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The regulation required full compliance by No- vember 15, 2017. This is the single largest change to the emergency pre-
January 2018

inside... 1

The Real world CMS

Emergency Preparedness Rule

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Editors Note Drudging Towards

Doomsday

6-7 Photos from Novem-

ber 29th Bookkeepers forum

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New Tax laws to Affect

Not-for-Profits

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AlTCfM Board of

Directors

w w w. A lT C f M . o R g

12 Programs & Events

The Real World CMS Emergency Preparedness Rule – 10 degrees and dropping By Scott Aronson

It is 9:30pm on a Saturday in January – temperature is 17 degrees. The area has experienced a power outage due to a substation failing. Your emergency power has not activated and only battery back-up lighting is working. The fire department arrives first and informs you that power will be out for a minimum of 6-8 hours. A technician arrives and identifies that there is no easy fix to the switchgear. The City Emergency Manager and DPH communicate to the Nursing Supervisor that you will need to evacuate your building if you can’t get the generator to work. It is too dangerous to the residents to remain with temperatures dropping quickly and no short-term primary or back-up power options.

Could this happen to you? Even hardened structures like the Atlanta Airport (busiest in the world) were down for almost a full day without commercial power and emergency power (December 17, 2017). Think about the effects: resident evacuation and tracking; continuous communications with families, staff, the media, and receiving facilities; and building recovery with the potential for internal flooding due to pipes freezing.

Due to isolated issues like this and larger area-wide disasters, the Centers for Medicare & Medicaid Services (CMS) implemented the “Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers”. The regulation required full compliance by November 15, 2017. This is the single largest change to the emergency preparedness requirements in long-term care in our recent history.

The Emergency Preparedness Program (EPP) includes four (4) core elements. The emphasis is to ensure adequate planning for both natural, man-made and technological disasters (loss of utility systems, etc.), and coordination with local, regional, state and federal agencies (community partners). The 4 elements include: 1 Annual Risk Assessment & Emergency Planning (all-hazards approach/Hazard Vulnerability Assessment) 2 Communication Plan 3 Policies and Procedures specific to the outcome of your risk assessments Continued on Page 2

Continued from Cover Page

EDITOR’S NOTE

Dear Readers,

wow, I certainly feel as though I am a bit delayed in writing this. Unfortunately, when I think of the reasons why it is certainly not due to writers’ block! In fact, there is too much “mandatory reading” . By mandatory, I mean articles and CMS documents that are necessary in order for us to continue to thrive both in survey and payment regulations. Now that November 28th is past, I will take the time to reflect and observe but also to celebrate the holidays with our residents and staff. Training and education on industry changes are just as important as celebration and traditions are to our residents. we must remember that.

Please let us know what we can do to help better serve you with resources and information in this time of healthcare reform.

4 Training of all staff and leadership with testing of the plan via disaster exercises twice annually.

what really needs to be done? Every facility should be completing a thorough Hazard Vulnerability Assessment (HVA). You are unable to be prepared for a disaster if unsure of your level of readiness. Use the community partners to assist in this process by first looking internally at how prepared you are for a myriad of disasters and then establishing mitigation plans. It is important to determine the potential financial impact of each high probability event to determine if you will be able to fix the issue or develop low cost alternative strategies to minimize the impact.

An example may be that you need to increase the size of your generator to fully handle the HVAC load in high heat or extreme cold. There may not be funding to cover the costs of the $750,000 upgrade, but there is the potential to spend $10,000 to install a “quick connect” where an exterior generator can be rented in advance (pre-hurricane) or during an incident that could backfill your capabilities. The solution does not need to break the bank, but the facility must know what the risks and exposures are and have a cost model to mitigate.

Sincerely,

Karen Donorfio, [email protected]

You Provide Expert Long Term Care...So Do We We understand the increasing pressure you face to preserve and even increase your revenue base.

The HVA is the driver of all 4 elements of the CMS Emergency Preparedness Rule. Take the necessary steps to assess your risk, establish mitigation plans, and implement the plans through procedure design, training/education and potential facility improvements. Then complete the process by testing your highest risk threats through disaster exercises using realistic scenarios.

At BlumShapiro, we have 80 professionals dedicated exclusively to healthcare. With decades of in-depth experience, we’re just what the doctor ordered.

The residents rely on the provider to protect them, as do their families, and the long-term care community is dedicated to supporting those who cannot protect themselves in a fire or other disaster. while it appears overbearing on the surface, using a practical strategy to address the process outlined in the CMS Emergency Preparedness Rule will improve the safety at long-term care facilities.

Our Services Include: - Accounting, Tax and Business Consulting - Corporate Governance - Third Party Reimbursement - Cost Report Preparation

Connecticut Massachusetts Rhode Island 866.356.BLUM blumshapiro.com

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Scott Aronson is a Principal of RPA, a JENSEN HUGHES Company and can be reached at [email protected]

THE AlTCfM JoURNAl

Published by the Association for long Term Care financial Managers

LONG-TERM CARE ADVISORS

Please submit articles to Executive Editor: Karen Donorfio T: 860-747-1637 f: 860-410-2045 email: kdonorfi[email protected] Associate Editors: Jeffrey Dexter, [email protected] Roger Sliby, [email protected] Contributing Writers: Scott Aronson Karen Donorfio Maureen McCarthy Mark Piszko

Photographer: Jeff Sobiech, Daley Studios, Hartford



The views expressed herein are those of the authors and do not reflect official AlTCfM policy. AlTCfM is not responsible for typos or errors of omission.





P PHONE :

If you have any suggestions, corrections or concerns, please write or call the editor.



860-321-7413

:

EMAIL CON C [email protected] WEB: WWW.CELTICCONSULTING.ORG

AlTCfM JoURNAl ADVERTISINg INfoRMATIoN

Marcum LLP

The AlTCfM welcomes advertisements from reputable suppliers of products and services to the long term care financial community. However, AlTCfM does not perform “due diligence” on advertisers and cannot guarantee that their offerings are suitable or correct. Upcoming Issues and Deadlines: March 2018 Issue Deadline: feb. 20, 2018 May 2018 Issue Deadline: April 20, 2018 August 2018 Issue Deadine: July 20, 2018 December 2018 Issue Deadline: Nov. 20, 2018

is a proud sponsor of the

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For more information visit us at

marcumllp.com

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CT Municipalities Undergoing Assessment Revaluations in Grand List Year 2017 (Check below to see if your facility is going through a Reval this year.)

The Long-Term Care Practice Group at Murtha Cullina Q Q Q Q Q Q Q Q Q

Regulatory and risk management Acquisitions and sales Commercial and tax-exempt financing Medicare and Medicaid Audits/Reimbursement Litigation/Labor and employment/OSHA HIPAA and corporate compliance Licensing Work-outs and restructuring Collections and evictions

Heather O. Berchem Chair [email protected] 203.772.7728 BOSTON + HARTFORD + NEW HAVEN + STAMFORD + WHITE PLAINS + WOBURN MURTHALAW.COM

Ansonia, Berlin, Bethel, Bozrah, Bristol, Canaan, Cromwell, Danbury, East Haddam, East windsor, farmington, glastonbury, goshen, granby, guilford, Middletown, Newtown, New Britain, North Canaan, orange, Plainfield, Preston, Redding, Ridgefield, Roxbury, Simsbury, South windsor, Southbury, Sprague, Stamford, Sterling, Stonington, warren, waterbury, waterford, wilton, winchester

Assessment Change Notices for most municipalities came out in November or December. There is a brief appeal period after receiving your Notice. Excessive, unwarranted increases in your real estate assessment could result in overpaying your taxes by many thousands of dollars over the next fIVE years.

Submitted by Jeffrey Dexter, Cost Reduction Services Group LLC. Email: [email protected] 855203-5390 or cell: 203-525-5048

Need results? Work with Crowe. At Crowe Horwath LLP our healthcare specialists work with thousands of healthcare leaders to raise quality, revenue, and margins while lowering costs and risks with our unique, data-driven analytical tools and experience. To learn more about Crowe healthcare services, please contact Todd Thiesfeldt at +1 860 470 2114. Smart decisions. Lasting value.™

Audit / Tax / Advisory / Risk / Performance

In accordance with applicable professional standards, some firm services may not be available to attest clients. © 2016 Crowe Horwath LLP, an independent member of Crowe Horwath International crowehorwath.com/disclosure

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HC-17000-013F

Drudging Toward Doomsday By Maureen McCarthy, RN, BS, RAC-MT, QCP-MT

Between Requirements of Participation Phase 1 and Phase 2 providers have barely been able to catch their breath. Now that the window for anticipated compliance has passed, many are looking to Phase 3 to prepare for those additional changes. But don’t be fooled into thinking that there aren’t multiple other changes looming ahead before 11/28/2019. SNf providers will be facing a new Value Based Program, a Quality Reporting Program which may result in payment penalties, and to top it all off, an entirely new reimbursement system. All 3 new initiatives will be hitting the same day, 10/1/18, which is why I am calling it Doomsday.

Having lived through the change from cost-based payments to Prospective Payment System (PPS), just the fact that we are changing payment systems would be enough to make any provider’s head spin. But to add the other initiatives as well, is enough to have some folks considering early retirement or a career in a new field.

So, here’s the scoop. on 10/1/18 the data that has been collected on falls with major injury, stage 2-4 pressure ulcers and unstageable ulcers, as well as the dreaded new Section gg of the MDS (which gauges the effectiveness of the facility rehab program by measuring the resident’s improvement from admission to discharge off Medicare A coverage) will all be used to help determine fY19 rates. when the Quality Reporting Program (QRP) started in 4th quarter 2016, CMS wanted reporting; it didn’t matter what the data said, just that there were values in those boxes of the MDS. Moving forward the data will be used to determine the percentages and compare to other SNf providers across the nation. In addition, on 10/1/18, the SNf Value-Based Purchasing Program will begin. The cost to providers will be 2% of your Medicare rate. This is not optional; all facilities will be participating. You will have the option to ‘buy’ your money back, yes just like a game show, if you can meet the minimal achievement threshold. The amount of money you ‘buy back’ is determined by how much you can reduce your rehospitalizations. CMS has released reports outlining facility historical rehospitalization rates going back to 2013 on the CASPER site. for the 10/1/18 Doomsday deadline, calendar year 2015 will be compared to calendar year 2017. So, hopefully you have improved over your own facility in 2015, or over the bottom 25% of facilities in 2015, which is the achievement threshold.

But you’re not done yet! There is also that new reimbursement system beginning on 10/1/18 as well, called Resident Classification System or RCS-1. This will bring about its own issues, a new case mix index, a new MDS schedule, and a new way to provide rehabilitative therapy. Therapy minutes will no longer be the driving factor in this reimbursement system, now it will be resident condition. The more chronic conditions or diagnoses, the more risk adjustment and revenue. There will be over 92 ‘categories’ or classification levels that can be mixed and matched to determine the final payment level. SNf MDS and finance staff will have to learn a whole new system while minding the current reporting programs, which all affect revenue.

Preparation for Requirements of Participation will seem like a piece of cake compared to the inception of 3 federal program changes all due on the same day. Providers will need to keep their eyes on their quality, rehospitalizations and convert to a new payment system all at once. Those who started early will have an advantage over those who did not, because they had a chance to monitor the data as it was happening, being proactive rather than reactive. 5

Continued on Page 8

Bookkeeper Forum Avery Heights 11.29.17

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Bookkeeper Forum Avery Heights 11.29.17

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REMINDERS AND UPDATES

Submitted by Karen Donorfio, ALTCFM Newsletter Editor

Emergency Preparedness: final Rule went into effect on November 15, 2017. This involved a detailed approach to a facility risk assessment, Hazard Vulnerability Assessment (HVA), and a comprehensive drill. Certainly in the light of recent hurricanes and with our winter season, a focus on disaster planning is both realistic and timely. for Interpretative guidance (Ig) on these areas please see the following from CMS: https://www.cms.gov/Medicare/Provider-Enrollment-andCertification/SurveyCertEmergPrep/Downloads/Advanced-Copy-SoM-Appendix-Z-EP-Igs.pdf

Infection Control: Though an Antibiotic Stewardship Program must be in place as of November 28, 2017, you are not required to have a designated Infection Preventionist until next year. You can find helpful information on the CDC website regarding tracking, monitoring, accountability regarding the use of antibiotics, etc.

Therapy Caps 2018: Please note an update to the therapy caps for 2018. Physical Therapy and Speech Therapy combined cap is $2,010 and occupational Therapy cap will be $2,010 (separately). Medicare Savings Program: DSS released an update on the timeline of MSP cuts on December 6th. The original implementation date of January 1, 2018 is being pushed out for an expected two months based on the many concerns from beneficiaries. As you know in october, the state budget was passed and it included reduced eligibility limits. Nursing Home Compare Changes: In a Survey & Certification letter dated November 26th, CMS announced changes to Nursing Home Compare’s star rating system for health inspections. It will no longer include 3 years of surveys. It will be based on the 2 most recent health inspection ratings40% weighting for the oldest survey and 60% rating for the most recent. You should also be aware that there is a frozen health inspection rating until November 27, 2018.

Drudging Toward Dooms Day (continued from Page 5)

The biggest suggestion is to monitor the Section gg goals and the resident’s progress toward those goals on a weekly basis at the Medicare meeting. The reason why is that CMS will be adding a new measure to determine the percentage of residents who improved from admission performance in gg130 (1) to discharge performance in gg170 (1). Then the percentage of residents who met or exceeded their discharge goal as documented in gg130 (2) and gg170 (2). So, it behooves you to know whether the bulk of your residents are meeting the criteria or not and to do something about it in real time. Those facilities who have handed the gg section over to rehab with no input from nursing, especially the aides taking care of the resident, will likely be the losers in this game. If you only set 1 goal and do not reach that goal at the conclusion of the Medicare stay, your percentage is 0, where a facility that sets 10 goals and reaches 8 of them has an 80% achievement percentage. The higher percentages are the winners here. But how would you know if you aren’t even looking at it?

what should you do now, you ask? Educate your teams to let them know what’s coming. Prepare for the future by testing new strategies now. Restructure your rehab program with your managed care covered residents who are NoT paid by the RUg level, but by a contracted level. (i.e.: level 1=$350, level 2=$450, level 3=$550, etc.) where minutes are expected to be given but are not managed. Utilize group and concurrent therapy for those payers where minutes are expected at a certain level but How those minutes are provided is up to the SNf. This will likely be the same system you will use under RCS-1.

If you would like more information, please do not hesitate to contact Maureen at Celtic Consulting 860-321-7413. 8

NEW LAW EFFECTIVE JANUARY 1

A new law went into effect January 1, 2018 that requires payers of taxable pensions and annuities that maintain an office or transact business in CT to withhold CT income tax from distributions to CT residents. This requirement would cause individuals to not have enough income to pay the full patient liability owed to nursing homes and home care providers.

WE C CAN AN SOL SOLVE LVE VE Y YOUR O F FACILITY’S

MEDICAID MEDIC AID CHA CHALLENGE!

DSS worked jointly with DRS to draft a communication detailing an important clarification regarding the new law. Individuals active on CT Medicaid and residing in a nursing home or receiving home and community based waiver services are not required to have CT income tax withheld from their pensions and annuities.

Prevent Prevent denials from occurring Optimize Medicaid eligibility Optimize Medic aid e Educate families families abo Educate about Medicaid guidelines Medicaid Expedite the speed Expedite of approvals approvals of your Improve Improve y our ǹƃƺȈȢȈɽʰԇɰƺƃɰȃːɁʥ ǹƃƺȈȢȈɽʰԇɰƺƃɰȃːɁʥ

for a copy of the DSS notice go to: https://alcfm.memberclicks.net/assets/documen ts/Bookkeeperforum/DRS-DSS%20notice.pdf

Reduce Medicaid Medicaid pe Reduce penalties

EFFICIENT. EFFICIENT T. COMMITTED COMMITTED.. C COMPREHENSIVE.

Call toll free: 855.S.Planning- 1.855. 1.855.775.2664 775.2664 www.senior-planning.com .senior-planning.com Visit us at www

































For more information about the law firm of Wiggin and Dana, please contact Maureen Weaver at [email protected] or 203.498.4384, or Michelle Wilcox DeBarge at [email protected] or 860.297.3702.

AT T O R N E Y A D V E R T I S I N G

NEW HA HAVEN VEN I STAMFORD STAMFORD I NEW YORK I HARTFORD HARTFORD I PHILADELPHIA I GREENWICH GREENWICH I WASHINGTON, WASHINGTON, DC DC

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w w w. w i g g i n . c o m

New Tax Law Could Affect Not-for-Profits By Mark Piszko, CPA, CgMA

The historic tax reform bill approved by Congress signed into law by President Trump — the “Tax Cuts and Jobs Act Bill” — will affect almost all individual and corporate taxpayers beginning in 2018. Not-for-profit organizations, as well, may be affected, though the actual impact is difficult to determine at this point. Many charitable organizations fear that the tax law changes will negatively impact muchneeded revenue streams, both from individual contributions and government subsidies, potentially hurting non-profits, particularly those located in high state and local tax areas, including New York. we outline some of the changes which may impact not-for-profit entities.

Increase in the Standard Deduction The new tax law nearly doubles the standard deduction in 2018. The increase in the standard deduction is expected to reduce the percentage of taxpayers who itemize deductions on their tax returns from approximately 30% to 5%. Because fewer people would itemize, the tax benefit incentive to make charitable contributions would diminish.

for the small fraction of people who will continue to itemize however, the new tax law raises the threshold for cash donations and repeals the “Pease” provision, which currently limits charitable deductions for the wealthiest taxpayers. The increase in the donation threshold and elimination of the “Pease” provision may soften an expected reduction in donations, but probably not enough to compensate for it entirely.

A recent study by the Indiana University lilly School of Philanthropy estimates that overall charitable giving would decline by 5%, or $13 billion, as a result of changes in the tax law.

Reduction in State and Local Tax Deductions The new tax law limits the deductibility of state/local taxes and property taxes (combined) to $10,000. This may impact charitable giving in those states with the highest state/local taxes and property taxes because under prior tax rules, taxpayers could deduct all state and local taxes paid and all property taxes paid. Under the new law, the limitation on this deduction may result in fewer taxpayers itemizing deductions, or may result in higher tax bills at year-end for individuals living in high tax states and locales.

In addition, having constituents with higher tax bills may give pause to state and local legislators when considering tax increases in those states and cities to fund governmental services, including monies earmarked for not-for-profits, so as not to impact their constituent taxpayers to an even greater degree.

Increase in the Estate Tax Exemption The new tax law doubles the exemption on the estate tax to approximately $11 million for individuals and $22 million for couples. This increased threshold on taxable estates is estimated to reduce tax collections an estimated $95 to $150 billion dollars over the next ten years. There is some concern among certain not-for-profits that fewer individuals will consider planned gifts to charitable organizations as part of their estate tax planning since the increase in the estate tax exemption may reduce the incentive for potential donors to establish planned giving to charities.

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Continued on Page 12

2017-18 AlTCfM offICERS AND DIRECToRS

PRESIDENT: Cheryl Shirley, Chief financial officer The Mary wade Home 118 Clinton Avenue, New Haven, CT 06513 T) (203) 672-7817 [email protected]

TREASURER: Jon Morgan, CPA wonneberger & Morgan 1157 Highland Avenue, Suite 108 Cheshire, CT 06410 T) (203) 272-4417 fax) (203) 250-2054 [email protected]

SECRETARY: Karen Donorfio, Reg. VP of operations Apple Rehab Corporate 21 waterville Road, Avon, CT 06001 T) (860) 678-0755 [email protected]

IMM. PAST PRES. Maureen McCarthy, President Celtic Consulting one Torrington office Plaza 507 East Main St., Ste 308, Torrington, CT 06790 T) (860) 321-7413 [email protected] PROGRAM CHAIR: Carol Barno, Chief financial officer Mclean 75 great Pond Road Simsbury, CT 06070 T) (860) 658-3759 fax: (860) 658-3769 [email protected]

GOVERNANCE CHAIR: Robert gwizdak, VP Accounting Apple Rehab 21 waterville Road, Avon, CT 06001 T) (860) 678-9755 fax) (860) 677-4232 [email protected]

PROGRAM - CEU: Maureen weaver, Partner wiggin and Dana llP one Century Tower, New Haven, CT 06508-1832 T) (203) 498-4384 fax) (203) 782-2889 [email protected]

MEMBERSHIP CHAIR: Raymond gasperini, Vice President & Cfo Church Homes, Inc. 217 Avery Hights, Hartford, CT 06106-4200 T) (860) 527 9126 ext. 360 fax) (860) 560-2469 [email protected] NEWSLETTER CHAIR: Karen Donorfio (See Secretary)

WEBSITE CHAIR: Kevin o'Connell, PT, MBA, Campus Administrator geer Corporation 99 South Road, Canaan, CT 06018-0819 (T) (860) 824-5137 fax) (860) 824-1474 [email protected] BOOKKEEPER FORUM: Michelle Pascetta, Dir. of Reimb. & Budgeting Church Homes, Inc. 217 Avery Heights, Hartford, CT 06106-4200 T) (860) 527-9126 fax) (860) 560-2469 [email protected]

Maritza Deflorio, Regional Director of finance Hamden Rehabilitation 1270 Sherman lane, Hamden, CT 06514 T) (203) 281-7555 fax) (203) 381-3827 [email protected] DIRECTORS AT LARGE

Julia Eisenhaur, CPA PKf o'Connor Davies, llP 100 great Meadow Rd, Ste 401 wethersfield, CT 06109 T) (860) 257-1870 fax) (860) 257-1875 Email: [email protected] John Iovieno, Cfo Matuliatis Nursing Home 10 Thurber Road, Putnam, CT 06260 T) (860) 395-4833 [email protected]

frank Miceli, Audit Partner Marcum llP CityPlace II, 185 Asylum St., Hartford, CT 06103 T) (860) 218-1420 fax) (860) 549-8501 [email protected]

Patricia Morse, President CT Baptist Homes/PierceCare 292 Thorpe Avenue, Meriden, CT 06450 T) (203) 237-1206 fax) (203) 639-5900 [email protected]

liz Perugini, A/R Regional Athena Healthcare 44 Abbott Terrace, waterbury, CT 06702 T) (203) 755-4870 fax) (203) 755-5054 [email protected]

Sharon Robinson, Dir. of Senior Care, Hartford Healthcare Senior Services 80 Meriden Avenue, Southington, CT 06489 (T) (860) 378-1274 [email protected] Roger Sliby, VP finance, Cfo Jewish Senior Services 42 Park Avenue, Bridgeport, CT 06604 (T) (203) 365-6405 fax) (203) 396-1092 [email protected]

Todd Thiesfeldt, CPA, Partner Crowe Horwath llP 175 Powder forest Drive, Simsbury, CT 06070 (T) (860) 678-9202 [email protected] george Thomas, Director Blum Shapiro & Co., P.C. 29 South Main Street, 4th floor west Hartford, CT 06107 T) (860) 561-6853 fax) (860) 570-6320 [email protected] Keith Varian, Attorney Murtha Cullina 177 Broad Street, 4th floor Stamford, CT 06901 T) (203) 653-5400 fax) (203) 653-5444

ADMINISTRAToR: Jaclyn farnham Association Alternatives 95 west Street, Rocky Hill, CT 06067 T) (860) 721-7400 fax) (860) 721-7406 Email: [email protected]

ASSoCIATIoN foR loNg TERM CARE fINANCIAl MANAgERS MEMBERSHIP APPlICATIoN

Name:_________________________________________ Title:______________________________

Employer: ________________________________________________________________________

Address: _________________________________________________________________________

Phone: _________________________________ fax: ____________________________________

Email: ___________________________________________________________________________

The annual membership fee is $85 and renewable on April 1st. Make checks payable to: AlTCfM, 95 west Street, Rocky Hill, CT 06067. for more information, call 860-721-7400 or email [email protected].

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A lT C f M P R o g R A M S

&

EVENTS

Bookkeeper Forum - Hartford

Thursday, February 22, 2018 8:30 - 10:30 AM Church Homes, Hartford STAY TUNED... MORE TO BE ANNOUNCED SOON

More information and to Register visit http://www.altcfm.org/event-list Topics and dates are subject to change.

wE ARE AN ASSoCIATIoN woRKINg To ENHANCE fINANCIAl AND oTHER MANAgEMENT EXPERTISE of INDIVIDUAlS wITHIN THE loNg TERM CARE CoNTINUUM.

New Tax Law (continued from page 10)

Federal Deficit There is great concern among a number of not-for-profits that — as a result of the changes affected by the new tax law — tax collections by the federal government will decrease, causing a reduction in federal subsidies to states and local governments. Many charitable organizations, particularly those providing social services programs to communities, are reliant on government funding, both federal and local, to subsidize their operations. A reduction in government funding, combined with a potential drop in individual donations, could be disastrous for some organizations, or at the very least, could result in increased budget constraints and a potential reduction in program services provided.

What Now? The tax reform act contains other changes that could affect charitable organizations that we will discuss in future editions of our newsletter. The full impact the tax reform changes will have on not-forprofit organizations cannot be predicted at this point; however, in the meantime, we encourage Boards and management executives to have open, frank discussions about the potential impact the tax changes may have on your organization and what, if any, actions you need to take to address that impact. Mark Piszko, CPA, CGMA, is a Partner at PKF O’Connor Davies, LLP, [email protected]