GIK valuation

Increased disclosures for gifts-in-kind required by new accounting rule.

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In September 2020 the Financial Accounting Standard Board issued ASU 2020-07.  Formal title for the document is Not-for-Profit Entities (Topic 958) – Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets.

Contributed nonfinancial assets means gifts-in-kind. The ASU does not apply to donated services or donated financial assets such as stocks and bonds.

ASU 2020-07 will only change the presentation of GIK on the statement of activity and require additional disclosures in the notes. It will not require any change to the valuation of donated pharmaceuticals (accountants call that recognition).

You can get your own copy of ASU 2020-07 here.

Statement of activity

The total of GIK will need to be presented as a separate line within the revenue & contribution section of the statement of activity, separate from donated cash and any donated financial assets.

Note disclosures

There are a number of new note disclosures which will be required for gifts-in-kind:

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Jim Ulvog

Summary of GIK exposure draft

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FASB has provided an explanatory article and video for the exposure draft on gifts-in-kind disclosures.

The ED would require presenting GIK on a separate line of the statement of activity and additional disclosures in the notes. Most significant new disclosure would be the valuation techniques and inputs used for calculating value of the GIK.

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Jim Ulvog

FASB releases exposure draft on presentation and disclosure for gifts-in-kind.

    Image courtesy of FASB under Fair Use.

The exposure draft will require the amount of donated nonfinancial assets to be disclosed on a separate line in the statement of activities.  Some additional disclosures will be required. The main new disclosure is the technique and inputs used to value the GIK along with the principal market for the items.

The draft is titled Not-for-Profit Entities (Topic 958) / Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets.

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Jim Ulvog

Update on exposure draft for increased GIK disclosures

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FASB update presentation today (12/19/19) indicated the GIK disclosures project is moving forward as previously outlined.

An exposure draft is expected to be released in January 2020.  There will be a 60 day comment period.

Previous post described the outline and limited scope of the project as approved by FASB:

In condensed form, the project will require separate disclosure of donated goods on the face of the statement of activities and require some additional disclosures in the notes. There will not be any change in valuation of donated medicine.

Jim Ulvog

More articles on GIK valuation. The issue isn’t going away.

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Nicola White, writing at Bloomberg Tax, has several articles following up on the GIK valuation issue after the veto of California AB 1181 by the governor. If you have been following the issue, you will want to check her recent writing.

End of this post discusses the departure from FASB of a project manager long involved with nonprofit rulemaking.

The articles, with a few highlights:

11/4/19 – Bloomberg Tax – Small Fixes Eyed for Charity Accounting as California Backs Off – Article describes why FASB is strongly resistant to any change in GIK valuation.

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Jim Ulvog

FASB provides outline for new disclosures on GIK

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On November 6, 2019, FASB discussed the GIK valuation project.

Back on August 21, 2019, FASB set the scope for the project to include only nonfinancial GIK with measurement (that means valuation) off the table. Staff was directed to work toward an exposure draft (ED) that would address only presentation and disclosure. That means an ED will only describe how GIK is presented on the statement of activity and what information is explained in the notes.

According to minutes of the 11/6/19 meeting, available here, FASB ratified that previous scope.

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Jim Ulvog

How big is the world of donated medicine? Updated estimate.

Medical factory storage warehouse. Image courtesy of Adobe Stock.

This post updates the previous estimate of the volume of donated medicine for the relief & development community of the nonprofit world.

There are a few charities receiving big volumes of medicine donated by the pharmaceutical companies. Those charities then get all those meds distributed to charity clinics and hospitals around the world. That is incredible work which is improving the lives of millions upon millions of poor people around the world.

Following is an estimate of the size of that sector, with subtotal of charities with over $20 million of donated medicine and supplies, under $20 million, and zero reported meds:

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Jim Ulvog

Presentation at CalCPA Accounting and Auditing conference: “California GAAP” – A case study in valuation of donated medicine

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On October 24 at 3:55 I will be speaking at the California Society of CPAs Accounting and Auditing Conference where industry speakers and experts will provide comprehensive updates on current issues and emerging trends. The conference runs the 24th and 25th.

My topic is valuation of donated medicine in the not-for-profit community. I have the privilege of working with a 75 minute block of time.

If you are able to attend the session you will gain an understanding of the long-term enforcement effort at the federal and state level regarding valuation of donated meds. My concern is that the governor’s veto of AB 1181 is not the end of the enforcement actions considering what has happened over the last 9 years.

Title of the session is “California GAAP” – A case study in valuation of donated medicine.

Overview of the session from the conference schedule:

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Jim Ulvog

Governor vetoes AB 1181. More details and background on override.

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On Saturday October 12, 2019, Governor Newsom vetoed California AB 1181. The bill would require charities filing financial statements with the state Registry of Charitable Trusts to value donated medicine at the fair value in the market the medicine would be distributed.

Essentially this would have required charities to use values in the international market instead of the U.S. market.

The governor announce a list of bills he signed and vetoed. You can find the list here. By my count he signed 69 and vetoed 58 on Saturday.

Veto message

The governor’s veto message can be read here. In it he said:

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Jim Ulvog

Governor vetoes AB 1181

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On Saturday October 12, 2019, Governor Newsom vetoed California Assembly Bill 1181, which would have required charities filing financial statements with the state Registry of Charitable Trusts to value donated medicine at the fair value in the end recipient market. Essentially this would have required charities filing in the state to use values in the international market instead of the U.S. market.

More discussion will follow later today.

Update: more details in followup post.

Update: The post you are reading here was the initial one published immediately after I learned the governor vetoed the bill. Later on Sunday a wrote a longer post which provided far more background. For some reason, the majority of traffic coming into this blog is going to this short post. To provide more value to those arrive in this page, I will copy the additional info on the longer post here. Hope this info is helpful.

Followup to this post, which was previously published here. Additional info is the text of the governor’s veto message, background on the veto override protocol, and my assessment whether the bill is totally, completely dead or not:

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Jim Ulvog

More details on Food for the Poor’s settlement with Michigan Attorney General

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Previous discussion on 10/4/18 provided details on a settlement between Food for the Poor and the Michigan Attorney General.

Prior post provided explanation of the FFP appeal claiming 95% efficiency, the cost of 6 cents to provide a meal, and joint cost allocation of speakers who go out to raise funds.

I have obtained and read a copy of the settlement agreement with the AG.  There are a few more details that are worth describing.

Penalties

The settlement agreement was effective 9/27/18. It was announced the next day.

FFP denies their appeals were misleading and denies any violation of state law. They also deny doing anything wrong.  The charity does recognize

“…that modifying its solicitations would better emphasize its impact, as well as achieve greater transparency. Food For The Poor worked with the Department to modify its solicitation materials and resolve the Department’s concerns.”

FFP agreed to pay $250,000 to two charities in Michigan which feed poor people. The charity also agreed to pay the AG $50,000 as reimbursement for their litigation costs.

Issues and resolutions

Efficiency claims 

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Jim Ulvog

Discussion of possible ramifications and compliance issues for AB 1181.

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Nicola White has an article at Bloombergtax.com discussing the ripple effects of AB 1181 along with some pondering on compliance issues for charities and auditors:  California Drug Bill Could Hike Accounting Costs for Charities.

Full disclosure:  I am quoted in the article. Scary step for me is this was my first on-the-record interview. This is only the second time I’ve been quoted in an article.

This article is not behind a paywall.

If you have been following the GIK issue, you will want to read the full article.

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Jim Ulvog

Accessible copies of Final Cease and Desist Orders from California AG

The order may be final but case is not finished. Image courtesy of Adobe Stock.

If you are so interested, you can read for yourself the final cease and desist orders from the California AG against MAP International, Catholic Medical Mission Board, and Food for the Poor. They may be found at:

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Jim Ulvog

Recent articles and comments on GIK valuation

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There has been little discussion of the GIK valuation issue, especially regarding AB 1181, that I have noticed over recent weeks. Here are all the public comments I have seen. Let me know anything I missed.

Before getting to five articles, a quick minor comment on AB 1181.  It was officially enrolled on 9/18/19. As of this morning (10/2/19) the exact status of the bill is that on 9/25/19 it was “Enrolled and presented to the Governor at 3:30 p.m.” according to the bill’s history.

I’m still playing catch-up on understanding the legislative process here in California. I now know that a bill must go through ‘engrossing and enrolling’ before going to the Governor for his consideration. Based on looking at some other bills, the next step after presentation to Governor is for him to sign. Then the bill is ‘chaptered’, or given an official location in the state statutes.

All that detail means the bill could not have been signed by the Governor before 9/25/19.

According to the Assembly’s legislative calendar, the governor has through 10/13/19 to either sign or veto bills.

Articles

Bloomberg Tax – 8/21/19 – Crackdown May Stop Charities From Inflating Cost of Donations

Article provides good background on the medical GIK issue. Gives good, brief background on the FTC case against four charities in 2015. Also summarizes the new FASB project.

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Jim Ulvog

Not-for-Profit Advisory Committee agrees with FASB there is no need to change how donated medicine is valued.

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On 9/27/19 FASB sent out a FASB Action Alert. These are sent to people who sign up for various newsletters from FASB. This one is titled Not-for-Profit Advisory Committee Meeting Recap and summarizes their meeting on September 16 & 17, 2019.

This committee is referred to as NAC. They meet twice a year.

Main topic of discussion, based on the notes, was the FASB’s project on Not-for-Profit Reporting of Gifts-in-Kind.  You can keep track of the project by checking that web page.

I will quote several of the key comments in the email and summarize other comments:

NAC generally agreed that additional disclosure might be helpful to readers of financial statements.

Meaning of the following paragraph is that NAC concurs with FASB’s scope decision for this project to address presentation and disclosure and exclude any consideration of valuation:

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Jim Ulvog