may increase the risk of coverage disruptions.

Full repayment of excess subsidies. Consumers will no longer have caps on how much excess premium tax credit (PTC) they must repay at tax filing. Some immigration categories will lose eligibility for subsidies, and people enrolling outside a qualifying life event will not qualify for financial assistance. Together, these changes may reduce enrollment continuity and raise financial exposure for households with variable income.

Enhanced subsidies expire. The enhanced premium tax credits (PTCs) introduced under the American Rescue Plan Act and extended through 2025 by the Inflation Reduction Act will expire. Beginning in 2026, subsidies will revert to pre-2021 levels, increasing required premium contributions across income groups. These enhancements had boosted Marketplace enrollment by lowering premiums and eliminating the “subsidy cliff” for many middle-income and older adults.

Analyses by KFF and the Urban Institute project that, without an extension, average consumer-paid premiums could more than double in 2026 and coverage could decline by approximately 4.8 million people. Their expiration has become a central issue in ongoing Congressional negotiations during the federal government shutdown. If no deal is reached, higher premiums and reduced enrollment are likely outcomes.

Ending “silver loading.” Insurers have historically increased silver-tier premiums to offset the cost of providing cost-sharing reductions (CSRs), which raised the benchmark used to calculate premium tax credits (PTCs). H.R. 1 ends this practice. Silver premiums would likely decline along with the benchmark—reducing subsidies across all plan tiers. Brookings estimates that current silver benchmarks are about 28% higher because of silver loading; removing it could lower subsidies by a similar amount. While unsubsidized silver-plan enrollees may see lower gross premiums, many subsidized consumers—particularly those in bronze, gold, or platinum plans—could face higher net premiums and greater sensitivity to income fluctuations.

Coordination gets harder. Medicaid and the ACA marketplaces act as complementary coverage systems, with many individuals moving between them as incomes change. Tighter Medicaid eligibility rules and shorter redetermination cycles may increase these transitions. At the same time, reduced Marketplace subsidies and stricter enrollment criteria may limit affordable coverage options for those losing Medicaid—leading to higher churn, uncompensated care, and pressure on risk pools. These dynamics could create coordination challenges for states and insurers as they manage eligibility transitions and enrollment stability.

Medicare: Payments and innovation models

Eligibility and payments. H.R. 1 narrows Medicare eligibility rules, delays implementation of the 2023 Medicare Savings Program enrollment rule until 2034, and links physician payment updates to the Medicare Economic Index, slowing projected growth after 2027. The law also ends enhanced payments for Advanced Alternative Payment Models (APMs), extends orphan-drug exemptions from federal price negotiation, and postpones new federal nursing home staffing standards until 2034. Changes may affect payment stability and innovation pathways—potentially increasing attribution volatility, complicating risk adjustment, and adding operational and financial complexity for organizations participating in value-based or alternative payment models.

Outlook and implications

H.R. 1 marks a broad realignment of federal health policy, tightening eligibility standards, expanding verification and reporting requirements, and revising financing structures across Medicaid, the ACA Marketplaces, and Medicare. Overall, the legislation redistributes financial responsibilities among federal, state, and local entities and is expected to reshape healthcare coverage, financing, and innovation over the next decade.

Better policy through better information

BerryDunn’s healthcare policy and economics team provides the insights government agencies, healthcare policy research groups, and other organizations need to improve healthcare accessibility and affordability. We have the expertise to inform intelligent, impactful decisions related to healthcare payment reform and cost transparency, to the effect of government mandates on population health and insurance costs, and to market competition. We also have a comprehensive understanding of economic and quality issues in behavioral healthcare—including substance abuse disorder treatment—and of mental health coverage parity. Learn more about our team and services. 

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H.R. 1: What state agencies, providers, and payers need to know

Read this article to get a physician's perspective on onboarding from Alan Weintraub, MD.

For a physician beginning a new clinical role, the onboarding process is more than a formality—it lays the foundation for safe, efficient, and high-quality care delivery. Onboarding, particularly surrounding credentialing, clinical privileging, and provider enrollment, is the bridge between a clinician’s availability and their ability to practice. When this process is fragmented or delayed, it doesn’t just frustrate the provider—it impacts patient access, revenue cycles, compliance, and team morale. A seamless onboarding experience signals to clinicians that the organization values their time, expertise, and contribution to the care continuum. In today’s environment, where every dollar and every patient interaction count, the financial impact of a well-executed onboarding strategy is considerable. 

Creating a strategy for clinician onboarding 

Healthcare organization leaders must recognize onboarding as a strategic lever—not a back-office task. A well-planned onboarding journey, from aligning payer contracting timelines to ensuring organizational and NCQA-compliant credentialing workflows, directly impacts patient care. A streamlined onboarding experience reflects an organization’s commitment to operational excellence and clinician support. 

Onboarding is a continuum of processes and procedures that begin from the time a clinician agrees to join the practice or organization and extends through the first six months to a year after hiring. The continuum consists of credentialing, clinical privileging, payer enrollment, and a set of activities and informational components that equip clinicians with the tools to practice effectively with a goal of establishing a long-term relationship. 

The extensive volume of information that clinicians are often asked to submit during onboarding can be overwhelming, especially when it must be provided separately to different offices, organizations, or locations. This “hassle factor” can result in missing data or documents, errors, delayed start dates, or dissuading clinicians from fulfilling their commitment to join. 

What does streamlined onboarding look like? 

A tight onboarding process should: 

  • Accelerate ramp-up time for new providers 

  • Reduce burnout by minimizing administrative friction 

  • Boost retention by making clinicians feel supported from day one 

  • Improve patient access and revenue cycle efficiency 

  • Support compliance and revenue integrity 

To create a clinician-focused and efficient onboarding experience, be sure to: 

  • Coordinate closely with the hiring team: Provide clear, consistent information about what to expect and plan all aspects of onboarding. Include a checklist of all required information and documents. 

  • Provide an onboarding contact: Have a single (ideally) or consistent, identified point of contact for the clinician. 

  • Centralize processes and communication: Request documents once and then distribute appropriately. 

  • Set a timeline: Goals should be realistic and achievable to help with effective planning and ensure clear expectations. 

  • Be consistent with feedback: Provide and request transparent and regular feedback on credentialing, privileging, and the enrollment progress. 

Providers aren’t asking for perfection—they’re asking for clarity, consistency, and connection. An efficient onboarding experience shows that the organization values their time and expertise. It sets the tone for collaboration and trust. With thought, intention, and appropriate resources, you can make onboarding the portal to a thriving clinical workforce. 

BerryDunn’s healthcare compliance team incorporates deep, hands-on knowledge with industry best practices to help ensure your operation is compliant and efficient. Our credentialing team is adept at navigating the challenges providers face. As an NCQA-certified Credentials Verification Organization (CVO), we help clients streamline processes with strict adherence to compliance policies and regulatory standards. Reach out for information about our physician consulting services

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Why clinician onboarding matters: A physician's perspective