Non-profit accounting

California A.G. files complaint against a charity for overvaluation of donated medicine. That charity agrees to dissolve itself. Three other charities issued cease-and-desist order.

“The Evolution of Law; Bas Relief, Los Angeles Superior Court” by JoeInSouthernCA is licensed under CC BY-ND 2.0

(update: headline modified)

The conflict over donated pharmaceuticals has heated up again.

The California Attorney General has filed cease and desist orders against three large charities who received between 89% and 98% of their revenue from medical GIK.

Update:  Those percentages appear to include all GIK, not just medicines. For example, in 2015 Food for the Poor had $1,159M total income with $1,033M of donated goods, according to their audited financial statements. According to their 990 for 2015, of the total GIK $818.7M was drugs and medical supplies, $110.8M was clothing and household goods, with $103M of other GIK. For 2015 donated drugs and medical supplies are 70.6% of total support and revenue.

Update: For MAP in 2015, total drugs and medical supplies from Schedule M of the 990 ties to the donated inventory on the audited financial statements. The only other GIK listed on Schedule M are securities, which amount ties to the financial statements. For 2015, donated drugs and medical supplies are 97.8% of total revenue and support.  Likewise for CMMB, the drugs and medical supplies listed on Schedule M ties to the line donated pharmaceuticals, equipment and supplies on the audited financial statements. For 2015, donated drugs and medical supplies are 90% of total support and revenue.

A complaint was filed against another charity, National Cancer Coalition, for overvaluation of GIK. The charity conceded the state’s claims and agreed to terminate the charity’s existence.

The three large charities are Food for the Poor, MAP International, and Catholic Medical Mission Board.

The cease and desist orders can be found at the AG’s web site:

Actions regarding the charity closing its doors:

This post will describe the complaint against NCC and the stipulated judgment.

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Jim Ulvog

Free update on new and recent accounting rules from CCH

For a summary of the accounting rules released in 2017 and the most significant new rules from 2016, 2015, and 2014, check out A Closer Look: Discussion and Analysis of Current Accounting and Audit Issues.

CCH made this update available for free to people on their mailing list. I received permission from my editor at CCH to make it available on my blog.

Click here to download the 54 page newsletter. CCH does not  have a separate landing page for the document, so that link automatically downloads the newsletter. UPDATE:  If link didn’t work for you, please try again. I reloaded the link and it is working now.

 

For each of the accounting rules covered, the newsletter provides:

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Jim Ulvog

Various thoughts from continuing education classes this year, part 3. Not so good news on audit and peer review quality.

The road we CPAs need to be on, but not all of us are…
Image courtesy of Adobe Stock.

As I’ve mentioned here and here, I have reread my notes from several continuing education classes this year. Thought I would share a variety of stray ideas.

Probably need to note again that I have not gone back and read the original pronouncements supporting each idea and therefore I do not have a specific citation for you. (Reading three of the documents is the next step for  my writing project.)

I should probably throw in a disclaimer. All of the comments I’m mentioning were the opinion of the presenter, not the agency from whom the person was drawing a paycheck. That is why I’m not mentioning the names of the presenters, or even the CPE event. In addition, the rephrasing of their comments is my interpretation, not their words.

Here are some tidbits you might enjoy:

More interest in Financial Reporting Framework for Small- and Medium-sized Entities (FRF-SME)?

The FRF-SME framework is a non-GAAP alternative to GAAP. It is dramatically less complicated with the promise it will not be revised more often every three years.

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Jim Ulvog

Various thoughts from continuing education classes this year, part 2

“nonprofit” by sinclair.sharon28 is licensed under CC BY 2.0: EKG Technician Salary

As mentioned in the previous post, I’ve reread my notes from several continuing education classes this year. Thought I would share a variety of stray ideas.

For what it is worth here are some tidbits you might enjoy:

Presentation of not-for-profit financials – ASU 2016-14

Presenter said that if an organization wanted to break out the with restriction column into more detail there is nothing to resented been broken into two or three columns. Perhaps it could be columns for:

  • donor endowment
  • other with restriction contributions
  • time restrictions
  • total with donor restriction
  • without donor restriction
  • total (total column is not required, but total change in net assets is)

Another possibility to present more detail would be to present multiple lines within the with donor restriction column, such as contributions to donor endowment, various purpose restrictions, time restriction, and a subtotal.

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Jim Ulvog

Various thoughts from continuing education classes this year, part 1

Image courtesy of Adobe Stock.

As part of working on a big writing project, I’ve reread my notes from several continuing education classes this year. (More details later and a link to the published material much later.) Thought I would share a variety of stray ideas. Here are a few tidbits from the classes.

Probably need to note that I have not gone back and read the original pronouncements supporting each idea and therefore I do not have a specific citation for you. (Reading three of the documents is the next step for my writing project.)

For what it is worth here are some tidbits you might enjoy:

Leases – ASU 2016-02.

One of the key on/off switches is whether a particular transaction or document is a lease. That will require an assessment of each transaction.

Right of use assets (the new description) resulting from operating and financing leases need to be listed separately on the statement of financial position. Those two categories (operating right of use and financing right of use) will be presented separately from fixed assets.

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Jim Ulvog

FASB exposure draft on contributions and grants.

Image courtesy of Adobe Stock.

FASB has released an exposure draft which slightly redefines the distinction between revenues and contributions for the nonprofit world.

Exposure draft is called Not-for-Profit Entities (Topic 958) – Clarifying the Scope and the Accounting Guidance for Contributions Received and Contributions Made.

On 9/11/17 I watched FASB’s one hour webcast on the exposure draft. This is only the second time I’ve seen a presentation on the issue and I haven’t yet dived into the 51 page document. That means I’m just starting to understand the changes.

What I’m going to do here is give a high level introduction. Keep in mind this is just an overview without all the details. Furthermore it is my preliminary understanding after having only heard the presentation twice and looking at the slide deck once. Please don’t cite this in your workpapers!

This exposure draft does not call for any change in how transactions are presented in the statement of activities. Organizations can present particular transactions as either revenue or contributions as they wish. The point was made several times in the presentation that the rules spelled out here determine which model is used for recognizing a transaction, not what presentation is used on the statement of activity.

There is a fantastic graph in the slide deck that provides a good visualization of the current and proposed accounting. It is copyrighted and thus I won’t be presenting it here. I’m sure you’ll be seeing the graphic before you get very far into your study.

Here’s a breakout of how exchange transactions are currently handled. These are also called reciprocal transactions. Currently we think of these as revenue, although the verbal comments in the presentation indicate that is no longer necessarily how exchange transactions must be presented.

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Jim Ulvog

Before the tsunami hits it might be time to tune into the accounting rules on the horizon.

“tsunami” by hansol is licensed under CC BY 2.0

Updated for ASU 2018-08.

7/18/19 Update:  FASB voted on 7/17 to postpone the effective date for leases and credit losses.

While you have been sitting on the beach enjoying life this summer, have you noticed that dark, odd horizontal line out there on the horizon?

It isn’t a figment of your imagination. There really is a tsunami wave out there in the distance of the accounting ocean and it is going to hit the shore where you are sun bathing.

As if that wasn’t bad enough, there will be fresh waves of water hitting the beach over four years.

The good news? Maybe one or two or three of the waves will miss your organization.

Here is a quick glance of what’s on the horizon:

  • Overhaul NFP financial statement presentation
  • Restricted cash on cash flow statement
  • Revenue recognition for all entities
  • Grant and contribution recognition for NFPs
  • Most leases brought onto the statement of financial position
  • Credit losses on loans and receivables

Update: Comments added whether early adoption is or is not allowed.

Here is just a bit more detail:

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Jim Ulvog

Comments on changes to financial statement presentation during 2017 CalCPA Not-for-profit conference, part 2

Image courtesy of Adobe Stock.

Here are a few of the comments from CalCPA’s May 24, 2017 Not-for-profit conference about major overhaul of financial statement presentation that I thought would be of interest to others in the nonprofit community. This post addresses ASU 2016-14. Part 1 addressed tax, revenue recognition, and single audit update sessions.

Accounting update – The first presenter is a FASB staff person. While comments made are the presenter’s opinions, we ought to pay attention to such a person’s opinions. Another disclaimer is the following summaries are from me.

ASU 2016-14 is the document changing not-for-profit financial statement presentation. We all need to get to the place where ASU 2016-14 or 16-14 easily rolls off our tongues.

ASU 2016-14:

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Jim Ulvog

Helpful comments from 2017 CalCPA Not-for-profit conference, part 1

Image courtesy of Adobe Stock.

Here are a few of the comments from the May 24, 2017 Not-for-profit conference presented by California Society of CPAs that I thought would be of interest to others in the nonprofit community. Since all comments are the opinion of the speaker, neither their names nor organizations will be mentioned. The ideas mentioned can stand or fall on their own.

This is the first of two posts. The next discussion will address changes in financial statement presentation outlined in ASU 2016-14. In this post: tax, revenue recognition, and single audit.

Tax update:

  • It might just be possible that filing a form 1023 or 1023-EZ is so easy that people can get exempt status for an organization without knowing the requirements to properly operate a charity and maintain exempt status. In examinations to follow-up after exempt status is approved, the IRS is finding a lot of charities are out of compliance.
  • One of several focuses of the IRS is filing of FBARs, those forms used to report overseas bank accounts. One ripple effect of chasing money laundering is the impact on charities who have overseas accounts. Even though there is minimal risk of those accounts being used for tax evasion the FBAR filing requirement still apply. As a reminder, the deadline for filing FBARs is now April 15 with a six-month extension available.

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Jim Ulvog

Not-for-profit risk alert for 2017 is available

Cover of 2017 risk alert from the AICPA, used under fair use since I’m urging you to buy their product.

The 2017 risk alert for non-profits is available from the AICPA.

Highlighted updates this year include:

  • AUS 2016-14 – New financial statement presentation
  • ASU 2016-02 – Leases
  • SAS 132 – Going concern

If you don’t feel overwhelmed, you haven’t been paying close enough attention to recent pronouncements. If so, the risk alert will help you catch up.

If you are feeling overwhelmed, the risk alert is a great first step in getting comfortable.

Jim Ulvog

Free resource explaining overtime rules

Image courtesy of Adobe Stock.
Image courtesy of Adobe Stock.

The Evangelical Council for Financial Accountability has published a concise, free resource explaining many of the rules of overtime, especially in the context of the charity world.

You can find it here and get a copy merely by giving them your email address. Not to worry – I don’t think they are going to overload you with spam – I’ve signed up for several things from them and the only emails I get are for free resources and invitations to webinars that are actually of interest. Oh, and news that is of interest to those of us in the charity world.

Oh, did I say it was free?

Jim Ulvog

What to do about the new overtime rules since they are on hold?

Image courtesy of Adobe Stock.
Image courtesy of Adobe Stock.

The new overtime rules were set to go into effect tomorrow, December 1. The rules are on hold as a result of an injunction issued by a federal judge. What should charities do about changes that have been implemented, or announced, or on the drawing board?

Two articles have some suggestions:

11/29 – Baltimore Business Journal – Plenty of questions still surround blocked overtime pay law – It is very uncertain how the new overtime rules will be handled. Article cites the CEO of an outsourcing and payroll company. His advice is stay tuned to developments. The rules could be implemented, overturned, or modified.

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Jim Ulvog

Overtime rules on hold after federal judge issues nationwide injunction

Image courtesy of Adobe Stock.
Image courtesy of Adobe Stock.

…places a hold on the new rules regarding…

Image courtesy of Adobe Stock.
Image courtesy of Adobe Stock.

 

A federal judge in Texas issued an injunction putting on hold the new Department of Labor rule increasing the threshold for paying overtime. The judge concluded there was a reasonable likelihood (I don’t quite appreciate the technical description so will use casual wording) that the lawsuit by 21 states and a lot of businesses would succeed. He also concluded the rule could cause irreparable financial harm. Thus, he issued the injunction, which applies nationwide.

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Jim Ulvog

More background on revision to nonprofit reporting

Image courtesy of Adobe Stock.
Image courtesy of Adobe Stock.

The new rules revising not-for-profit financial reporting are a significant change although they are not as dramatic as what we saw a long time ago with SFAS #116 and #117.

ASU 2016-14, Presentation of Financial Statements of Not-four-Profit Entities, was issued August 18, 2016. You can find the document here.

I will write a series of articles going into detail on the new rules. In the meantime, here are a few more articles providing background.

8/18 – AICPA – FASB’s standard Aims to Improve Not-for-Profit Financial Reporting – good overview of most changes

8/18 – Journal of Accountancy – FASB modifies not-for-profit accounting rules – High level overview. Article also provides some background on the process. Revision of GAAP to require operating measures is still under consideration but will be part of the next phase.

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Jim Ulvog