What picture enters your mind when you hear “Full Steam Ahead!”? Is it a group of people racing toward a finish line? Or maybe the noise of a steam engine powering a large piece of equipment? After reading the book “Full Steam Ahead!” by Ken Blanchard and Jesse Lyn Stoner, this phrase now reminds me to grab onto my personal vision and use positive energy to forge past any “gremlins” that try to block me.
The book tells the story of a new employee who gets caught up in the creation of a vision for her company. Along the way, she also realizes she needs a vision to guide her family values. The concepts are introduced easily through the story line and allow the reader to see vision creation in action.
So, what is a vision? Think of it as the “why” behind what you do, a picture of the future, and a set of values that guide you along your journey. A vision gives purpose to an ultimate big-picture legacy and allows you to drill down and create micro-steps (i.e. goals) that take you down the path of achievement.
Creating my personal vision included analyzing my joys, dreams, values, and talents and truly allowing myself to picture how those intangibles could manifest into the life I want to live. From my vision, I have been able to create goals in all areas of my life that help me live my legacy.
At Ketel Thorstenson, LLP, our vision is to inspire excellence in our people, clients and communities by living our core values – being excellent, innovative, friends, true, and different. Using this vision to guide us, we can find the best answers to problems that arise and serve our staff and our clients at the highest possible level each and every day.
I challenge you to create your own vision – both personally and professionally. As a coach once told me, once you know your destination, the path becomes clearer. Take time to dream big and develop that vision. And if you need a little help, grab “Full Steam Ahead!” for an easy read and a roadmap to start your journey.
You survived the initial business closures associated with COVID-19 and were lucky enough to obtain Paycheck Protection Program (PPP) and/or Economic Injury Disaster Loan (EIDL) funding. You may have even muddled through forgiveness applications. But you still need to figure out how to account for all this in your financial statements! Just like everything else associated with COVID-19, nothing is simple.
PPP Funding
PPP dollars are considered conditional contributions under generally accepted accounting principles, with the condition being government approval of forgiveness. As such, cash received is initially recorded as a “refundable advance” liability on the statement of financial position. Once the Organization is notified that forgiveness is approved, the conditional contribution becomes unconditional. At this time, the refundable advance can be zeroed out and recognized as restricted revenue. The restriction relates to the requirement that funds must be spent on payroll, rent, utilities, etc. as specified in the funding documents. The restriction will be immediately released since it has already been met at the time of forgiveness. If it becomes certain that a portion of the PPP funding will need to be repaid, the “refundable advance” liability becomes long-term debt, no different than other bank borrowings.
As the PPP forgiveness process continues to be clarified, the accounting for PPP gets muddier. The accounting profession has been debating whether formal forgiveness is necessary to recognize PPP revenue. If your organization has calculated the forgiveness, compiled supporting documentation, and deem formal forgiveness merely an administrative process and not a barrier, you may be able to recognize the revenue in advance of formal forgiveness.
In addition, interest at 1% begins accruing immediately based on the terms of the agreement with the lender. However, there is debate in the accounting profession as to when/if this liability should be recorded on the financial statements. In general, the liability should not be significant if you are anticipating qualifying for PPP forgiveness, and you can likely avoid recording the interest until more clarification is received.
EIDL Funding
EIDL dollars from the Small Business Administration may have arrived in two different forms – an initial advance of up to $10,000, and a formal loan that must be repaid. EIDL dollars have no restrictions on spending and can be used for any operational costs. The initial advance is considered an unrestricted contribution and is recorded as revenue at the time it is received. The loan funds are recorded as long-term debt. Don’t forget to consider any related accrued interest – this can become significant to some organizations since repayment does not begin immediately.
Consideration of Federal Funds
The Office of Management and Budget has clarified that PPP funding is NOT considered to be federal dollars and is NOT subject to Uniform Guidance audit requirements. However, any EIDL funding received, whether in the form of loans or grants, is required to be included on your Schedule of Federal Awards. In some cases, this funding could push total federal expenditures over $750,000 and subject the organization to a compliance audit. In other cases, these funds could shift the compliance testing to a different federal program than was originally anticipated.
And remember – no double dipping! If PPP or EIDL dollars are used to cover certain payroll or other costs, those same costs can’t be used in other grant drawdowns.
Audit Disclosures
You can expect additional financial statement disclosures related to the pandemic and any applicable funding the organization received, even if the events happened after the close of the fiscal year. Be prepared to visit with your auditors about the organization’s ability to continue operations, cash flow and budget projections, investment declines, and the status of any forgiveness application that has been filed. If business continuity is uncertain, the audit opinion letter may include a going concern disclosure that clearly identifies the challenges you face.
Don’t let accounting for these unique cash flow streams become frustrating. The experts at Ketel Thorstenson, LLP are here to assist you in navigating the accounting details summarized above and are happy to assist you!
We want you to know we are ready to help as you face the challenge of keeping employees on the payroll and operating at the level necessary to serve our community during this unprecedented time. We at KT have had a chance to digest the Families First Coronavirus Response Act and the Coronavirus Aid, Relief and Economic Security Act (CARES). We’ve been deep in the details and are continuing to learn more every day. All these laws have little caveats and triggers that need to be carefully considered. We are continuing to update our website with information as we get it. If you are not receiving our emails and newsletters, please let me know so you can be added to our list.
See the attached summary of the Families First Coronavirus Response Act for details regarding specific eligibility, amount of payment, exemptions, etc. This is effective April 1, 2020. The basic premise of this law is as follows:
Emergency family and medical leave must be provided to employees who can’t work because their child’s school or daycare provider is closed or unavailable due to coronavirus emergency/declaration.
Emergency paid leave must be provided to employees if they are missing work because of coronavirus (i.e. government or medical quarantine/isolation of employee or someone they are caring for, seeking medical diagnosis, or caring for child whose school or daycare is closed). If employees choose to self-isolate, this provision does not apply.
Tax credits are available to offset wages paid under the above provisions – you can reduce your payroll tax deposit by the amount of the credit. Forms will be available soon to submit a refund claim if the reduction in payroll tax deposit is not enough to cover employee wages paid under these provisions.
See the attached SBA Loan Program Summary – this is the best summary we have found. These loans are good until they run out and are available to nonprofit organizations.
The Paycheck Protection Program (PPP) covers the cost of retaining employees. These loans are available through your banker – visit them soon to make sure this loan is right for you and to get an application started – funds are not unlimited!
Loan amounts are based on 2.5X the prior year’s average payrolls. See page 4 regarding forgiveness of these loans.
For the 8 weeks following the date you receive the loan, four things are totaled to figure the amount of the loan forgiven (interest on mortgage debt and secured equipment loans, rent, utilities, and payroll costs). However, there is a catch – the amount of forgiveness is reduced by a ratio of employees maintained during the 8 weeks compared to the average FTE’s in prior periods.
A couple of hints to maximize amounts you can receive under this loan program: (1) if you lease your building from a third party and are asking for rent relief, ask for that relief after the 8-week period has passed; (2) pay as many bills as possible related to the above eligible costs during the 8-week time frame.
If you choose not a pursue a PPP loan, two other options may be available to your organization (see page 10):
The employee retention credit is equal to 50% of wages for employees who were furloughed or had their hours reduced. Employers are eligible in the event of a government order limiting your operations or if you experience over 50% reduction in quarterly receipts.
Payroll tax deferral of 2020 employer social security taxes (6.2%) – half must be paid in 2021, with the remaining half paid in 2022.
The Economic Injury Disaster Loans & Emergency Economic Injury Grants (EIDLs – see page 7) – these loans provide an immediate grant, as well as additional loan funds. Amounts can be used for any expenses that could have been met if the disaster had not occurred, including payroll and other operating costs. The application process does not go through the bank, but you will need to apply quickly before funds run out!
Within 3 days of application, your organization receives an advance of $10,000 to be used for employee sick leave, payroll, rent, or mortgage costs. This grant does not have to be repaid, but is subtracted from the PPP loan amount forgiven.
Additional funds are in the form of loans up to $2M. Interest rates are set at 2.75%, and payments of principal and interest are deferred for 4 years.
Unemployment benefits have been significantly expanded, and any layoffs due to COVID-19 will not impact your experience rating. This may be an option that will allow employees to stay afloat in the short-term, keep only essential staff on the payroll, and then bring them back when you are ready.
Many of your employees may be working remotely, taking home confidential information, performing different job responsibilities, or not working at all. In addition to the stress this creates on normal operations, it can also create significant segregation of duties issues as your processes are required to change. Extra stress on employees, combined with new opportunities to circumvent internal controls, can result in errors or fraud. Don’t forget to maintain as much monitoring and segregation of duties as possible.
Also consider budget revisions, cash flow projections, debt covenant waivers, and granting agency compliance waivers.
Charitable contributions up to $300 can be deducted in 2020 even if an individual can’t itemize on their tax return. Limits are also reduced for corporations making donations. Small amounts add up, so reach out to donors as the economy begins to recover!
Our team is available to answer your questions and support
your efforts – please reach out when you need us.
Your story is more than just your numbers! Most of us think of a tax return as a
regulatory requirement, but nonprofits have a unique opportunity to tell their
story through their Form 990. Surveys
show that donors, grantors, and potential board members seek out online information
about your organization before deciding where their support is most needed and
best used. One source of this online information
is an organization’s Form 990, which can be easily found on the IRS website, as
well as various charity watchdog websites.
To make your Form 990 stand out, consider what about your
organization will get the general public excited and entice them to become
involved, whether through monetary donations or volunteering. Paint a picture of what has been accomplished
over the year – how many people have been served in your programs, what
activities you have undertaken, how you have met your goals, etc. Don’t just say “we serve the homeless
population”. Instead, say “we housed an
average of 25 people each night in our shelter and served 25,000 meals to
individuals who would have otherwise been cold and hungry on the streets of our
community”. Also be transparent in
explaining best practices, related party transactions, etc. Providing the right
amount of information will avoid unanswered questions that might turn away
potential contributors.
Remember, it’s not just the numbers – the Form 990 is a blank
slate you can use to make an impact on anyone reading it. Work with your CPA today to educate the
public and create a more effective message that will resonate and stand out!
The landscape surrounding revenue recognition is changing dramatically in 2019, and nonprofit organizations are not exempt from its effects. In fact, the way you record revenue for certain types of transactions could be changing.
Two new
revenue recognition standards are effective for years ending December 31, 2019. One relates specifically to contributions and
grants (which affects most nonprofits), and one covers most other revenue
sources (which will have minimal effect for most nonprofits). Both standards are intended to reduce diversity
in practice and ensure all organizations are recording revenue in the same
manner. Some of the key issues included
in these standards include:
Membership Dues
Currently,
membership dues are recorded over the term of the membership period, regardless
of what benefits the member is receiving.
Under the new guidance, you will need to document exactly what the
member is paying for and analyze each of those components to determine how
revenue should be recognized. For
example, if a member pays $100 for annual dues, receives quarterly newsletters,
and has access to your facility and website (which is not available to nonmembers),
each of those items is considered to be a performance obligation for which a
portion of the $100 in dues must be allocated.
The timing of recording that revenue may also change – for example, the
portion of revenue related to the newsletters would be recognized at the time
the newsletter is delivered to the member, while the portion related to
facility access would be recognized over the term of the membership.
Nonrefundable Upfront Fees
Many
nonprofits charge an application fee to cover the cost of processing
applications for reduced rate services, low income housing, etc. These fees were generally recorded as revenue
at the time of receipt due to the fact they were nonrefundable. Under the new guidance, nonprofits must
determine if the customer is receiving something in return for the application
fee. If the fee is merely to cover costs
of processing by the nonprofit, the customer receives nothing in return, and no
performance obligation exists.
Therefore, the fee should be recognized over the term of the service
that will be performed (e.g. over the term of the low-income housing
lease).
Splitting Transactions Between Contribution
and Exchange Transactions
Although the
accounting rules have always required consideration of what a donor receives in
return for their contribution, this analysis becomes more critical with the
change in revenue rules. For example, if
the nonprofit charges $500 per ticket for a fundraising dinner, the portion of
the ticket representing the cost of the meal provided is an exchange
transaction. The remaining portion of
the ticket price is a contribution. The
two different pieces of the transaction follow different revenue recognition
rules, and must be considered appropriately under those rules.
Grants
Significant
diversity in practice exists in accounting for grants, resulting in the
potential for nonprofits to account for the same exact grant in a different
manner based on how the accounting rules are interpreted. New guidance is meant to eliminate these discrepancies
and provide for more consistency in accounting.
Under this guidance, a clearer definition of when a grant is considered
a contribution exists. If the granting
agency does not receive commensurate value in return for the grant given to the
nonprofit, the grant is considered to be a contribution. The next step in the process would be to
determine if the grant is conditional or unconditional (see below). Unconditional grants are recorded with or
without donor restriction, with any restrictions being released upon satisfying
the donor’s wishes. The new accounting
guidance specifically states that the granting agency is not synonymous with
the general public – if the only benefit received by the granting agency is
societal benefit (e.g. housing the homeless), commensurate value is not
exchanged, and the grant is deemed to be a contribution. In many cases, nonprofits have been calling
these grants exchange transactions, so significant changes in timing of recognition
could occur.
Conditional Contributions
Another area
of diversity in the nonprofit accounting world relates to whether contributions
are unconditional (and can be recorded immediately) or conditional (and can’t
be recorded until conditions are met).
For a grant to be considered conditional, it must include a barrier to
overcome and either the right of return of assets transferred or the right of
release of the promisor’s obligation to transfer the assets. Barriers may be measureable performance-related
barriers (e.g. achieving a certain level of service or obtaining a certain
level of matching dollars before the contribution is given) or may stipulate
limits on how activities are conducted (e.g. approval of expenses before they
are allowed to be reimbursed or the hiring of a specific position). Administrative or trivial items, such as
filing of an annual report, are not considered to be barriers that would result
in a contribution being conditional.
The two new
revenue standards are complex and require a significant amount of analysis and
judgment. The above examples are not
all-inclusive and do not contain all the specific details that need reviewed in
order to determine the timing and amount of revenue your organization will
recognize. You will need to review the
standards closely and document your revenue streams in order to ensure
compliance. This will be a significant
component of your audit beginning with the December 31, 2019 financial
statements. Contact the experts at Ketel
Thorstenson, LLP today for assistance!
What?! Nonprofits pay tax on employee offered parking??
Yes, you read that correctly! A hidden provision in the 2017 Tax Cuts and Jobs Act makes employer-provided parking nondeductible. Because nonprofits don’t generally pay tax to begin with, parking is now considered a taxable event that requires filing of Form 990-T and payment of 21% tax. Here are a couple examples:
NPO pays third-party for employee parking. The payment made to this third-party equates to $100 per month per employee. Because this amount is below IRS limits, none of it is included as wages on the employee’s W2. However, it is taxable to the NPO, and a Form 990-T must be filed.
NPO owns its parking lot and reserves a certain number of spots for employees only. An allocation must be made to determine the cost of those spots, and a Form 990-T must be filed to pay tax on that amount.
The above examples are simplistic – there are many details for allocating costs in different situations, as well as instances when employer provided parking could be taxable to the employee. One way to avoid this situation is to never reserve parking spots for employee-only use. If you choose to offer the benefit, contact our non-profit experts to understand the tax implications.
Reporting Considerations for Successful Golf Tournaments
After a long winter, it is finally time to enjoy the beautiful outdoors of the Black Hills! The good weather also means a flurry of charitable golf tournaments. Although your development team takes the lead in seeking out businesses to be hole sponsors, donate prizes, and form teams of golfers, the accounting department also plays a critical role in all phases of the tournament.
Tournament Planning
Any communication made to golfers, sponsors, or donors by the development team has both accounting and tax implications. If the accounting department is not involved in these discussions in advance, unintended complexities and additional work could be created. Things to consider include:
Who will be collecting cash and soliciting prizes?
How much of the fee represents golf and cart rentals vs. contributions?
Are all in-kind contributions of prizes being tracked?
Do fundraising materials contain statements restricting tournament proceeds for any specific purpose of the organization?
Are sponsors receiving any substantial return benefit?
Tournament Controls
As with any significant process, internal controls surrounding cash collections should be reviewed to ensure no one individual has complete control over the process. This can be especially challenging if volunteers are utilized as part of the fundraising team. Prizes being solicited from area businesses should be logged and safeguarded. Involving more than one individual in this process will ensure the prizes make it to the tournament and are not kept for personal use. Receipts should be given for cash collected in advance. The numerical sequence of receipts should be tracked independently to ensure completeness. More than one individual should be involved in collecting cash at the event – dual control will prevent cash receipts from being taken. Also consider publishing a list of all donors and sponsors, along with contact information to notify the organization if the information is not accurate – this contact should be someone independent of the development and accounting staff.
Tournament Accounting
Several unique accounting considerations could apply to your golf tournament:
Participant fees should be split between direct donor benefits (i.e. fair value of green fees, cart rental, food, etc.) and contributions (any excess amount).
In-kind contributions should technically be recorded at fair market value at the time of the donation, and then removed from the general ledger when they are given out as prizes. The resulting contribution revenue and special event expense should be recorded.
If proceeds are restricted for a specific purpose, they need to be tracked in order to ensure funds are spent as intended.
Tournament Tax Implications
Splitting tournament fee revenue between direct donor benefits and contributions is also required for reporting your golf tournament properly on Form 990, as these are two separate line items.
If gross receipts from your tournament exceed $5,000, you may be required to report the event in more detail on Schedule G. This detail includes itemizing event expenses (e.g. food, facility rentals, and prizes).
Identifying the benefit tournament sponsors receive in exchange for their sponsorship is necessary to determine if sponsorship revenue results in unrelated business income tax. If a sponsor receives “substantial return benefit” (e.g. advertising beyond just identifying the sponsor), you may be subject to additional tax.
Tournament Wrap-Up
Your work is not done after the tournament is over. In addition to finalizing the accounting, you also need to consider two other important items:
Prizes paid to individuals that exceed $600 require 1099 reporting
Tournament donors (including golfers who paid more than fair value to participate) should receive acknowledgement letters thanking them for their donation and advising them of their charitable deduction. A good faith estimate of what the donor received in return for the contribution (i.e. green fees, meal, etc.), must be included in the acknowledgement. If the donor provided a non-cash prize, the acknowledgement should include a description of the item, but not a value.
You are now ready to hit the golf course! Contact the professionals at Ketel Thorstenson, LLP if you need any assistance or clarification as you plan your tournament.
As a reminder, Accounting Standards Update (ASU) 2016-14 is effective for 12/31/18 year-ends and will affect every nonprofit organization. In our last article, “Functional Allocation of Expenses,” we provided information on the guidance for allocating expenses between program and supporting services. The last provision of ASU 2016-14 is addressed in this newsletter series and relates to liquidity disclosures.
Nonprofit financial statements are sometimes seen as misleading and difficult to interpret. Because of the requirement to show contributions as revenue in the period pledged instead of the period spent, revenue and expenses related to contributions are not always recorded in the same fiscal year. This can cause large fluctuations in net income and detract from the operating results of the organization’s program activities. In addition, you might have assets on your balance sheet that aren’t available for current needs because they are restricted by certain donor stipulations. Your auditors may have tried to identify these issues when explaining your financial statements and comparing current results with those of prior periods. Under ASU 2016-14, a new concept is introduced that attempts to provide financial statement readers with this information in the form of qualitative and quantitative note disclosures.
The qualitative disclosure requirement requires nonprofits to explain how liquid resources are managed to meet cash needs for general expenditures within one year of the balance sheet date. The board of directors should approve a formal policy that addresses liquidity needs, as this policy has to be disclosed in the financial statements annually. Things to consider include strategies for addressing organization-wide risks (e.g. undesignating net assets and access to line of credit or long-term financing), establishing liquidity reserves, and the time horizon used to manage liquidity (e.g. 30, 60, or 90 days).
The quantitative disclosure requirement communicates the availability of financial assets at the balance sheet date to meet cash needs for general expenditures over the next year. Management will have to identify all financial assets and any limitations on their use in the next 12 months. This may include external limits (e.g. by donors or granting agencies) or internal limits (e.g. assets designated as a reserve for future building needs). All financial liabilities will also need to be identified. A reader will then be able to compare those liabilities with the available assets to gain an understanding of future liquidity needs. Although no specific format is required for this disclosure, it should reconcile to the balance sheet.
So, what does this look like? Here is a simple example:
The Board periodically designates a portion of any operating surplus to its liquidity reserve. As of December 31, 2018, the liquidity reserve was $1,300. This is a board-designated fund with the objective of setting funds aside to be drawn upon in the event of financial distress or an immediate liquidity need resulting from events outside the typical life cycle of converting financial assets to cash or settling financial liabilities. In the event of an unanticipated liquidity need, the organization could also draw upon $10,000 of available lines of credit or the quasi-endowment fund.
Financial assets at December 31, 2018 $229,200
Contractual or donor-imposed restrictions making
financial assets unavailable for general expenditure (192,413)
Quasi-endowment fund, primarily for long-term investing (34,628)
Amounts set aside for liquidity reserve (1,300)
Financial assets available within one year to meet cash
needs for general expenditures within one year $ 859
This example clarifies that although the balance sheet shows just over $229,000 in total assets, only $859 of those assets are available for operational needs within the next year. In addition, the reader is now aware that if liquidity becomes an issue, the organization will utilize line of credit borrowings or un-designate quasi-endowment dollars in order to make ends meet.
This is one very simple example to start the thought process of what may be relevant to your organization. Working through these disclosure requirements will be a useful tool for management and the board to assist them in better understanding the organization’s financial picture. It may also highlight instances in which going concern issues need to be addressed.
Reminder
The above provisions need to be adopted for your 12/31/18 financial statements. The nonprofit experts at Ketel Thorstenson, LLP are here to help you navigate the intricacies of ASU 2016-14. Call us at 605-342-5630 to set up a meeting now.
Functional Allocation of Expenses Under ASU 2016-14
As a reminder, Accounting Standards Update (ASU) 2016-14 is effective for 12/31/18 year-ends and will affect every nonprofit organization. In our last article, “Miscellaneous Provisions,” we provided information on some of the less publicized provisions of ASU 2016-14 – reporting of investment return, use of the indirect method of reporting cash flows, and release of restrictions related to donations for fixed asset purchases. Another provision of ASU 2016-14 addresses the functional allocation of expenses, with the goal of improving presentation and disclosure. This will affect every nonprofit organization, even those that already prepare a functional allocation.
Many nonprofit organizations are considered “voluntary health and welfare entities” – their purpose is to provide voluntary services for various segments of society that solve health or welfare problems. These organizations have always been required to functionally allocate their expenses in a full set of financial statements. In addition, every nonprofit organization having a Form 990 filing requirement completes a Statement of Functional Expenses. This information can be very useful to donors, and has also been known to be a point of contention in the media when a nonprofit shows a higher than usual percentage of their costs coded to administration.
With the implementation of ASU 2016-14, all nonprofit organizations will now be required to include an analysis of expenses by nature (e.g. salaries, utilities, etc.) and function (e.g. Program A, Program B, management, and fundraising) in one location. Three options are provided:
Present a separate statement of functional expenses – this option will likely be chosen by most organizations
Present a table in the notes to the financial statements
Incorporate the details into the statement of activities
Whether this is a new requirement for your nonprofit, or you have always presented this information in your financial statements, you should assess which presentation you prefer. It’s also a good time to reevaluate which functions are most meaningful to financial statement readers. The requirement includes allocating between programs and supporting services, but each nonprofit must define those functions. You may have more than one program, and your supporting services could include management duties, fundraising functions, and membership development. What programs do you talk to your donors or granting agencies about? Would it make sense to show each of these programs as a separate column to provide better financial information about their cost? Once this determination is made, you may need to update your chart of accounts to help you track some of these costs more appropriately.
In addition, allocation methodologies between program and supporting services should be reviewed. If not already in place, formal allocation methodologies that follow ASU 2016-14 and make sense based on operations, should be developed. Historically, management may have “guessed” what the allocation should be – e.g., “I spend about 10% of my time doing fundraising.” With the new reporting requirements, the allocation method will need to be disclosed, and “guesses” may not make the best disclosure in your financial statements! Instead, you are going to want to specify what methodology is applied. For example, occupancy costs might be allocated based on the square footage used for each program or supporting service, while salaries might be allocated based on time and effort expended.
Finally, ASU 2016-14 provides more guidance on management expenses than previous accounting literature. This is intended to reduce diversity in practice and improve comparability of financial statements between organizations. The new definition of management and general expenses is “supporting activities that are not directly identifiable with one or more program, fundraising or membership-development activity.” Each organization is unique and needs to analyze how its expenses support its activities; however some examples of what should be included in management include:
General recordkeeping and payroll
Budgeting
Financing, including interest costs not directly related to a program
Audit costs
Producing and distributing an annual report
Human resource functions, to include employee benefits management and oversight
As a “catch-all”, the standard clarifies that all other management and administration, except for the direct conduct or supervision of program activities, is considered management expense. Activities that represent direct conduct or supervision should be allocated to the functions they relate to. Examples might include:
IT benefits various functions and generally would be allocated
CEO salaries are likely allocated to program, fundraising, and management
HR does not provide direct supervision, so these costs are generally assigned to management
Grant accounting and reporting could be program (e.g. program related reports) or management (e.g. financial reports and related accounting activities)
Nonprofit organizations will want to perform this analysis prior to year-end to see how it affects the percentage of expenses charged to programs. Donors and watchdog agencies use these percentages to analyze and evaluate your nonprofit in comparison to others, so any significant fluctuations could be a red flag.
Reminder
The above provisions need to be adopted for your 12/31/18 financial statements. If preparing comparative financial statements, nonprofits who weren’t previously required to show functional and natural expenses in one statement, can omit that presentation for the previous year.
Watch for future articles on additional provisions of this new standard that will apply to your organization. The nonprofit experts at Ketel Thorstenson, LLP are here to help you navigate the intricacies of ASU 2016-14. Call us at 605-342-5630 to set up a meeting now.
As a reminder, Accounting Standards Update (ASU) 2016-14 is effective for 12/31/18 year-ends and will affect every nonprofit organization. In our last article, “New Presentation Rules for Donor Restrictions,” we provided information on the main provision of ASU 2016-14 – moving from three classes of net assets (unrestricted, temporary, and permanent) to two classes of net assets (with and without donor restrictions). Several other miscellaneous provisions may affect your organization, and this article explores those provisions.
Investment Return
Under current accounting rules, nonprofit organizations had the option to net investment fees against investment income (in which case, disclosure of the expense amount was required), or to present the fees as an expense. Under ASU 2016-14, investment return must be presented on a net basis. In other words, all external and direct internal investment management and custodial expenses must be netted against the income to show a net investment return. No separate disclosure of the expense is required, and the individual components of the investment return (e.g. interest, gains, etc.) are not required to be disclosed. The statement of activities will now show one line item labeled “investment return.” However, don’t forget these details are still required to be presented separately in Form 990, so you will need to continue tracking each component.
The concept of “direct internal investment expenses” is likely unfamiliar to most nonprofit organizations. The formal definition of this is “any internal expense that includes the direct conduct or supervision of the strategic and tactical activities involved in generating investment return.” In laymen’s terms, this:
Includes salaries, benefits, travel, and other costs associated with staff responsible for the development and execution of investment strategy, including supervising, selecting, and monitoring external managers.
Excludes costs not associated with generating investment return, such as administrative management, contracts, and pooled-fund administration (e.g. soliciting funds to add to an endowment are not directly associated with increasing investment return).
This portion of ASU 2016-14 is not applicable to programmatic investments. For example, if your organization makes loans to low-income individuals to promote home ownership, the expenses related to granting and monitoring these investments are not allowed to be netted against the interest income earned on the loans.
Organizations will need to ensure their accounting processes identify all external and direct investment management and custodial expenses so such costs can be reported in a separate general ledger account (or at least identified for reclassification at a later date). Some allocation methods may need to be implemented (e.g. CFO salary may include overseeing the investment portfolio). Management should be aware this change will also impact functional expense allocations – these expenses were likely allocated to management or fundraising costs in the past, and will now be excluded from expense totals.
Statement of Cash Flows
Most nonprofit organizations utilize the indirect method of reporting when presenting a statement of cash flows (i.e. start with change in net assets and adjust for changes in assets and liabilties). However, organizations have always had the option to utilize the direct method of reporting (i.e. show actual cash paid and received from various activities). Under legacy accounting rules, the direct method of reporting also required a reconciliation between the two methods. ASU 2016-14 removes this reconciliation requirement in the hopes of encouraging more organizations to consider utilizing the direct method of presentation. Management should consider the two methods and determine which presentation they find more useful – many financial statement users have argued that the direct method is intuitively easier for them to understand.
Fixed Assets
When nonprofit organizations receive contributions restricted for the purchase or acquisition of fixed assets, two options exist under current accounting rules as to when such restrictions are considered released:
Placed-in-service approach: the restriction expires at the time the asset is placed in service
Over time approach: the restriction is released over the asset’s useful life (e.g. release 1/5 of the contribution each year to match the 5-year useful life of the asset acquired)
ASU 2016-14 removes the second option above from the accounting guidance (unless a donor explicitly requires this method to be used). Most organizations have historically used the first option due to its simplicity, so it is not expected this change will affect many nonprofits.
Reminder
As the above provisions are adopted for your 12/31/18 financial statements, remember that if comparative financial statements are being presented, they must be restated to conform to the new accounting rules.
Watch for future articles on additional provisions of this new standard that will apply to your organization. The nonprofit experts at Ketel Thorstenson, LLP are here to help you navigate the intricacies of ASU 2016-14. Call us at 605-342-5630 to set up a meeting now.
