CECL will have major implications for healthcare companies, including pharmaceuticals, hospitals, and insurance providers.
The new current expected credit loss model, known as CECL, drastically changes the way healthcare companies record losses on financial instruments such as receivables, reinsurance receivables, available-for-sale securities, sales and financing leases, off-balance sheet credit exposures, and commercial mortgage loans carried at amortized cost. Under the new standard, companies must record an allowance for expected future credit losses over the lifetime of the asset and consider past events, current conditions, and reasonable and supportable forecasts. The estimated credit loss is booked concurrently with recognition of the asset and the credit loss estimate must be updated during each future reporting period.
While CECL will likely have the most significant impact on financial institutions due to their large loan portfolios, the new guidance will have major implications for healthcare companies, including pharmaceuticals, hospitals, and insurance providers. Although many within the healthcare industry are aware that CECL affects trade receivables, understanding the full scope of financial assets impacted is important for companies to prepare for a successful transition to the new standard.
Healthcare companies should begin the scoping process as early as possible and develop an adoption plan to address each class of financial asset. During this process, companies should focus on the following financial assets as they consider the adoption of the new standard.
While it remains to be seen how CECL will affect each entity based on the mix of financial assets, healthcare companies can prepare for the change by leveraging several practical expedients that are available to streamline application of the new standard.
After considering all available practical expedients, companies may find that certain financial assets are within scope of CECL but not eligible for a practical expedient (e.g., trade receivables and sales and financing leases). In this case, companies must measure the expected credit loss, if material. If the new standard does not result in a material impact, companies should still analyze and document existing contracts and processes to satisfy requirements from management, auditors, and regulators.
Last July, the FASB voted to delay CECL implementation for many companies. Calendar year-end SEC filers—excluding smaller reporting companies— are required to adopt the new standard as of January 2020 while non-public entities have until January 2023 to comply with the changes. For all entities, early adoption is permitted.
Healthcare companies should take advantage of the deferred effective date to understand the potential impact of the new standard to their business and build an effective implementation plan. Companies required to adopt CECL on January 1, 2020, should finalize the loss methodology and estimate the quantitative impact of CECL for disclosure in their year-end financial statements. While there likely will not be drastic changes to the modeling of trade receivables—other than recording an allowance for current receivables—the other financial instruments mentioned above will require extensive effort prior to adoption.
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