Guidance on valuing medical GIKs in the 2011 NPO Audit Risk Alert

The issue of determining fair value of donated pharmaceuticals has been quiet for a little while. I’ve not seen much discussion of mebendazole on the ‘net lately.  Perhaps it is safe to venture back into the waters.

I’d like to mention some of the accounting guidance that is around and provide a few comments.

The AICPA’s 2011 Not-for-Profit Entities Industry Developments Audit Risk Alert contains a two-page discussion of valuing gifts-in-kind (GIK).  SOme key paragraphs are quoted below along with my comments.

This is not an exhaustive discussion of the issue and is not a position paper.

This is intended to further the conversation on valuing GIKs, especially for people who don’t keep copies of the audit risk alerts on their nightstand for leisure reading. (You may now roll your eyes in pity for those of us who enjoy reading such things.)

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Jim Ulvog

Two more cautions on how to interpret overhead ratios

Came across two more articles reminding us to be careful in how we use overhead ratios to assess nonprofits. The functional allocation is a useful tool but needs to used and interpreted carefully.

Meaningless Fractions is a guest post at AidSpeak from Fredrick.

His concern is that the way overhead ratios are emphasized creates confusion between inputs and outputs. Overhead is one of many inputs. Delivering aid requires a wide range of inputs. In addition to infrastructure, an organization needs skilled people in the right locations at the right time, corporate knowledge of how to deliver effective aid, and dozens of other inputs.

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Jim Ulvog

Because of Americans who have fought over the last 236 years…

… yesterday I worshiped at a church that preaches what my group believes without the government caring what we proclaim.

…yesterday I led a Bible study explaining the Scriptures the way my group interprets them.

… this morning I browsed the sample ballot for the primary election a week from now and pondered who I will vote for in a free election in which I get to cast a secret ballot.

…tomorrow I will return to work in my own business pursuing my financial interests in the way I wish to do so and will keep the proceeds of my work after I pay a readily calculable tax to the government without fear of expropriation.

… I write this blog post with more freedom to say whatever I want than most people on the earth have today and with more freedom than most people throughout history ever dreamed of.

Thank you.

Thank you.

Thank you.

Update 6-6-12: Today my wife and I voted in our state’s primary. Thank you again to the heroes who laid down their lives to buy freedom so I can walk into a polling station and cast a secret ballot without fear.

Jim Ulvog

Background on HHS requirement to provide contraceptives in health insurance plans – part 2

There is a mandate from HHS that affects every health insurance plan in the country.  It will be going into effect for your health plan starting with the next plan year.  My previous post provided some initial background on the requirement.

For additional background, printed below is a newsletter from the Gammon and Grange law firm in the Washington, D.C. area.  The article can also be found here.

The article is so good that I am posting all of it.  I requested and received permission from the Gammon and Grange firm to post the full article.  My thanks to them for permission to do so. The article has their contact information at the end.

HHS Mandated Employer Health Insurance Requirements Begin August 1, 2012 –
Do you need to comply?

This week, the Franciscan University of Steubenville became the first university to cease offering health insurance to its students in response to what has become known as the “HHS Mandate.” As many religious employers are aware, on January 20, 2012, the Department of Health and Human Services (“HHS”) finalized regulations under the Patient Protection Affordable Care Act (“ACA Regs”). These ACA Regs require almost all employers with more than 50 employees to offer health insurance plans that will fully cover reproductive “preventive health services.” Covered services include sterilization procedures and the contraceptive drugs known as Plan B (the “morning after” pill) and ulipristal or ella (the “week after” pill), which are considered to be abortifacients or abortion-inducing medicines.

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Jim Ulvog

Background on HHS requirement to provide contraceptives in health insurance plans – part 1

I don’t do politics on my blogs.  I’m not making an exception now or anytime in the future.

It is not political to speak up when official government policy will require you or your organization to compromise your faith-formed, scripture-driven, core religious beliefs.

That is the place many people are at with the requirement from HHS to include contraceptives, including abortifacients, in all healthcare plans.

Such a requirement is completely contrary to the beliefs of people from the Roman Catholic tradition, as we saw in the news yesterday. It also violates the core beliefs of many other people and organizations in the religious nonprofit community.  This isn’t a concern for everyone, but it will be a major issue for many traditions.

I don’t follow healthcare issues closely, but I think it is time to provide some background for readers of my blog.

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Jim Ulvog

Tweets I wish I’d sent from the 2012 Chick-FIl-A LeaderCast

  • #JohnMaxwell   People without passion in life are already dead – – they just haven’t made it official
  • #AndyStanley    Questions to clarify your thinking – #1 what would my replacement do?
  • #AndyStanley    Questions to clarify your thinking – #2 What would a *great* leader do?
  • #AndyStanley    Questions to clarify your thinking – #3 What story do I want to tell? (legacy)
  • #JohnMaxwell   Bet on yourself – Your best investment is you
  • #AndyStanley I’m not the smartest person around here. I’m just the leader.
  • #TimTebow   don’t worry about what you can’t control – critics and what they say
  • #TimTebow   focus on what you can control – your attitude and performance

I had a great time watching the LeaderCast.  After going through my notes a couple of times, wish I’d sent the above tweets.  I have a few more thoughts here and here.

Jim Ulvog

Are timelines of a document retention policy onerous? Yup.

When you look at the recommended retention times in a document retention policy you will see time frames like three years or seven years. For employment records you’ll see recommendations of seven years after termination.

I’m not an attorney, so I’ll discuss this from the perspective of an accountant.

You may look at those timelines and think that is quite burdensome. Well, yes, it probably is. So is sorting out what stuff gets put in which category.

However, those sorts of timelines are now the best practice for document retention. (more…)

Jim Ulvog

Sample document retention and destruction policies for religious nonprofit organizations

It is becoming increasingly important for nonprofit organizations to have a policy describing how long to keep different kinds of documents. A key part of any policy is to describe how and when to place a hold on document destruction.

Here are a few samples you could use to develop a document retention and destruction policy for your organization. Because of the wide-ranging legal issues, variations by state, and circumstantial application, I’m not comfortable producing a sample policy.

I have found a few that you could use as a starting point.  Here are some samples for your consideration.

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Jim Ulvog

Nothing like recovering from a computer failure to show how much change is going on

(cross-posted from my other blog, Outrun Change.)

One of the main computers I use in my business failed Sunday night. For various reasons, I’ve held off on making several major upgrades, like jumping to Windows 7 and Office 2010.

So I shopped for new computer, have it in place, and as of yesterday have almost all the software running. Still have a couple of things to bring online, but they can wait for the moment.

Making the jump to a host of new technology tools all at once highlights the volume of change surrounding us.

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Jim Ulvog

Evaluating a used car as an illustration of the differences between compilation, review, and audit

You could figure out how good a car is by looking at it from across the street. 

Or you could look inside & drive it around the block. 

Or you could take the car to your mechanic for a couple of hours to get it really checked out .

We can use that as an analogy of the differences between a compilation, a review, and an audit.

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Jim Ulvog

Conflict at TBN goes public

I’ve not been paying much attention over the years to the occassional conflict around Trinity Broadcasting Network. An article in The New York Times this week reports there is a major round of turmoil that is now visible.

Family Battle Offers Look Inside Lavish TV Ministry, by Erik Eckholm, reports on accusations of extravagant spending by Mr. and Mrs. Crouch leveled by one of their granddaughters and accusations of theft by the granddaughter leveled by TBN.

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Jim Ulvog

Waste

I don’t do rants on my blog.  Not my style.  Besides, who wants to hear that?

I’ve made a rare exception at my other blog, Outrun Change.  My post Waste shares the irritation I feel when I see waste, whether caused by unintended consequences in foreign aid, substance abuse, or lives wasted by failed education.

My feeble conclusion?  It is time to move beyond failed solutions that have failed for decades.  How about we find something that ends the waste of lives?

I mention my rant because I think many readers of this blog are motivated by wanting to end wasted lives.  At a deep level, I think that is the drive many of us feel when we want to change the world.

 

Jim Ulvog

Another article on donated meds and overhead ratios – the impact of substitution on our thinking process

An Op-Ed in the Los Angles Times by Jack Shakely, president emeritus of the California Community Foundation, discusses the impact of donated medicines on the functional allocation:  The worst way to judge a charity.

A friend of his was grouching about another NPO buying meds for $0.10 a pill and booking them as GIK revenue at $7.00.  Mr. Shakely looked at the organization’s web site and found they claim 90% of the contributions go to program, with 5% to G&A. That leaves 5% for fundraising.

He then wonders why we are putting so much emphasis on the functional allocation as the main measure of an NPO.

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Jim Ulvog