July, 2017 | RKL LLP
Posted on: July 26th, 2017

RKL’s Mink One of Central PA’s “Forty Under 40” Young Leaders

D. Hunter Mink, CPA, CCIFP, manager in RKL's Audit Services GroupPRESS RELEASE

YORK, PA (July 26, 2017) – RKL LLP today announced that D. Hunter Mink, CPA, CCIFP®, has been recognized among the region’s most accomplished young leaders by the Central Penn Business Journal as part of its 2017 “Forty Under 40” awards program.

“Not only is Hunter an industry expert and a strategic advisor to his clients, he also plays a key role in shaping the future of our firm and improving the quality of life in the York community,” RKL CEO Edward W. Monborne said. “We’re pleased to see the Central Penn Business Journal celebrate Hunter for the many qualities that make him a valued member of the RKL team.”

Mink joined RKL in 2012 as a manager in the firm’s Audit Services Group, where he plans and supervises audit engagements for clients across a wide range of industries. He specializes in serving the consulting and assurance needs of the architecture/engineering (A/E) sector and works closely with many A/E firms throughout the Mid-Atlantic region. Mink also sits on RKL’s Audit & Accounting Committee, helping to manage the firm’s professional development, continuing education and quality control standards.

A member of RKL’s Real Estate Development & Construction Industry Group, Mink deepened his expertise and expanded his relevance in the sector by becoming a Certified Construction Industry Financial Professional (CCIFP®) in 2015. Achieving the CCIFP designation places Mink among an elite group of professionals nationwide that meet rigorous standards of ethical financial management in the complex construction environment.

A 2009 graduate of the Leadership York training program, Mink recently advanced to leadership positions with two local civic and professional development organizations. He was installed as Treasurer of the South Central Chapter of the Pennsylvania Institute of Certified Public Accountants (PICPA) in May, and was named Vice President of the York East Rotary Club earlier this month.

Mink serves as Board Member and Treasurer for the Farm & Natural Lands Trust of York County and sits on the Annual Campaign Cabinet for the United Way of York County. Mink also pays his professional expertise forward to local students, participating in hands-on educational events from Junior Achievement of South Central PA and presenting at Dallastown High School’s business ethics workshop.

Mink holds a Bachelor of Science in Accounting from York College of Pennsylvania. He has been licensed as a Certified Public Accountant in Pennsylvania since 2007, and belongs to the PICPA and American Institute of Certified Public Accountants (AICPA). A lifelong York County resident, Mink resides in York with his wife, Emily, and his twin daughters.

The annual “Forty Under 40” program celebrates Central Pennsylvania’s best and brightest young business leaders. Mink and his fellow 2017 honorees will be celebrated on October 2 at a ceremony at the Hilton Harrisburg. Click here for more information on CPBJ’s “Forty Under 40” Awards.


Posted on: July 18th, 2017

The Changing Landscape of Nursing Home Five-Star Ratings

The Changing Landscape of Nursing Home Five-Star RatingsNursing homes that participate in the federal Medicare or Medicaid programs are measured against a set of quality ratings, collectively referred to as the Five-Star Quality Rating. Established by the Center for Medicare & Medicaid Services (CMS) in December 2008, the Five-Star rating is an important tool for the facility itself to earn government reimbursements, insurance payments and patient referrals, and also for families researching nursing homes for their loved ones. There are changes on the horizon for how certain aspects of the Five-Star rating are reported and calculated, but first let’s recap the existing model.

Current rating system for nursing homes

Currently, there are three categories of measures that are rated individually on a scale of one to five stars, and then combined into an overall star rating for the facility.

  • Health inspections: Ratings in this category are drawn from the number, scope and severity of deficiencies reported in the three most recent annual state inspection and the most recent 36 months of complaint surveys. The fewer deficiencies, the higher the star rating for this category.
  • Nurse staffing: In this category, more Registered Nurse and overall nursing staff equals a higher star rating.
  • Quality measures: This third category was based, until 2016, on the results of 11 distinct measures of quality reported using a standardized form. An example of one of these 11 quality measures is the percentage of residents falling one or more times with major injury.

New measures added to rating system

In recent years, several U.S. Senators, including Robert P. Casey, Jr. of Pennsylvania, began to question the methodology of the Five-Star Quality Rating System. Since then, several changes have been implemented to make the rating process more vigorous and dependable.

CMS added five new measures to the quality measures rating in July 2016, three of which are based on hospital Medicare claims. This is significant because the measures rely on data instead of self-reported information from nursing homes.

Another change expected as we move through 2017 is how the nurse staffing rating is calculated. Instead of the current self-reporting system, CMS intends to instead base this staffing rating on actual payroll data for the nursing home. This will enhance the nurse staffing rating by reflecting the level of staffing throughout the year, rather than what is currently being captured only at the time of the annual health inspection.

Financial and operational impact to facilities

Taken together, these changes will help improve the accuracy and reliability of the Five-Star Quality Rating, which is important to families selecting a nursing home and for hospitals and physicians referring patients. Beyond the reputational aspect, there are serious financial and operational impacts as well. As Pennsylvania transitions to a Managed Care model with Medicaid payments administered by insurance companies, it is expected that nursing homes rated beneath an overall three-star rating may not be eligible to contract with the insurer. If this is the case, a number of nursing homes throughout the Commonwealth may face significant financial challenges.

Families interested in reviewing current Five-Star Quality Ratings can visit the Nursing Home Compare website, where they can search by name or location, compare up to three facilities side by side and drill down into reported deficiencies.

The role of the Five-Star Quality Rating System will play an increasingly significant role in the financial success and sustainability of nursing homes, as the cost of caring for our aging population grows and places more demands on governmental support systems. With ratings potentially dictating which facilities will survive and which could be at risk of shutting down or being forced to merge with another provider, the move toward empirical, claims-based data instead of self-reported data will provide more assurance of accuracy and instill more confidence into the families, health care partners and government agencies that use it.

James M. Spencer, CPA, MBA, Manager in RKL’s Senior Living Services Consulting GroupContributed by James M. Spencer, CPA, MBA, Manager in RKL’s Senior Living Services Consulting Group. Jamie specializes in the preparation of financial models and analysis, including projections and forecasts, financial feasibility studies and transaction due diligence.




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Posted on: July 6th, 2017

Employers: Is Your Health and Welfare Plan Compliant with ERISA?

Employers: Is Your Health and Welfare Plan Compliant with ERISA?Providing health and welfare benefits to employees is a powerful recruitment and retention tool, but it also involves many responsibilities and requirements for the employer. Employers that offer these benefits must comply with the full range of reporting deadlines and fiduciary obligations that accompany them.

An often overlooked or misunderstood aspect of health and welfare benefit reporting is fiduciary responsibilities required by the federal Employee Retirement Income Security Act (ERISA). Missing these documentation and reporting requirements or failing to carry out these responsibilities can leave an employer at risk for liability, fine or penalty. Below, we provide an overview of just some of the fiduciary and filing requirements for health and welfare plans under ERISA.

Examples of Health and Welfare Benefit Plans Subject to ERISA

Most employers generally understand how ERISA impacts the retirement plans they offer to employees, but many are unaware that ERISA also applies to health and welfare benefit plans. Just like employer-sponsored retirement plans, ERISA sets minimum reporting and disclosure standards for health and welfare benefit plans, whether they are insured or self-insured.

Examples of health and welfare benefit plans that are subject to ERISA include, but are not limited to:

  • Medical and prescription drug plans
  • Health Reimbursement Arrangements (HRAs) and health Flexible Spending Accounts (FSAs)
  • Dental and vision plans
  • Disability plans
  • Life and accidental death and dismemberment (AD&D) plans
  • Severance pay plans

ERISA Requirements for Employer-Sponsored Health and Welfare Plans

Exceptions to ERISA are limited, so it is important to be aware of ERISA reporting and disclosure requirements. Outlined below are just some of the documentation and reporting requirements:

Plan Document and Summary Plan Description

Employers have the option of designing their benefits program so that each insurance contract or type of benefit is considered a separate plan or grouping several insurance contracts or benefits together under one plan. Regardless of plan design or size, under ERISA, each separate health and welfare benefit plan must have a Plan Document in writing. The Plan Document supplements the insurance contract(s) to meet ERISA disclosure requirements. This document must identify and describe the plan name, plan sponsor, plan administrator, benefit(s), eligibility, benefit funding and administration procedures for the plan, among other details.

ERISA also requires that employers provide a Summary Plan Description (SPD) to participants and beneficiaries that explains in plain language the plan’s basic information and features. ERISA requires the SPD to be distributed to participants automatically within 90 days of becoming covered by the plan. ERISA also requires an updated SPD to be distributed within a certain number of years based on if and when changes are made or the plan is amended.

It is important to note that insurance policies or Certificates of Insurance do not meet ERISA standards and are not permitted to be submitted in place of Plan Documents and Summary Plan Descriptions.

Annual Form 5500 and Summary Annual Report

Any health and welfare benefit plan, whether it is insured or self-insured, that covers 100 or more participants at the beginning of the plan year must file Form 5500 annually with the U.S. Department of Labor. Form 5500 is due by the last day of the seventh calendar month after the plan year end date. For plans with a calendar year end date, the form is due by July 31.

Since Form 5500 is required to be filed for each plan that meets the filing requirements, it is important for employers to have proper plan documentation identifying its plan(s), as explained above. If proper plan documentation is not in place, each insurance contract or type of benefit is considered a separate plan by default and subject to separate Form 5500 reporting.

In a previous post, we took a closer look at different types of plans and the filing and audit requirements that go along with these categorizations.

Employers should also be aware that beyond the Form 5500 requirement, self-insured medical plans (including HRA arrangements and certain FSA arrangements) have additional IRS filing requirements under the Affordable Care Act.

The Summary Annual Report (SAR) provides a narrative recap of the Form 5500. The SAR must be distributed annually to participants and beneficiaries within nine months after the end of the plan year or two months after the Form 5500 filing.

RKL’s team of small business and tax advisors is available to help employers file the required Form 5500 and prepare the Summary Annual Report or answer questions related to ERISA fiduciary responsibilities. Contact your RKL professional or one of our local offices for more information on this and other financial topics impacting employers.

Laura S. Rineer, CPAContributed by Laura S. Rineer, CPA, a supervisor in RKL’s Small Business Services Group. Laura specializes in helping small businesses from a wide variety of industries with financial statements, tax returns and related accounting and business needs. 




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Posted on: July 5th, 2017

RKL Welcomes New Partner Barry M. Pelagatti to Firm Leadership

Barry M. Pelagatti, Partner and leader of RKL's Financial Services Industry Group. Pelagatti will lead the firm’s Financial Services Industry Group


RADNOR, PA (July 5, 2017) – RKL LLP today announced that Barry M. Pelagatti, CPA, has joined the firm as a Partner. Based out of the firm’s Radnor office, Pelagatti will lead RKL’s Financial Services Industry Group.

“We’re proud to welcome Barry Pelagatti to the RKL leadership team,” said Edward W. Monborne, RKL CEO. “His reputation as a trusted advisor and business strategist for financial institutions in the Greater Philadelphia region will be a tremendous asset to RKL as we expand our capabilities to more comprehensively serve the financial services industry throughout our footprint.”

“With its entrepreneurial culture, team of talented professionals and innovative approach to professional services, it’s an exciting time to join RKL,” Pelagatti said. “I look forward to contributing value and industry insights to the firm’s expanded efforts to help financial institutions proactively manage evolving challenges like risk and regulatory compliance.”

Through its highly regarded credit union practice, RKL has long served the accounting and advisory needs of these financial institutions in Pennsylvania and neighboring states. The firm established a presence in the Greater Philadelphia region in October 2016 with the launch of Radnor-based RKL Risk Management LLC, which allows RKL to deliver internal audit, compliance and information technology audit services to a wider range of financial institutions.

Under Pelagatti’s leadership, RKL’s broadened focus on the financial services industry will allow the firm to deliver a robust spectrum of services to banks, credit unions and other institutions, ranging from traditional assurance and compliance requirements to cutting edge capabilities like cyber security and risk management. Pelagatti’s industry expertise and regional connections position RKL to not only grow its client base in the financial services realm but also to foster relationships across other industries in the Philadelphia area and beyond.

Pelagatti brings more than 20 years’ experience in public accounting to RKL. He has deep experience advising financial institutions on operational improvement and complex accounting and reporting matters, including mergers and acquisitions, SEC requirements and capital market transactions.

A member of the American Institute of Certified Public Accountants (AICPA), Pelagatti participates on the AICPA Depository and Lending Institutions Expert Panel. He also is a member of the Pennsylvania Institute of Certified Public Accountants, and is currently the chair of the PICPA Financial Institutions Training Committee.

Pelagatti is an active member of the New Jersey Bankers Association and the Pennsylvania Association of Community Bankers, and sits on the advisory board of the Financial Managers Society. He holds a B.S. in Accounting from St. Joseph’s University, and resides in West Grove, PA, with his wife and three daughters.