Chapter 35. NOT-FOR-PROFIT ORGANIZATIONS

Ronald F. Ries, CPA

American Express Tax and Business Services, Inc.

Ian J. Benjamin, CPA

American Express Tax and Business Services, Inc.

The authors wish to acknowledge that the exhibits and inspiration for this work were derived from the work Financial and Accounting Guide for Not-for-Profit Organizations, Fifth Edition, by Price Waterhouse LLP, Malvern J. Gross Jr., Richard F. Larkin, Roger S. Bruttomesso, and John J. McNally (John Wiley & Sons, Inc., 1995).

THE NOT-FOR-PROFIT ACCOUNTING ENVIRONMENT

Not-for-profit organizations range from the large and complex to the small and simple. They include hospitals, colleges and universities, voluntary social service organizations, religious organizations, associations, foundations, and cultural institutions. All are confronted with accounting and reporting challenges. All are presently covered by authoritative accounting literature. This chapter discusses not-for-profit accounting and reporting conventions and examines accounting pronouncements, auditing concerns, and the regulatory environment applicable to different types of not-for-profit organizations. Health care organizations are covered in Chapter 36.

As this latest edition of the Handbook goes to press, there are many issues within our community, including the accounting environment, which requires all organizations, including not-for-profits, to adhere to accounting policies and principles with the utmost due diligence required to satisfy a scrutinizing public and government regulators.

(a) CURRENT STATUS OF ACCOUNTING PRINCIPLES.

Not-for-profit accounting has undergone a period of profound change. In the recent past, authoritative accounting principles and reporting practices were established for many not-for-profit organizations that previously had neither.

In 1972, the American Institute of Certified Public Accountants (AICPA) issued an Industry Audit Guide for hospitals. In 1973, an Industry Audit Guide for colleges and universities was issued. And in 1974, a third not-for-profit Industry Audit Guide, for voluntary health and welfare organizations, was issued. In 1990, the AICPA issued a new audit and accounting guide, "Audits of Providers of Health Care Service," to replace the 1972 hospital audit guide.

In late 1978, the AICPA issued Statement of Position (SOP 78-10), "Accounting Principles and Reporting Practices for Certain Nonprofit Organizations." SOP 78-10 defines accounting principles and reporting practices for all not-for-profit organizations not covered by earlier guides.

For several years, as the most current broad-scope pronouncement of the accounting profession on not-for-profit accounting, the SOP was the authoritative reference for not-for-profit accounting and reporting questions for the organizations covered, and it was consulted for guidance by other organizations on questions not addressed in their respective audit guides.

These guides and the SOP had a dramatic effect on not-for-profit accounting, as they represented the first authoritative attempt to codify accounting principles and reporting practices for the not-for-profit industry. However, inconsistencies existed among the four guides, and they frequently contradicted one another on key accounting concepts. Also, the accounting principles presented in the guides had limited authority as they constituted Generally Accepted Accounting Procedures (GAAP) only until formal standards were set on this subject by the Financial Accounting Standards Board (FASB).

By the early 1980s, persons interested in not-for-profit accounting issues had identified the following key areas of accounting that would have to be considered in unifying the diverse not-for-profit accounting practices:

  • Reporting entity (when controlled and affiliated organizations should be included in an entity's financial statements)

  • Depreciation

  • Joint costs of multipurpose activities, particularly those involving a fund-raising appeal (on what basis such costs should be divided among the various purposes served)

  • Revenue recognition for expendable/restricted receipts (when, in which fund, and how such items should be reported as revenue)

  • Display (what format should be used to present financial data)

  • Valuation of investments

  • Contributions (how these should be valued, when and how they should be reported)

  • Grants awarded to others (when these should be accrued and expensed by the grantor)

Before accounting principles could be written, concepts had to be developed. The FASB had originally excluded not-for-profits from concepts development, but later started a separate project for not-for-profits. The first concepts statement under this project was issued in 1980. SFACNo. 4, "Objectives of Financial Reporting by Nonbusiness Organizations," proved to be so similar to the corresponding statement for businesses (SFAC No. 1) that the FASB started thinking in terms of only one set of concepts. Indeed, SFAC No. 2 was amended to include not-for-profits; SFAC No. 6, "Elements of Financial Statements" covers both types of entities, although some parts of this statement deal separately with the two sectors.

The FASB identified five areas in which it planned to develop accounting principles for not-for-profits: depreciation, contributions, the reporting entity, financial statement display, and investments, and has issued the following standards that have revolutionized not-for-profit accounting.

  • Depreciation is the subject of SFAS No. 93. Effective in 1990, this requires all not-for-profits to depreciate long-lived tangible assets, except that museum collections and similar assets often considered to be inexhaustible need not be depreciated if verifiable evidence of their inexhaustibility is available.

  • Accounting for contributions received and made and for museum collections is the subject of FASB Statement No. 116, effective beginning in 1995. Upon adoption it requires a number of significant changes to accounting practices previously followed by many not-for-profit organizations. It requires immediate revenue recognition for all unconditional gifts and pledges, regardless of the presence of donor restrictions and regardless of the intended period of payment (pledges payable in future periods will be discounted to Present Value (PV). Donors will follow a similar policy for recording expenses and liabilities. Donated services of volunteers will be recorded by charities if certain criteria are met. Museum collection items will be capitalized unless certain criteria are met.

    The requirement for immediate recognition of revenue for purpose and time restricted gifts results from FASB's conclusion in SFAC No. 6 that unspent expendable restricted gifts do not normally meet the definition of a liability (deferred revenue).

  • Financial statement format was initially the subject of initial work by an AICPA task force. FASB issued a statement of financial accounting standards No. 117 on financial statement format in June 1993. It became effective in 1995, at the same time as the new standard on contributions (previous bullet).

  • In 1995, the FASB issued SFAS No. 124, "Accounting for Certain Investments Held by Not-for-Profit Organizations." Briefly, its requirements are that all marketable securities be reported at current value in the balance sheet, and that unrealized losses be reported in the unrestricted class of net assets (absent donor restrictions or law which would require reporting losses in a restricted class). A more detailed summary of this standard is at Section 35.2(i).

  • In 1999, the FASB issued SFAS No. 136, "Transfers of Assets to a Not-for-Profit Organization or Charitable Trust that Raises or Holds Contributions for Others." It differentiates situations in which not-for-profit organizations act as agents, trustee, or intermediaries from situations in which not-for-profit organizations act as donors and donees. It also indicates how organizations that act as agents, trustees, or intermediaries are to report receipts and disbursements of assets if those transfers are not its contributions as defined in SFAS No. 116 and how a beneficiary is to report its rights to the assets held by a recipient organization.

(i) Summary of Statement of Financial Accounting Standards Nos. 116 and 117.

Implementation Schedule.

Both Statements were issued in June 1993. They were effective for fiscal years beginning after December 15, 1994 (e.g., for a June 30 year-end entity, for the fiscal year ending June 30, 1996). Adoption of No. 117 must be made retroactively; adoption of No. 116 can be made either retroactively or prospectively. Copies are available from the FASB Order Department: P.O. Box 5116, Norwalk, CT 06856.

Statement of Financial Accounting Standards No. 117 (Display).

Statement No. 117 requires organizations to present aggregated financial data: total assets, liabilities, net assets (fund balances), and change in net assets. Some not-for-profits already do, but many have not done this in the past. Organizations are free to present data disaggregated by classes of net assets (corresponding to funds), but, except for donor-restricted revenue, net assets, and change in net assets, no detail by class is explicitly required.

Three classes of net assets are defined: unrestricted, temporarily restricted, and permanently restricted. Net assets of the two restricted classes are created only by donor-imposed restrictions on their use. All other net assets, including board-designated or appropriated amounts, are legally unrestricted, and must be reported as part of the unrestricted class, although they may be separately identified within that class as designated if the organization wishes.

Permanently restricted net assets will consist mainly of amounts restricted by donors as permanent endowment. Some organizations may also have certain capital assets on which donors have placed perpetual restrictions. Temporarily restricted net assets will often contain a number of different types of donor-restricted amounts: unspent purpose-restricted expendable gifts for operating purposes, pledges payable in future periods, unspent explicitly time-restricted gifts, unspent amounts restricted for the acquisition of capital assets, certain capital assets, unmatured annuity and life income funds, and term endowments.

One requirement that is a significant change for many organizations is the reporting of all expenses in the unrestricted class, regardless of the source of the financing of the expenses. As expendable restricted revenue will be reported in the temporarily restricted class, when these amounts are spent, a reclassification (transfer) will be made to match the restricted revenue with the unrestricted expenses.

A second requirement is that all capital gains or losses on investments and other assets or liabilities will be reported in the unrestricted class, no matter which class holds the underlying assets/liabilities, unless there are explicit donor restrictions, or applicable law, which require the reporting of some or all of the capital gains/losses in a restricted class. This practice will often have the effect of increasing the reported unrestricted net asset balance (and decreasing the other net asset balances), compared with previous reporting principles.

All organizations must report expenses by functional categories (program, management, fund-raising). Voluntary health and welfare organizations must also report expenses by natural categories (salaries, rent, travel, etc.) in a matrix format; other organizations are encouraged to do so. Reporting in functional categories is new for some organizations, mainly those that do not raise significant amounts of contributions from the general public, such as trade associations, country clubs, and many local churches.

A new financial statement for many organizations is a statement of cash flows, showing where the organization received and spent its cash. Cash flows will be reported in three categories: operating flows, financing flows (including receipt of nonexpendable contributions), and investing flows. This statement has been required for businesses for several years by SFAS No. 95, which should be consulted for further information.

Statement No. 95 permits either of two basic methods for preparing the statement of cash flows: the "direct" or the "indirect" method. Briefly, the indirect method starts with the excess of revenues over expenses and reconciles this number to operating cash flows. The direct method reports operating cash receipts and cash disbursements, directly adding these to arrive at operating cash flows. The authors believe the direct method is much more easily understood by readers of financial statements, and thus recommends its use.

Much of the information used to prepare a statement of cash flows is derived from data in the other two primary financial statements, some of it from the preceding year's statements. Thus, when planning to prepare this statement for the first time, it is helpful to start a year in advance so that the necessary prior-year data is available when needed.

Sample financial statements, illustrating formats that contain the disclosures required by Statement No. 117, are shown in Appendix C to the Statement.

Statement of Financial Accounting Standards No. 116 (Contributions).

This document establishes one set of standards for all recipients of contributions, replacing the four different standards in the four AICPA audit guides. It also sets standards for donors of gifts; no explicit standards have heretofore existed, except for private foundations. For-profit organizations are also covered by this part of the document.

Certain types of transactions are not considered contributions: transactions that are in substance purchases of goods or services (even though they may be called grants) and transactions in which a recipient of a "gift" is merely acting as an agent or intermediary for, and passes the gift on to, another organization. Unfortunately, there is not much specific guidance for how to distinguish these two situations from real contributions; organizations will have to use judgment on a case-by-case basis.

SFAS No. 116 explicitly introduces a new concept into accounting for contributions: the conditional promise to give (pledge). This concept has implicitly existed for a long time, but has never before been articulated so clearly. A conditional pledge is one that depends on the occurrence of some specified uncertain future event to become binding on the pledgor. Examples of such events are the meeting of a matching requirement by the pledgee, or natural or man-made disasters such as a flood or fire. The mere passage of time is not a condition. Note that the concept of a condition is completely separate from that of a restriction. Conditions relate to events that must occur prior to a pledge becoming binding on the pledgor; restrictions relate to limits on the use of a gift after receipt.

Unconditional pledges are recorded at the time verifiable evidence of the pledge is received. Conditional pledges are not recorded until the condition is met, at which time they become unconditional. Pledges payable in future periods are considered implicitly time-restricted and are reported in the temporarily restricted class of net assets until they are due. Long-term pledges are also discounted to their present value to reflect the time value of money (in accordance with Accounting Principles Board Opinion No. 21); this is a new practice for most organizations. Accretion of the discount to par value will be reported as contribution income.

All contributions are reported as revenue, in the class of net assets (unrestricted, temporarily restricted, or permanently restricted) appropriate to any donor restrictions on the gift, at the time of receipt of the gift. This applies to unconditional pledges as well as cash gifts. The presence or absence of explicit or implicit donor-imposed time or purpose restrictions on the use of a gift do not affect the timing of revenue recognition, only the class in which they are reported. This principle is a significant change in practice for many organizations, which have heretofore deferred donor-restricted gifts and all pledges until a later period when the restriction was met or the pledge collected. The effect is to report higher net asset amounts, mainly in the temporarily restricted class, than under previous principles. This principle has generated a lot of controversy between those who favor retaining the previous deferral method and advocates of the new standard.

Accounting by donors for pledges and other contributions will follow the same principles with respect to recognition and timing as the donees, though of course all the accounting entries are reversed: expense instead of revenue, pledges payable instead of pledges receivable. Also, for-profit donors do not categorize their financial reports into classes because this concept only applies to not-for-profits.

The reporting of the value of donated services of volunteers has changed for many organizations under SFAS No. 116. The new standard requires reporting such a value if either of two criteria is met: (1) the services create or enhance nonfinancial assets, or (2) the services require specialized skills, are provided by persons possessing those skills, and would typically otherwise have to be purchased by the recipient if volunteers were not available. If neither criterion is met, the services may not be recorded. Organizations need to consider which of their volunteer services meet either of the two criteria.

Another matter that was controversial during the process of developing SFAS No. 116 was the question of accounting for museum collections. An early FASB proposal was to require capitalization of such assets. After much discussion of the subject, FASB agreed to allow noncapitalization of these items, if certain conditions relating to the items were met and certain footnote disclosures made.

(ii) Decisions.

Organizations have a number of decisions available to them under SFAS Nos. 116 and 117. These are:

Restricted contributions:

  • Do we wish to report restricted contributions whose restrictions are met in the same accounting period as that in which they are received as restricted or as unrestricted support? (Contributions paragraph 14, third sentence.)

  • Do we wish to adopt a policy which implies that on gifts of long-lived assets, there exists a time restriction which expires over the useful life of the donated assets? (Contributions paragraph 16.)

Basic financial statement format:

  • What titles do we wish to use for the balance sheet and for the statement of activity? (No particular titles are required or precluded by SFAS No. 117.)

  • Do we wish to present additional detail in the statement of financial position of assets and liabilities by class? (Display paragraph 156, next-to-last sentence.)

  • Which of the sample formats for the Statement of Activities do we wish to follow? (Display paragraph 157 and its examples that follow.)

  • Do we wish to present a measure of "operations"? (Display paragraphs 23, 163–167) (See Appendix 35.6 for further guidance.)

  • Do we wish to prepare the statement of cash flows using the direct or the indirect method? (SFAS No. 95, "Statement of Cash Flows," paragraphs 27–28.)

  • Do we wish to present comparative financial data for prior year(s)? (Display paragraph 70.)

Classification of expenses:

  • On the face of the statement of activities, do we wish to categorize expenses by functional or by natural classifications? (Display paragraph 26, second and third lines.)

  • If we are not required to disclose expenses in natural categories, do we wish to make such disclosure voluntarily? (Display paragraph 26, last sentence.)

  • If expenses have not previously been categorized by function, what categories (beyond the basic categories of program, management, fundraising, membership-development) do we wish to present? (Display paragraphs 26–28.)

  • Do we wish to disclose the fair value of contributed services received but not recognized as revenues? (Contributions paragraph 10, last sentence).

Collection items:

  • If our organization has assets that meet the definition of collection items at Contributions paragraph 11, do we wish to capitalize these assets or not?

  • If we have not previously capitalized but now wish to capitalize these items, do we wish to do so retroactively, or only prospectively? (Contributions paragraph 12.)

  • If we choose to capitalize these items retroactively, how do we wish to determine their value for this purpose? (Contributions, footnote 4.)

Do we wish to present nonmonetary information, as discussed in Display footnote 6?

Do we wish to retain our fund accounting system and convert our financial data to the new class structure by worksheets prior to preparing the financial statements, or do we wish to convert our entire accounting system to reflect the three-class structure discussed at Display paragraph 3 and Appendix D?

The division of net assets (formerly called fund balance) into three classes—unrestricted, temporarily restricted, and permanently restricted—as set forth in SFAC No. 6, and other matters discussed in that document, has a significant effect on the format of the financial statements of many not-for-profit organizations.

(iii) AICPA Audit Guide and Other Guidance.

In 1996, the AICPA issued two new audit guides, one for health care organizations (discussed in Chapter 36 and one for all other not-for-profit organizations. It provides additional implementation guidance for FASB Statements Nos. 116, 117, and 124, as well as other matters affecting not-for-profit organizations. Topics it covers in particular detail include reporting of split-interest gifts and expenses. Its provisions are discussed throughout this chapter.

AICPA Guidance in Specific Areas.

The AICPA issues technical practice aids to address questions it receives from practitioners. Preparers of not-for-profit organization financial statements should be familiar with these Technical Practice Aids (TPAs) that are included in the AICPA publication Technical Practice Aids at Section 6140.

Important aids that relate to the implementation of SFAS Nos. and 117 include the following:

  • 6140.03 Lapsing of Time Restrictions on Receivables that Are Uncollected at Their Due Date. SFAS No. 116 requires that pledges receivable be recorded as temporarily restricted with an implied time restriction that expires on the due date. Practice is sometimes to release restrictions when a pledge is paid rather than when it comes due. This TPA clarifies that release should occur at the due date; the due date needs to be identified based on the specific circumstances.

  • 6140.04 Lapsing of Restrictions on Receivables if Purpose Restrictions Pertaining to Long-Lived Assets Are Met before the Receivables Are Due. Many organizations raise funds for capital campaigns for building projects with pledges that are payable over a period that extends some time after the building is placed in to service. SFAS No. 116 provides that restrictions expire when the last restriction expires, but the contributions specified for the current period are not considered time restricted. Accordingly, it may be appropriate to release the restrictions on capital campaign pledges when the building is placed into service.

  • 6140.05 NPO Accounting for Loans of Cash that Are Interest Free or that Have Below-Market Interest Rates. The TPA sets out the accounting to be followed to record the contribution of interest at fair value where an organization receives a loan that is interest free or below market. For loans with terms of more than one year, the value needs to be recorded for the full term of the loan at the time of the loan agreement, with recording of interest expense over the term of the loan.

  • 6140.06 Functional Category of Costs of Sales of Contributed Inventory. The TPA recommends that organizations establish a separate classification for such cost of sales as a supporting activity unless the item sold relates to a program activity, in which case it would be reported as such.

  • 6140.7 Functional Category of Costs of Special and 6140.08 Functional Category of the Costs of Direct Donor Benefits. The TPA clarifies that not all costs of special events, in particular the cost of direct benefits to donors, are fund-raising costs. However, direct benefits to donors are fund-raising costs if the donor has not paid specifically for those benefits in an exchange transaction such as purchasing a ticket to a special event.

  • 6140.9 Reporting Bad Debt Losses. This TPA clarifies that bad debt losses cannot be netted against revenue. It should be noted, though, that losses do not have to be treated the same way as expenses in the statement of activities. Accordingly, to the extent that there is a bad debt loss related to a pledge that has not yet come due, that loss can be recorded as a reduction in temporarily or permanently restricted net assets. This can be helpful to an organization in not increasing the percentage of expenses that relate to supporting activities.

  • 6140.10 Consolidation of Political Action Committee Political Action Committee PAC. This TPA clarifies that SOP 94-3 applies to the consolidation of political action committees (PACs). Accordingly, a PAC should be consolidated when its government committee is appointed by a not-for-profit organization that benefits from its activities.

  • 6140.11 Costs of Soliciting Contributed Services and Time that Do Not Meet the Recognition Criteria in FASB Statement No. 116. This TPA arose from the practice of recording the costs of soliciting volunteers as a program activity. This is of particular importance to the many organizations that use volunteers extensively in meeting their program goals. In many cases the value of these services is not recognized in the financial statements consistent with the requirements of SFAS No. 116. The TPA clarifies that SFAS No. 117 requires that all costs of soliciting contributed services be recorded as fund raising even if the contributed services are not recognized in the financial statements. Organizations with large volunteer departments need to separately identify those costs of soliciting volunteers from the costs of managing volunteers, which may well be program in nature if the volunteers are meeting program goals. If such fund-raising costs are significant, organizations may wish to identify them separately in the financial statements so that readers can relate fund-raising costs with the value of the funds raised.

(iv) Projects in Process.

As of early 2002, the FASB was working on the following additional projects that are particularly applicable to not-for-profit organizations. For current status, refer to the FASB Web site at www.fasb.org.

Combinations of Not-for-Profit Organizations, Goodwill, and Intangible Assets.

The FASB issued Statement No. 141, "Business Combinations," and specifically excluded not-for-profit organizations. SFAS No. 142, "Goodwill and Intangible Assets," delays implementation for not-for-profit organizations until the FASB issues a statement on the combination of not-for-profit organizations.

The FASB tentatively determined that not-for-profit organizations should follow SFAS Nos. 141 and 142 except for circumstances in which a different approach is appropriate because of circumstances unique to not-for-profit organizations. Currently, not-for-profit organizations are required to account for business combinations and acquired intangible assets following the guidance in APB Opinion No. 16, "Business Combinations," and APB Opinion No. 17, "Tangible Assets." However, practice varies considerably and this results principally from combinations where there is no exchange of consideration. Many combinations of not-for-profit organizations have been accounted for using the pooling-of-interest method. The elimination of that method in SFAS No. 141 requires the development of clear guidance for not-for-profit organizations.

The FASB has tentatively concluded that a standard when issued will require identification of the acquiring organization in all combinations. The standard will include criteria to help identify the acquiring organization.

The assets and liabilities, including intangible assets, of the acquired organization will then need to be valued in accordance with the criteria applicable to business organizations in SFAS Nos. 141 and 142.

For combinations with no exchange of consideration, the acquiring organization will record the acquisition as receipt of a contribution in accordance with SFAS No. 116 at fair value.

In situations in which the fair value of the liabilities exceeds the fair value of the assets, the FASB has tentatively concluded that the difference should be accounted for as goodwill. However, the FASB is expected to reconsider this conclusion prior to the issuance of an exposure draft. Alternative approaches would appear to be to reduce the value of acquired assets so as not to exceed the value of the liabilities or to record the excess as an expense at the time of the combination.

For combinations in which there is an exchange of consideration, the FASB would require that SFAS No. 141 be followed. However, if the consideration is only part payment, the fair value of all assets and liabilities would need to be computed and the difference reported as a contribution.

A major difference for most combinations of not-for-profit organizations is the adjustment of values of assets and liabilities of the acquired organizations to fair value and the requirement to record the value of acquired intangible assets, including the value of trademarks and donor lists.

The FASB has not completed its deliberations, and an exposure draft is not expected until the first quarter of 2003.

Consolidations Policy and Procedures.

The FASB has been considering a proposed Statement that would require business enterprises and not-for-profit organizations that control other entities to include those subsidiaries in their consolidated financial statements. "Control" would be defined as the nonshared decision-making ability of one entity to direct the policies and management that guide the ongoing activities of another entity so as to increase its benefits and limit its losses from that other entity's activities.

During 2001, the FASB determined that it had insufficient support to complete this project. FASB members had difficulty agreeing on the definition of "control." Accordingly, the FASB has suspended its work in this area. Not-for-profit organizations cannot expect new guidance in the near future, so the current rules on SOP 94-3 remain applicable (see Section 35.2(k), "Related Organizations.")

(b) GOVERNMENT AUDIT REQUIREMENTS.

Not-for-profit entities are increasingly subject to audit requirements imposed by government agencies. These requirements are discussed in Subsection 35.4(f) of this chapter.

NOT-FOR-PROFIT ACCOUNTING PRINCIPLES AND REPORTING PRACTICES

(a) PRINCIPAL ACCOUNTING AND REPORTING REQUIREMENTS.

The various accounting standards discussed in this chapter affect considerably the accounting and financial reporting of all types of not-for-profit organizations. A list of the most significant requirements follows.

Accounting for Contributions (see SFAS No. 116, SFAS No. 136, and the AICPA Audit Guide)

  • Pledges are recorded when an unconditional promise to give is communicated to the donee.

  • A conditional promise to give is not reported until the condition is met.

    • (The distinction between conditional and restricted gifts is not always clear.)

  • Pledges are discounted to their present value and are reported net of an allowance for the estimated uncollectible amount.

  • All gifts, including pledges and restricted gifts, are reported as revenue when received.

  • Donors (including for-profit donors) must follow the same rules as donees (in reverse—an unconditional pledge must be recorded as an expense and a liability when made). (Fund-raisers should take note of this, as it will affect some donors' willingness to make unconditional pledges.)

  • Split-interest gifts are essentially treated as pledges (Audit Guide, Chapter 6); these include:

    • Gift annuities, remainder annuity trusts, unitrusts, Pooled Income Funds (PIF), lead trusts.

    • Irrevocable trusts held by others are reported in the beneficiary's financial statements.

  • Gifts-in-kind are recorded at fair value—including property, use of property, equipment, inventory for sale or use, services by other organizations (including bargain purchases).

  • Donated services of individual volunteers are recorded only when specified criteria are met:

    • The services create or enhance nonfinancial assets (building something), or

    • The services require specialized skills, the volunteer possesses those skills, and the donee would typically have to purchase the services if the volunteer were not available (the services involve a significant and central activity of the entity).

  • A pass-through entity may not be able to record gifts as revenue, depending on the circumstances of the gift.

  • A museum does not have to capitalize its collection if certain criteria are met.

  • New principles apply to transfers of cash or other financial assets from a donor to a recipient organization that agrees to use the assets on behalf of or transfer the assets to a specified beneficiary.

  • If the recipient organization and the specified beneficiary are unaffiliated, the recipient organization reports the assets at fair value and a liability of equal amount. However, if the donor explicitly grants the recipient organization variance power—unilateral power to redirect the use of the assets to another beneficiary—or if the recipient organization and the specified beneficiary are financially interrelated, the recipient organization reports the fair value of the assets as a contribution received.

  • A specified beneficiary reports its rights to the assets as an asset at fair value while it has rights to the assets, unless the donor explicitly granted the recipient organization variance power. If the beneficiary and the recipient organization are financially interrelated, the beneficiary reports at fair value its interest in the net assets of the recipient organization and adjusts that interest for its share of the change in net assets of the recipient organization. However, if the recipient organization is explicitly granted variance power, the specified beneficiary does not report its potential for receipts from the assets held by the recipient organization.

Financial statement format (see SFAS No. 117 and the AICPA Audit Guide)

  • Required disclosures are: totals of assets, liabilities, net assets, change in net assets.

  • Net assets (formerly, fund balance) and revenue are categorized into three classes:

    • Unrestricted; temporarily restricted; permanently restricted (per donor restrictions only).

    • Restrictions imposed by nondonors do not change category (e.g., contracts).

  • Required disclosures for each class are: net assets, change in net assets.

  • A statement of cash flows is required (the "direct" method is preferred).

  • All expenses are reported in the unrestricted class.

    • Temporarily restricted net assets are reclassified to match related expenses.

  • Expenses are reported on a functional basis (program, management, fund raising).

  • Revenues and expenses are reported gross, not net (exception: investment management fees).

    • Related items (e.g., sales/cost of sales) may be shown as: gross, deduction, net.

  • (See below for treatment of capital gains/losses.)

  • Affiliated entities are combined if specified criteria are met (SOP 94-3):

    • For-profit affiliate: criteria based on ownership.

    • Not-for-profit affiliate: criteria based on control and economic interest.

Accounting for Investments (see SFAS No. 117 and 124)

  • Marketable securities are reported at current market value.

  • Capital gains and losses on endowment are reported mostly in the unrestricted class, unless state law or a donor stipulation specifies otherwise.

Other Matters

  • Depreciable assets must be depreciated (see SFAS No. 93).

  • Not-for-profits must follow requirements of generally accepted accounting principles (see SOP 94-2).

  • Joint costs of multipurpose activities can be allocated to program functions only if certain criteria are met:

    • Purpose; audience; content, including a call to action other than giving (see SOP 98-2, which replaced SOP 87-2).

  • Contribution rules in SFAS No. 116 do not affect the timing of revenue recognition for advance payments of earned income: dues, fees, sales, season tickets, and so on—these are still deferred until earned.

(b) BASIS OF ACCOUNTING: CASH OR ACCRUAL.

Not-for-profit organizations frequently maintain their records on a cash basis, a bookkeeping process that reflects only transactions involving cash. On the other hand, most commercial organizations, as well as many medium and large not-for-profit organizations, keep accounts on an accrual basis. In accrual basis accounting, income is recognized when earned and expenses are recognized when incurred. For bookkeeping purposes, either basis is acceptable.

Each accounting basis has certain advantages. The principal advantage of cash basis accounting is simplicity—its procedures are easy to learn and easy to execute. Because of this simplicity, a cash basis accounting system is less complicated and less expensive to maintain than an accrual basis system. A less complicated system will be easier for a volunteer bookkeeper who does not feel comfortable with the more complicated accrual methods. Because there is often no material difference in financial results between cash and accrual basis accounting for small organizations, the incremental cost of an accrual basis system may be unwarranted. In addition, many not-for-profit organizations think it more prudent to keep their books on a cash basis. They often do not want to recognize income prior to the actual receipt of cash.

The principal advantage of accrual basis accounting is that it portrays financial position and results of operations on a more realistic basis—a complex organization with accounts receivable and bills outstanding can present realistic financial results only on the accrual basis. In addition, accrual basis accounting usually achieves a better matching of revenue and related expenses. Also, many individuals who use the financial statements of not-for-profit organizations, such as bankers, local businesspeople, and board members, are often more familiar with accrual basis accounting.

Organizations wanting the accuracy of accrual basis accounting, but not wishing to sacrifice the simplicity of cash basis bookkeeping, have alternatives. They may maintain their books on a cash basis and at year end record all payables, receivables, and accruals. These adjustments would permit presentation of accrual basis financial statements.

An organization can also keep its books on a cash basis, except for certain transactions that are recorded on an accrual basis. A popular type of "modified cash basis" accounting is to record accounts payable as liabilities are incurred, but to record income on a cash basis as received.

(c) FUND ACCOUNTING.

Fund accounting is the process of segregating resources into sets of self-balancing accounts on the basis of either restrictions imposed by donors or designations imposed by governing boards.

In the past, most not-for-profit organizations followed fund accounting procedures in accounting for resources. This was done because many organizations regard fund accounting as the most appropriate means of exercising stewardship over funds. Reporting all the details of funds, however, is not required of all not-for-profit organizations, and in many cases is not recommended. Fund accounting, if carried to its logical extreme, requires a separate set of accounts for each restricted gift or contribution; this leads to confusing financial statements that often present an organization as a collection of individual funds rather than as a single entity. Today, many not-for-profit organizations are combining funds and eliminating fund distinctions for reporting purposes to facilitate financial statement users' understanding of the organization as a whole.

The FASB Standard on financial reporting (SFAS No. 117) specifically requires the reporting of certain financial information by what it calls "classes" rather than funds.

An infinite variety of funds is possible. To limit the number of funds reported, broad fund classifications may be used. One scheme commonly used today is classification of resources by type of donor restriction. Another criterion for classifying funds is the degree of control an organization possesses over its resources. Under this approach, funds are combined for reporting purposes into two groupings—unrestricted and restricted. A third approach classifies resources on the basis of their availability for current expenditure on an organization's programs. Under this approach, funds are combined into two categories, expendable and nonexpendable.

When resources are classified by type of donor restriction, four fund groupings are commonly used—current unrestricted, current restricted, endowment, and fixed asset funds.

The current unrestricted fund contains assets over which the board has total managerial discretion. This fund includes unrestricted contributions, revenue, and other income and can be used in any manner at any time to further the goals of the organization. For all not-for-profit organizations, "board-designated" funds should be included with current unrestricted funds. Board-designated funds are voluntary segregations of unrestricted fund balances approved by the board for specific future projects or purposes.

Current restricted funds are resources given to an organization to be expended for specific operating purposes.

Endowment funds are amounts donated to an organization with the legal restriction that the principal be maintained inviolate either in perpetuity or for a stated period of time and amounts set aside by the organization's governing board for long-term investment. Investment income on such funds is generally unrestricted and should be reported in the current unrestricted fund. Occasionally, endowment gifts stipulate restricted uses for the investment income, and such restricted income should be reported in the appropriate fund.

The fixed asset fund represents the land, buildings, and equipment owned by an organization. Since these assets are usually unrestricted in the sense that the board can employ (or dispose of) them in any manner it wishes to further the goals of the organization, fixed assets need not be reported in a separate fund, and may be reported as part of the current unrestricted fund.

(i) Reclassification of Funds into Classes.

Under SFAS No. 117, organizations must access each component of each fund on an individual basis to determine into which class that fund balance (net assets) should be classified. This assessment, as to the temporarily and permanently restricted classes, is based only on the presence or absence of donor-imposed restrictions. All funds without donor-imposed restrictions must be classified as unrestricted, regardless of the existence of any board designations or appropriations.

Following is a chart showing typical classes into which various types of fund balances will normally be classified:

Funds

Unrestricted

Temporarily Restricted

Permanently Restricted

[a]

[b]

[c]

[d]

[e]

Endowment

Quasi

Term

Permanent

Specific purpose, or current restricted

Board-designated

Donor-restricted

N/A

Loan

Board-designated

Donor-restricted[a]

Revolving[a]

Split-interest (annuity, life income, etc.)

Voluntary excess reserves

Unmatured

Permanent[b]

Fixed asset

Expended;[c] Board-designated

Donor-restricted unexpended; Expended donated

See note [d]

General/Operating

Unrestricted

Donor-time restricted

N/A

Custodian

All (on balance sheet only)[e]

N/A

N/A

[a] A permanently restricted loan fund would be one where only the income can be loaned, or, if the principal can be loaned, repayments of principal by borrowers are restricted to be used for future loans. A loan fund in which principal repayments are available for any use would be temporarily restricted until the loans are repaid, at which time such amounts would become unrestricted.

[b] For example, an annuity fund that, upon maturity, becomes a permanent endowment.

[c] Expended donor-restricted plant funds will be either unrestricted or temporarily restricted, depending on the organization's choice of accounting principle under paragraph 16 of SFAS No. 116.

[d] Fixed assets could be permanently restricted if a donor has explicitly restricted the proceeds from any future disposition of the assets to reinvestment in fixed assets. Museum collection items received subject to a donor's stipulation that they be preserved and not sold might also be considered permanently restricted.

[e] Note that because no transactions related to custodian funds are reported in the income statement of the holder of the assets, and because there is never a fund balance amount (assets are always exactly offset by liabilities), reporting of such funds as separate items becomes an issue only when a balance sheet is disaggregated into classes. The logic for reporting the assets and liabilities of custodian funds in the unrestricted class is that such assets are not the result of donor-restricted gifts, which is a requirement for recording items in one of the restricted classes.

(d) RECLASSIFICATIONS.

The use of fund accounting necessitates transfers in some situations to allocate resources between funds or classes. Financial statement readers often find it difficult to comprehend such reclassifications. In addition, if not properly presented, reclassifications may give the impression that an organization is willfully manipulating amounts reported as income.

To minimize confusion and the appearance of deception, transfers must not be shown as either income or expenses of the transferring fund. Reclassifications of the total organization are merely an internal reallocation of resources and in no way result in income or expense recognition.

Columnar statements, which present the activity of each class in separate, side-by-side columns, facilitate clear, comprehensive presentation of reclassifications.

(e) APPROPRIATIONS.

Appropriations (or designations) are internal authorizations to expend resources in the future for specific purposes. They are neither expenditures nor legal obligations. When appropriation accounting is followed, appropriated amounts should be set aside in a separate account as part of the net assets of an organization.

Appropriation accounting is both confusing and subject to abuse. It is confusing because "appropriation" is an ambiguous term, and many readers do not understand that it is neither a current expenditure nor a binding obligation for a future expenditure. It is subject to abuse because, when treated incorrectly, appropriations can appear to reduce the current year's excess of revenue over expenses to whatever level the board wants. The board can then, at a later date, restore "appropriated" funds to the general use of the organization.

The use of appropriation accounting is not recommended. If an organization wishes to follow appropriation accounting techniques and wants to conform with GAAP, it must be certain that appropriations are not presented as expenses and that they appear only as part of the net assets of the organization. Expenses incurred out of appropriated funds should be charged as expenses in the year incurred, and the related appropriations should be reversed once an expense has been incurred.

Disclosure in notes is an alternative to appropriation accounting. Under this approach, an organization does not refer to appropriations in the body of its financial statements but instead discloses such amounts only in notes to the financial statements.

(f) FIXED ASSETS.

Treatment of fixed assets is sometimes a perplexing accounting issue confronting not-for-profit organizations. There are three reasons some not-for-profit organizations have historically not recorded a value for fixed assets on their balance sheets. First, many not-for-profit organizations have not been as interested in matching income and expenses as are businesses. This being the case, management of these organizations has felt no compelling need to record assets and then charge depreciation expense against current income. Second, the principal asset of some not-for-profit organizations is real estate that was often acquired many years previously. In these inflationary times, many organizations do not wish to carry at cost and depreciate assets now worth several times their original purchase price. Third, many not-for-profit organizations plead poverty as a means of raising funds. By not recording fixed assets, they appear less substantial than they in fact are.

Confusion concerning fixed assets has been heightened by lack of a universally accepted treatment for fixed assets. Historically, there have been three common alternatives for handling fixed assets: immediate write-off, capitalization (with or without depreciation), and write-off, followed by capitalization.

Immediate write-off is the simplest method of treating fixed assets and is used most frequently for small organizations and those on a cash basis. Under this method, an organization expenses fixed asset purchases immediately on the statement of income and expenses.

The principal advantage of this approach is simplicity—the bookkeeping complexities of capitalization are avoided, and the amount of excess revenue over expenses reported on the statement of income and expenses more closely reflects the amount of money at the board's disposal.

The major disadvantage of immediate write-off is that the historical costs of an organization's fixed assets are not recorded, and its balance sheet does not present the true net worth of the organization. Another disadvantage is that expensing fixed assets may produce fluctuations in net income that are largely unrelated to operations. Finally, this approach does not conform with GAAP.

A second alternative available to an organization is to capitalize all major fixed asset purchases. Under this approach, all major fixed assets are reflected on the organization's balance sheet.

The principal advantage of this approach is that it conforms with GAAP and permits an auditor to express an unqualified opinion on an organization's financial statements. It also documents the amount of assets the organization controls, permitting evaluation of management performance, and allows the organization to follow depreciation accounting.

The major disadvantage of capitalization is that it renders financial statements more complex. An unsophisticated statement reader may conclude that an organization has more funds available for current spending than it actually has.

A third alternative is to immediately write off fixed asset purchases on the statement of income and expenses and then capitalize these assets on the balance sheet. This method permits an organization to report expenditures for fixed asset purchases on the statement of income and expenses, thus offsetting any excess of income over expenses that may have been caused by contributions received for fixed assets on its balance sheet.

However, this approach is very confusing, is inconsistent with other accounting conventions, does not permit depreciation accounting in a traditional sense, and does not constitute GAAP. Accordingly, the use of this approach is strongly discouraged.

(i) Fixed Assets Where Title May Revert to Grantors.

Some organizations purchase or receive fixed assets under research or similar grants which provide that, at the completion of the grant period, the right of possession of these fixed assets technically reverts to the grantor. If the grantor is not expected to ask for their return, a fixed asset, whether purchased or donated, should be recorded as an asset and depreciated as with any other asset.

(g) DEPRECIATION.

Depreciation has been as thorny a problem for not-for-profit organizations as the problem of fixed assets. If an organization capitalizes fixed assets, it is immediately confronted with the question of whether it should depreciate them: that is, allocate the cost over the estimated useful life of the assets.

Depreciation accounting is now a generally accepted practice for most not-for-profit organizations, and since 1990, it constitutes GAAP for all not-for-profit organizations. (Prior to that year it was optional for colleges.) SFAS No. 93, "Recognition of Depreciation by Not-for-Profit Organizations," requires not-for-profit organizations to record depreciation on fixed assets. Many arguments in favor of recording depreciation, such as the following, are valid for not-for-profit organizations:

  • Depreciation is a cost of operations. Organizations cannot accurately measure the cost of providing a product or service or determine a fair price without including this cost component.

  • Most organizations replace at least some fixed assets out of recurring income. If depreciation is not recorded, an organization may think that its income is sufficient to cover costs when, in reality, it is not.

  • If depreciation is not recorded, income may fluctuate widely from year to year, depending on the timing of asset replacement and the replacement cost of assets.

  • Organizations that are "reimbursed" by a government agency for the sale of goods or services must depreciate fixed assets if they wish to recapture all costs incurred.

  • Some not-for-profit organizations pay federal income tax on "unrelated business income." Depreciation should be reported as an expense to reduce income subject to tax.

Depreciation is computed in the same manner as that used by commercial enterprises. Depreciation is reported as an item of expense on the statement of income and expenses, and accumulated depreciation is reported under the "fixed assets" caption on the balance sheet.

If fixed asset purchases are capitalized but not written down through regular depreciation charges in the statement of income and expenses, it may be necessary to periodically write down their carrying value so that the balance sheet is not overstated. The preferred method of achieving this is to report the write-down as an expense on the statement of income and expenses and to reduce the asset value on the balance sheet.

(h) INVESTMENT INCOME.

Dividends and interest earned on unrestricted investment funds, including board-designated funds, should be reported as income in the unrestricted class.

Unrestricted investment income earned on endowment funds should also be reported as income directly in the unrestricted class.

Restricted investment income should be reported directly in the appropriate restricted fund. For example, if the donor of an endowment fund gift specifies that the investment income be used for a particular purpose, investment income should be reported directly in the temporarily restricted class rather than the unrestricted or the permanently restricted class.

(i) GAINS AND LOSSES ON INVESTMENTS.

The FASB reporting standard in Statement No. 117 required many organizations to change their method of reporting gains and losses on endowment funds from the method previously used and described in the seventh edition of this book. Briefly, the new method involves determining which portion of the gains are legally restricted, either by explicit donor restrictions or by applicable laws to which the organization is subject. All gains not so restricted will be reported directly in the unrestricted class rather than in the endowment fund.

Realized gains or losses on unrestricted investment funds should be reported directly in the unrestricted class. Unrestricted capital gains or losses may be reported in the statement of income and expenses as an income item along with dividends and interest, or they may be reported separately from other investment income, above the caption "Change in net assets."

Realized gains or losses on endowment investments were traditionally treated as adjustments to principal of the endowment fund. They have not been considered as income and were thought to possess the same restrictions as those that are attached to the principal. The legal status of gains or losses on endowment funds—as unrestricted income or as a component of restricted principal—is, however, currently discussed in SFAS No. 117. Where permitted by state law, such gains or losses should be treated as income and reported with dividends and interest in the unrestricted class above the caption "change in net assets." Restricted gains or losses may be treated in a similar manner except that they are reported in the appropriate restricted class.

Unrealized gains or losses did not pose accounting questions for not-for-profit organizations prior to 1973 because, before that year, investments could be carried only at cost and gains or losses were realized only at the time investments were sold or otherwise disposed of.

After 1973, the tenor of accounting pronouncements on the carrying value of investments and the treatment of unrealized gains or losses changed dramatically. In 1973 and 1974, the AICPA Industry Audit Guides for colleges and universities and voluntary health and welfare organizations permitted those organizations to carry their investments at either cost or market. Hospitals were required in 1978 to carry equity investments at market if the fair value dipped below cost. SOP 78-10 permitted covered organizations to carry investments at market or the lower of cost or market.

When investments are carried at market, gains and losses are recognized on a continuing basis. Realized and unrealized gains or losses should be reported together in a single caption: "net increase (decrease) in carrying value of investments." It is appropriate to report this increase or decrease in the same section in which investment dividends and interest are reported.

In 1995, SFAS No. 124 was issued. Its requirements include:

  • Equity securities that have readily determinable fair market values and all debt securities shall be reported at current fair value.

  • In the absence of donor stipulations or law to the contrary:

    • — Capital losses shall reduce temporarily restricted net assets to the extent that donor-imposed restrictions on net appreciation of the fund have not yet been met.

    • — Any remaining loss shall reduce unrestricted net assets.

    • — Gains that restore previous losses shall be reported in the unrestricted class.

Even when investments are carried at cost, if market value declines "permanently" below cost, the carrying value of this investment should be written down to the market value. This is accomplished by setting up a "provision for decline in market value of investments" in the statement of income and expenses in the same section where realized gains or losses are presented.

(j) CONTRIBUTIONS.

Support for a not-for-profit organization can be received in many different forms. Each of the types of contributions will be discussed in a separate section of this chapter.

In 1993, the controversy about proper accounting for contributions was settled by the issuance of SFAS No. 116, "Accounting for Contributions Received and Contributions Made." In brief, it says that all contributions, whether unrestricted or restricted, and in whatever form—cash, gifts-in-kind, securities, pledges, or other forms—are revenue in full immediately upon receipt of the gift or an unconditional pledge. (The practice in many organizations was for restricted contributions not to be deferred until the restriction was met.) The revenue is reported in the class of net assets appropriate to any donor-imposed restriction on the gift (unrestricted, if there is no donor-imposed restriction). It also contains guidance on accounting for donated services of volunteers and an exception to the normal rule when dealing with museum collection objects.

(i) Expendable Current Support.

Unrestricted Contributions.

This section discusses simple unrestricted cash gifts. Unrestricted gifts in other forms, such as pledges, gifts of securities, and gifts of equipment and supplies, are discussed in later sections. The general principles discussed here apply to all unrestricted gifts, in whatever form received.

Historical Practices. All unrestricted contributions should be recorded in the current unrestricted fund. This principle is fairly well accepted and followed by most not-for-profit organizations. What was not uniformly followed is a single method of reporting such unrestricted contributions. Some organizations followed the practice of adding unrestricted contributions directly to the fund balance either in a separate Statement of Changes in Fund Balances or in the fund balance section where a combined Statement of Income, Expenses, and Changes in Fund Balances was used. Others reported some or all of their contributions directly in an unrestricted investment fund, and worse still, some reported unrestricted contributions directly in the endowment fund as though such amounts were restricted. The result of all these practices was to make it difficult for the readers of the financial statements to recognize the amount and nature of contributions received. Sometimes this was done deliberately in an attempt to convince the readers that the organization badly needed more contributions.

Accounting for Unrestricted Contributions. All unrestricted contributions should be reported in the unrestricted class of net assets in a Statement of Income and Expenses or, if a combined Statement of Income, Expenses, and Changes in Net Assets is used, such unrestricted contributions should be shown before arriving at the "Excess of income over expenses" caption. It is not acceptable to report unrestricted contributions in a separate Statement of Changes in Net Assets or to report such gifts in a restricted class of net assets.

Bargain Purchases. Organizations are sometimes permitted to purchase goods or services at a reduced price that is granted by the seller in recognition of the organization's charitable or educational status. In such cases, the seller has effectively made a gift to the buyer. This gift should be recorded as such if the amount is significant. For example, if a charity buys a widget for $50 that normally sells for $80, the purchase should be recorded at $80, with the $30 difference being reported as a contribution.

It is important to record only true gifts in this way. If a lower price is really a normal discount available to any buyer who requests it, then there is no contribution. Such discounts include quantity discounts, normal trade discounts, promotional discounts, special offers, or lower rates (say, for professional services) to reflect the seller's desire to utilize underused staff or sale prices to move slow-moving items off the shelves.

Current Restricted Contributions.

Current restricted contributions are contributions that can be used to meet the current expenses of the organization, although restricted to use for some specific purpose or during or after some specified time. An example of the former would be a gift "for cancer research" (a "purpose restriction") and, of the latter, a gift "for your 20XX activities" (a "time restriction"). In practice, the distinction between restricted gifts and unrestricted gifts is not always clear. In many cases, the language used by the donor leaves doubt as to whether there really is a restriction on the gift.

Current restricted contributions cause reporting problems, in part because the accounting profession took a long time to resolve the appropriate accounting and reporting treatment for these types of gifts. The resolution arrived at is controversial because many believe it is not the most desirable method of accounting for such gifts.

The principal accounting problem relates to the question of what constitutes "income" or "support" to the organization. Is a gift that can only be used for a specific project or after a specified time "income" to the organization at the time the gift is received, or does this restricted gift represent an amount which should be looked on as being held in a form of escrow until it is expended for the restricted purpose (cancer research in the above example), or the specified time has arrived (20XX in the above example)? If it is looked on as something other than income, what is it—deferred income or part of a restricted net asset balance?

If a current restricted gift is considered income or support in the period received—whether expended or not—the accounting is fairly straightforward. It would be essentially the same as for unrestricted gifts, described earlier, except that the gift is reported in the temporarily restricted class rather than in the unrestricted class of net assets. But if the other view is taken, the accounting can become complex.

The approach required by SFAS No. 116 is to report a current restricted gift as income or support in full in the year received, in the temporarily restricted class of net assets. In this approach, gifts are recognized as income as received and expenditures are recognized as incurred. The unexpended income is reflected as part of temporarily restricted net assets.

Observe, however, that in this approach, a current restricted gift received on the last day of the reporting period will also be reflected as income, and this would increase the excess of support over expenses reported for the entire period. Many boards are reluctant to report such an excess in the belief this may discourage contributions or suggest that the board has not used all of its available resources. Those who are concerned about reporting an excess of income over expenses are therefore particularly concerned with the implications of this approach: a large unexpected current restricted gift may be received at the last minute, resulting in a large excess of income over expenses.

Others, in rejecting this argument, point out that the organization is merely reporting what has happened and to report the gift otherwise is to obscure its receipt. They point out that in reality all gifts, whether restricted or unrestricted, are really at least somewhat restricted and only the degree of restriction varies; even "unrestricted" gifts must be spent realizing the stated goals of the organization, and therefore such gifts are effectively restricted to this purpose even though a particular use has not been specified by the contributor.

There are valid arguments on both sides. This approach is the one recommended in the AICPA Audit Guide for Voluntary Health and Welfare Organizations and therefore has been very widely followed. It will now become the method used by all not-for-profit organizations if they want their independent auditor to be able to say that their financial statements are prepared in conformity with generally accepted accounting principles.

Grants for Specific Projects. Many organizations receive grants from third parties to accomplish specific projects or activities. These grants differ from other current restricted gifts principally in the degree of accountability the recipient organization has in reporting back to the granting organization on the use of such monies. In some instances, the organization receives a grant to conduct a specific research project, the results of which are turned over to the grantor. The arrangement is similar to a private contractor's performance on a commercial for-profit basis. In that case, the "grant" is essentially a purchase of services. It would be accounted for in accordance with normal commercial accounting principles, which call for the revenue to be recognized as the work under the contract is performed. In other instances, the organization receives a grant for a specific project, and while the grantee must specifically account for the expenditure of the grant in detail and may have to return any unexpended amounts, the grant is to further the programs of the grantee rather than for the benefit of the grantor. This kind of grant is really a gift, not a purchase.

The line between ordinary current restricted gifts and true "grants" for specific projects is not important for accounting purposes because the method of reporting revenue is now the same for both. What can get fuzzy is the distinction between grants and purchase of services contracts. Most donors of current restricted gifts are explicit as to how their gifts are to be used, and often the organization will initiate a report back to the donors on the use of their gifts. However, restricted gifts and grants usually do not have the degree of specificity that is attached to purchase contracts. Appendix 35.1 contains a checklist to help readers distinguish between gifts and purchase contracts in practice.

Prepayment versus Cost Reimbursement.

Grants and contracts can be structured in either of two forms: In one, the payor remits the amount up front and the payee then spends that money. In the other, the payee must spend its own money from other sources and is reimbursed by the payor.

In the case of a purchase contract, amounts remitted to the organization in advance of their expenditure should be treated as deferred income until such time as expenditures are made that can be charged against the contract. At that time, income should be recognized to the extent earned. Where expenditures have been made but the grantor has not yet made payment, a receivable should be set up to reflect the grantor's obligation.

In the case of a true grant (gift), advance payments must be recognized as revenue immediately upon receipt, as is the case with all contributions under SFAS No. 116. Reimbursement grants are recognized as revenue as reimbursements become due, that is, as money is spent that the grantor will reimburse. This is the same method as is used under cost-reimbursement purchase contracts.

Some organizations have recorded the entire amount of the grant as a receivable at the time awarded, offset by deferred grant income on the liability side of the balance sheet. This is no longer appropriate under SFAS No. 116. If the entire grant amount qualifies as an unconditional pledge (see below), then that amount must be recorded as revenue, not deferred revenue.

Investment Securities.

Frequently, an organization will receive contributions that are in the form of investment securities: stocks and bonds. These contributions should be recorded in the same manner as cash gifts. The only problem usually encountered is difficulty in determining a reasonable basis for valuation in the case of closely held stock with no objective market value.

The value recorded should be the fair market value at the date received. Marketable stocks and bonds present no serious valuation problem. They should be recorded at their market value on the date of receipt or, if sold shortly thereafter, at the amount of proceeds actually received. However, the "shortly thereafter" refers to a sale within a few days or perhaps a week after receipt. Where the organization deliberately holds the securities for a period of time before sale, the securities should be recorded at their fair market value on the date of receipt. This will result in a gain or loss being recorded when the securities are subsequently sold (unless the market price remains unchanged).

For securities without a published market value, the services of an appraiser may be required to determine the fair value of the gift. See Subsection 35.2(b) for further discussion of investments.

(ii) Gifts-in-Kind

Fixed Assets (Land, Buildings, and Equipment) and Supplies.

Contributions of fixed assets can be accounted for in one of two ways. SFAS No. 116 permits such gifts to be reported as either unrestricted or temporarily restricted income at the time received. If the gift is initially reported as temporarily restricted, the restriction is deemed to expire ratably over the useful life of the asset: that is, in proportion to depreciation for depreciable assets. The expiration is reported as a reclassification from the temporarily restricted to the unrestricted class of net assets. Nondepreciable assets such as land would remain in the temporarily restricted class indefinitely—until disposed of. (Recognizing the gift as income in proportion to depreciation recognized on the asset is not in conformity with generally accepted accounting principles.)

Supplies and equipment should be recorded at the amount that the organization would normally have to pay for similar items. A value for used office equipment and the like can usually be obtained from a dealer in such items. The valuation of donated real estate is more difficult, and it is usually necessary to get an outside appraisal to determine the value.

Despite some controversy over the subject, the new AICPA Audit Guide specifically requires the recording of a value for contributed inventory expected to be sold by thrift shops and similar organizations at the time the items are received. The amount will be an estimate based on the estimated quantities and quality of goods on hand and known statistics for the percentage of the goods that will eventually be sold for cash (versus given away or discarded).

Museum Collections.

SFAS No. 116 makes an exception for recording a value for donated (and purchased) museum collection objects, if certain criteria are met and certain disclosures are made. Owners of such objects do not have to record them, although they may if they wish.

Contributed Services of Volunteers.

Many organizations depend almost entirely on volunteers to carry out their programs and sometimes supporting functions. Should such organizations place a value on these contributed services and record them as "contributions" in their financial statements?

Criteria for Recording. The answer is yes, under certain circumstances. These circumstances exist only when either of the following two conditions is satisfied:

  1. The services create or enhance nonfinancial assets; or

  2. The services:

    1. Require specialized skills,

    2. Are provided by persons possessing those skills, and

    3. Would typically have to be purchased if not provided by donation.

If neither criterion is met, SFAS No. 116 precludes recording a value for the services, although disclosure in a footnote is encouraged. These criteria differ considerably from criteria in the earlier Audit Guides/SOP.

Creating or Enhancing Fixed Assets. The first criterion is fairly straightforward. It covers volunteers constructing or making major improvements to buildings or equipment. It would also cover things like building sets or making costumes for a theater or opera company, and writing computer programs, since the resulting assets could be capitalized on the balance sheet. The criterion says "nonfinancial" assets so as not to cover volunteer fund-raisers who, it could be argued, are "creating" assets by soliciting gifts.

Specialized Skills. The second criterion has three parts, all of which must be met for recording to be appropriate. The first part deals with the nature of the services themselves. The intent is deliberately to limit the types of services that must be recorded, thus reducing the burden of tracking and valuing large numbers of volunteers doing purely routine work, the aggregate financial value of which would usually be fairly small. SFAS No. 116 gives very little guidance about how to identify, in practice, those skills that would be considered "specialized," as opposed to nonspecialized. There is a list of skills that are considered specialized, but it merely recites a list of obvious professions, such as doctors, lawyers, teachers, carpenters. What is lacking is an operational definition of specialized that can be applied to all types of services. Appendix 35.2 contains a checklist to help readers make this distinction in practice.

The second part of the criterion will usually cause no problems in practice, as persons practicing the types of skills contemplated should normally possess the skills (if not, why are they performing the services?).

Would Otherwise Purchase. The third part of the criterion will be the most difficult of all to consider, as it calls for a pure judgment by management. Would the organization or would it not purchase the services? This is similar to one in SOP 78-10, which was as follows:

The services performed are significant and form an integral part of the efforts of the organization as it is presently constituted; the services would be performed by salaried personnel if donated services were not available ...; and the organization would continue the activity.

Probably the most important requirement is that the services being performed are an essential part of the organization's program. The key test is whether the organization would hire someone to perform these services if volunteers were not available.

This is a difficult criterion to meet. Many organizations have volunteers involved in peripheral areas which, while important to the organization, are not of such significance that paid staff would be hired in the absence of volunteers. But this is the acid test: If the volunteers suddenly quit, would the organization hire replacements? Appendix 35.3 contains a checklist to help readers assess this criterion.

Basis on Which to Value Services. An additional criterion that is not explicitly stated in SFAS No. 116 in connection with donated services is that there must be an objective basis on which to value these services. It is usually not difficult to determine a reasonable value for volunteer services where the volunteers are performing professional or clerical services. By definition, the services to be recorded are only those for which the organization would in fact hire paid staff if volunteers were not available. This suggests that the organization should be able to establish a reasonable estimate of what costs would be involved if employees had to be hired.

In establishing such rates, it is not necessary to establish individual rates for each volunteer. Instead, the volunteers can be grouped into general categories and a rate established for each category.

Some organizations are successful in getting local businesses to donate one of their executives on a full- or part-time basis for an extended period of time. In many instances, the amount paid by the local business to the loaned executive is far greater than the organization would have to pay for hired staff performing the same function. The rate to be used in establishing a value should be the lower rate. This also helps to get around the awkwardness of trying to discern actual compensation.

An organization may wish not to record a value unless the services are significant in amount. There is a cost to keep the records necessary to meet the reporting requirements, and unless the resulting amounts are significant, it is wasteful for the organization to record them.

Accounting Treatment. The dollar value assigned to contributed services should be reflected as income in the section of the financial statements where other unrestricted contributions are shown. In most instances, it is appropriate to disclose the amount of such services as a separate line.

On the expense side, the value of contributed services should be allocated to program and supporting service categories based on the nature of the work performed. The amounts allocated to each category are not normally disclosed separately. If volunteers were used for constructing fixed assets, the amounts would be capitalized rather than being charged to an expense category. Unless some of the amounts are capitalized, the recording of contributed services will not affect the excess of income over expenses, since the income and expense exactly offset each other.

The footnotes to the financial statements should disclose the nature of contributed services and the valuation techniques followed.

Use of Facilities.

Occasionally a not-for-profit organization will be given use of a building or other facilities either at no cost or at a substantially reduced cost. A value should be reflected for such a facility in the financial statements, both as income and as expense. The value to be used should be the fair market value of facilities that the organization would otherwise rent if the contributed facilities were not available. This means that if very expensive facilities are donated, the valuation to be used should be the lower value of the facilities that the organization would otherwise have rented. Implicit in this rule is the ability to determine an objective basis for valuing the facilities. If an organization is given the use of facilities that are unique in design and have no alternative purpose, it may be impossible to determine what they would have to pay to rent comparable facilities. This often occurs with museums that occupy elaborate government-owned buildings.

Where a donor indicates that the organization can unconditionally use such rent-free facilities for more than a one-year period, the organization should reflect the arrangement as a pledge and record the PV of the contribution in the same way as other pledges.

(iii) Support Not Currently Expendable.

Endowment Gifts.

Donor-restricted endowment fund contributions should be reported as revenue upon receipt in a restricted class of net assets: temporary in the case of a term endowment gift, otherwise permanent.

Gifts of term endowment are later reclassified to the unrestricted class when the term of the endowment expires. (If, upon expiration of the endowment restriction, the gift is still restricted— likely for some operating purpose—it would not be reclassified until money was spent for that purpose. If upon expiration of the term endowment restriction, the gift becomes permanently restricted, it should be recorded in that class initially.)

Pledges (Promises to Give).

A pledge[5] is a promise to contribute a specified amount to an organization. Typically, fund-raising organizations solicit pledges because a donor either does not want to or is not able to make a contribution in cash in the amount desired by the organization at the time solicited. In giving, as with consumer purchases, the "installment plan" is a way of life. Organizations find donors are more generous when the payments being contributed are smaller and spread out over a period of time.

A pledge may or may not be legally enforceable. The point is largely moot because few organizations would think of trying to legally enforce a pledge. The unfavorable publicity that would result would only hurt future fund raising. The only relevant criteria are: Will the pledge be collected and are pledges material in amount?

If these criteria are satisfied, then there are two accounting questions: Should a pledge be recorded as an asset at the time the pledge is received? If the answer is "yes," the next question is: When should the pledge be recognized as income?

Recording as an Asset. For many organizations, a significant portion of their income is received by pledge. The timing of the collection of pledges is only partially under the control of the organization. Yet over the years most organizations find they can predict with reasonable accuracy the collectible portion of pledges, even when a sizable percentage will not be collected. Accounting literature requires that unconditional pledges the organization expects to collect be recorded as assets and an allowance established for the portion that is estimated to be uncollectible.

Historically, there was considerable difference of opinion on this subject, with the AICPA Audit Guides and the SOP taking different positions. The College Audit Guide said recording of pledges was optional, and most colleges did not record them until collected. The other three guides required recording pledges, although their criteria and method of recording differed slightly. Now, SFAS No. 116 requires all organizations to record unconditional pledges.

Conditions versus Restrictions. The requirement in SFAS No. 116 is to record unconditional pledges as assets. Unconditional means without conditions. What is meant by conditions? FASB defines a condition as "a future and uncertain event" that must occur for a pledge to become binding on the pledgor. There are two elements to this definition: future and uncertain. Future means it has not happened yet; this is fairly clear. Uncertain is, however, more subject to interpretation. How uncertain? This will be a matter of judgment in many cases.

If a donor pledges to give to a charity "if the sun rises tomorrow," that is not an uncertain event; the sun will rise tomorrow, at a known time. If a donor pledges to give $10,000 to the Red Cross "if there's an earthquake in California," that is very uncertain (a geologist will say the eventual probability of an earthquake happening is 100 percent, but the timing is completely uncertain). This latter pledge would be conditional upon an earthquake occurring. Once an earthquake occurs, then the donor's pledge is unconditional (the condition has been removed), and the pledge would be recorded by the Red Cross.

Another example of a condition is a matching pledge (also known as a challenge grant). A donor pledges to give an amount to a charity if the charity raises a matching amount from other sources. (The "match" need not be one for one; it can be in any ratio the donor specifies.) In this case, the charity is not entitled to receive the donor's gift until it has met the required match. Once it does, it will notify the donor that the pledge is now due.

A third type of donor stipulation sounds like a condition, but it may or may not actually be one. A donor pledges to contribute to a symphony orchestra "if they will perform my favorite piece of music [specified by name]." (A cynical person would call this a bribe.) Yes, this is an uncertain future event, since the piece of music has not yet been performed, but how uncertain is it? If the orchestra might very well have played the piece anyway, then the "condition" is really trivial, and the event would not be considered uncertain. However, if the piece were one that the orchestra would be very unlikely to perform without the incentive represented by the pledge in question, then the event would be considered uncertain and the pledge conditional. In this case, the condition is fulfilled when the orchestra formally places the music on its schedule and so informs the donor.

Note that the concept of a condition is quite different from that of a restriction. Conditions deal with events that must occur before a charity is entitled to receive a gift. Restrictions limit how the charity can use the gift after receipt. Unconditional pledges can be either unrestricted or restricted; so can conditional pledges. Donor stipulations attached to a gift or pledge must be read carefully to discern which type of situation is being dealt with. For example, "I pledge $20,000 if you play my favorite music" is conditional but unrestricted (the donor has not said the gift must be used to pay for the performance), whereas "I pledge $20,000 for [the cost of] playing my favorite piece of music" is restricted, but unconditional. In the latter case, the donor has said the pledge will be paid but can only be used for that performance. The difference in wording is small, but the accounting implications are great. The conditional pledge is not recorded at all until the condition is met; the unconditional restricted pledge is recorded as revenue (in the temporarily restricted class) upon receipt of notification of the pledge. Appendix 35.4 contains a checklist to help readers determine whether an unconditional pledge actually exists. Appendix 35.5 contains a checklist to help distinguish conditions from restrictions.

Discounted to Present Value. Prior to SFAS No. 116, pledges were recorded at the full amount that would ultimately be collected. None of the accounting literature for not-for-profit organizations talked about discounting pledges to reflect the time value of money. There had been for many years an accounting standard applicable to business transactions that does require such discounting (APB No. 21), but not-for-profit organizations universally chose to treat this as not applicable to them, and accountants did not object.

SFAS No. 116 does require recipients (and donors) of pledges payable beyond the current accounting period to discount the pledges to their PV, using an appropriate rate of interest. Thus, the ability to receive $1,000 two years later is really only equivalent to receiving about $900 (assuming about a five percent rate of interest) now, because the $900 could be invested and earn $100 of interest over the two years. The higher the interest rate used, the lower will be the PV of the pledge, since the lower amount would earn more interest at the higher rate and still be worth the full $1,000 two years hence.

The appropriate rate of interest to use in discounting pledges will be a matter of some judgment. In many cases, it will be the average rate the organization is currently earning on its investments or its idle cash. If the organization is being forced to borrow money to keep going, then the borrowing rate should be used. Additional guidance is in SFAS No. 116 and APB No. 21.

As the time passes between the initial recording of a discounted pledge and its eventual collection, the PV increases since the time left before payment is shorter. Therefore, the discount element must be gradually "accreted" up to par (collection) value. This accretion should be recorded each year until the due date for the pledge arrives. The accretion is recorded as contribution income. (This treatment differs from that specified in APB No. 21 for business debts for which the accretion is recorded as interest income.)

Pledges for Extended Periods. There is one limitation to the general rule that pledges be recorded as assets. Occasionally, donors will indicate that they will make an open-ended pledge of support for an extended period of time. For example, if a donor promises to pay $5,000 a year for 20 years, would it be appropriate to record as an asset the full 20 years' pledge? In most cases, no; this would distort the financial statements. Most organizations follow the practice of not recording pledges for future years' support beyond a fairly short period. They feel that long-term open-ended pledges are inherently conditional on the donor's continued willingness to continue making payments and thus are harder to collect. These arguments have validity, and organizations should consider very carefully the likelihood of collection before recording pledges for support in future periods beyond five years.

Allowance for Uncollectible Pledges. Not all pledges will be collected. People lose interest in an organization; their personal financial circumstances may change; they may move out of town. This is as true for charities as for businesses, but businesses will usually sue to collect unpaid debts; charities usually will not. Thus another important question is how large the allowance for uncollectible pledges should be. Most organizations have past experience to help answer this question. If over the years, 10 percent of pledges are not collected, then unless the economic climate changes, 10 percent is probably the right figure to use.

Recognition as Income. The second, related question is: When should a pledge be recognized as income? This used to be a complicated question, requiring many pages of discussion in earlier editions of this Handbook. Now, the answer is easy: immediately upon receipt of an unconditional pledge. This is the same rule that applies to all kinds of gifts under SFAS No. 116. Conditional pledges are not recorded until the condition is met, at which time they are effectively unconditional pledges. Footnote disclosure of unrecorded conditional pledges should be made.

Under the earlier Audit Guides/SOP, pledges without purpose restrictions were recorded in the unrestricted fund. Only if the pledge has a purpose restriction would it be recorded in a restricted fund. Even pledges with explicit time restrictions were still recorded in the unrestricted fund, to reflect the flexibility of use that would exist when the pledge was collected. Under SFAS No. 116, all pledges are considered implicitly time-restricted, by virtue of their being unavailable for use until collected. Additionally, time-restricted gifts, including all pledges, are now reported in the temporarily restricted class of net assets. They are then reclassified to the unrestricted class when the specified time arrives.

This means that even a pledge not payable for 10 years or a pledge payable in many installments is recorded as revenue in full (less the discount to PV) in the temporarily restricted class in the year the pledge is first received. This is a major change from earlier practice, which generally deferred the pledge until the anticipated period of collection.

Sometimes a charity may not want to have to record a large pledge as immediate revenue; it may feel that its balance sheet is already healthy and recording more income would turn away other donors. If a pledge is unconditional, there is no choice: The pledge must be recorded. One way to mitigate this problem is to ask the donor to make the pledge conditional; then it is not recorded until some later time when the condition is met. Of course, there is a risk that the donor may not be as likely ever to pay a conditional pledge as one that is understood to be absolutely binding, so nonprofit organizations should consider carefully before requesting that a pledge be made conditional.

SFAS No. 116 requires that donors follow the same rules for recognition of the expense of making a gift as recipients do for the income: that is, immediately on payment or of making an unconditional pledge. Sometimes a charity will find a donor reluctant to make a large unconditional pledge but willing to make a conditional pledge. Fund raisers should be aware of the effect of the new accounting principles in SFAS No. 116 on donors' giving habits as well as on recipients' balance sheets.

Bequests.

A bequest is a special kind of pledge. Bequests should never be recorded before the donor dies—not because death is uncertain, but because a person can always change a will, and the charity may get nothing. (There is a special case: The pledge payable upon death. This is not really a bequest, it is just an ordinary pledge, and should be recorded as such if it is unconditional.)

After a person dies, the beneficiary organization is informed that it is named in the will, but this notification may occur long before the estate is probated and distribution made. Should such a bequest be recorded at the time the organization first learns of the bequest or at the time of receipt? The question is one of sufficiency of assets in the estate to fulfill the bequest. Since there is often uncertainty about what other amounts may have to be paid to settle debts, taxes, other bequests, claims of disinherited relatives, and so on, a conservative, and recommended, approach is not to record anything until the probate court has accounted for the estate and the amount available for distribution can be accurately estimated. At that time, the amount should be recorded in the same manner as other gifts.

Thus, if an organization is informed that it will receive a bequest of a specific amount, say $10,000, it should record this $10,000 as an asset. If instead the organization is informed that it will receive 10 percent of the estate, the total of which is not known, nothing would be recorded yet although footnote disclosure would likely be necessary if the amount could be sizable. Still a third possibility exists if the organization is told that while the final amount of the 10 percent bequest is not known, it will be at least some stated amount. In that instance, the minimum amount would be recorded with footnote disclosure of the contingent interest.

Split-Interest Gifts. The term split-interest gifts is used to refer to irrevocable trusts and similar arrangements (also referred to as deferred gifts) where the interest in the gift is split between the donor (or another person specified by the donor) and the charity. These arrangements can be divided into two fundamentally different types of arrangements: lead interests and remainder interests. Lead interests are those in which the benefit to the charity "leads" or precedes the benefit to the donor (or other person designated by the donor). To put this into the terminology commonly used by trust lawyers, the charity is the "life tenant," and someone else is the "remainderman." The reverse situation is that of the "remainder" interest, where the donor (or the donor's designee) is the life tenant and the charity is the remainderman, that is, the entity to which the assets become available upon termination (often called the maturity) of the trust or other arrangement. There may or may not be further restrictions on the charity's use of the assets and/or the income therefrom after this maturity.

Under both types of arrangement, the donor makes an initial lump-sum payment into a fund. The amount is invested, and the income during the term of the arrangement is paid to the life tenant. In some cases, the arrangement is established as a trust under the trust laws of the applicable state. In other cases, no separate trust is involved, rather the assets are held by the charity as part of its general assets. In some cases involving trusts, the charity is the trustee; in other cases, a third party is the trustee. Typical third-party trustees include banks and trust companies or other charities such as community foundations. Some arrangements are perpetual, that is, the charity never gains access to the corpus of the gift; others have a defined term of existence that will end either upon the occurrence of a specified event such as the death of the donor (or other specified person) or after the passage of a specified amount of time.

To summarize to this point, the various defining criteria applicable to these arrangements are:

  • The charity's interest may be a lead interest or a remainder interest.

  • The arrangement may be in the form of a trust or it may not.

  • The assets may be held by the charity or held by a third party.

  • The arrangement may be perpetual or it may have a defined term.

  • Upon termination of the interest of the life tenant, the corpus may be unrestricted or restricted.

Lead Interests. There are two kinds of such arrangements as normally conceived.[6] These are:

  1. Charitable lead trust

  2. Perpetual trust held by a third party

In both of these cases, the charity receives periodic payments representing distributions of income, but never gains unrestricted use of the assets that produce the income. In the first case, the payment stream is for a limited time; in case two, the payment stream is perpetual.

A charitable lead trust is always for a defined term, and usually held by the charity. At the termination of the trust, the corpus (principal of the gift) reverts to the donor or to another person specified by the donor (may be the donor's estate). Income during the term of the trust is paid to the charity; the income may be unrestricted or restricted. In effect, this arrangement amounts to an unconditional pledge, for a specified period, of the income from a specified amount of assets. The current value of the pledge is the discounted PV of the estimated stream of income over the term of the trust. Although the charity manages the assets during the term of the trust, it has no remainder interest in the assets.

A perpetual trust held by a third party is the same as the lead trust, except that the charity does not manage the assets, and the term of the trust is perpetual. Again the charity receives the income earned by the assets, but never gains the use of the corpus. In effect, there is no remainderman. This arrangement is also a pledge of income, but in this case the current value of the pledge is the discounted PV of a perpetual stream of income from the assets. Assuming a perfect market for investment securities, that amount will equal the current quoted market value of the assets of the trust or, if there is no quoted market value, then the "fair value," which is normally determined based on discounted future cash flows from the assets.

Some may argue that since the charity does not and never will have day-to-day control over the corpus of this type of trust, it should only record assets and income as the periodic distributions are received from the trustee. In fact, that is the way the income from this type of gift has historically been recorded. In the authors' view, this is overcome by the requirement in SFAS No. 116 that long-term unconditional pledges be recorded in full (discounted) when the pledge is initially received by the pledgee. Since SFAS No. 116 requires that the charity immediately record the full (discounted) amount of a traditional pledge, when all the charity has is a promise of future gifts, with the pledgor retaining control over the means to generate the gifts, then the charity surely must record immediately the entire amount (discounted) of a "pledge" where the assets that will generate the periodic payments are held in trust by a third party, and receipt of the payments by the charity is virtually assured.

A variation of this type of arrangement is a trust held by a third party in which the third party has discretion as to when and/or to whom to pay the periodic income. Since in this case the charity is not assured in advance of receiving any determinable amount, no amounts should be recorded by the charity until distributions are received from the trustee; these amounts are then recorded as contributions.

Remainder Interests. There are four types of these arrangements. These are:

  1. Charitable Remainder Annuity Trust (CRAT)

  2. Charitable Remainder Unitrust (CRUT)

  3. Charitable Gift Annuity (CGA)

  4. Pooled income fund (also referred to as a life income fund)

These arrangements are always for a limited term, usually the life of the donor and/or another person or persons specified by the donor—often the donor's spouse. The donor or the donor's designee is the life tenant; the charity is the remainderman. Again, in the case of a trust, the charity may or may not be the trustee; in the case of a CGA, the charity usually is the holder of the assets. Upon termination of the arrangement, the corpus usually becomes available to the charity; the donor may or may not have placed further temporary or permanent restrictions on the corpus and/or the future income earned by the corpus.

In many states, the acceptance of these types of gifts is regulated by the state government—often the department of insurance—since, from the perspective of the donor, these arrangements are partly insurance contracts, essentially similar to a commercial annuity.

A charitable remainder annuity trust (CRAT) and Charitable Remainder Unitrust (CRUT) differ only in the stipulated method of calculating the payments to the life tenant. An annuity trust pays a stated dollar amount that remains fixed over the life of the trust; a unitrust pays a stated percentage of the then current value of the trust assets. Thus, the dollar amount of the payments will vary with changes in the market value of the corpus. Accounting for the two types is the same except for the method of calculation of the amount of the PV of the life interest payable to the life tenant(s). In both cases, if current investment income is insufficient to cover the stipulated payments, corpus may have to be invaded to do so; however, the liability to the life tenant is limited to the assets of the trust.

A charitable gift annuity (CGA) differs from a CRAT only in that there is no trust; the assets are usually held among the general assets of the charity (some charities choose to set aside a pool of assets in a separate fund to cover annuity liabilities), and the annuity liability is a general liability of the charity—limited only by the charity's total assets.

A pooled income fund (PIF) (also sometimes called a life income fund) is actually a creation of the Internal Revenue Code Section 642(c) (5), which, together with sec 170, allows an income tax deduction to donors to such funds. (The amount of the deduction depends on the age(s) of the life tenant(s) and the value of the life interest and is less than that allowed for a simple charitable deduction directly to a charity, to reflect the value that the life tenant will be receiving in return for the gift.) The fund is usually managed by the charity. Many donors contribute to such a fund, which pools the gifts and invests the assets. During the period of each life tenant's interest in the fund, the life tenant is paid the actual income earned by that person's share of the corpus. (To this extent, these funds function essentially as mutual funds.) Upon termination of a life interest, the share of the corpus attributable to that life tenant becomes available to the charity.

Accounting for Split-Interest Gifts. The essence of these arrangements is that they are pledges. In some cases, the pledge is of a stream of payments to the charity during the life of the arrangement (lead interests). In other cases, the pledge is of the value of the remainder interest. Calculation of the value of a lead interest is usually straightforward, as the term and the payments are well defined. Calculation of remainder interests is more complicated, since life expectancies are usually involved and the services of an actuary will likely be needed.

SFAS No. 116 gives very little guidance specific to split-interests. Chapter 6 of the new AICPA Audit Guide for not-for-profit organizations discusses in detail the accounting for split-interest gifts. Briefly, the assets contributed are valued at their fair value on the date of gift (the same as for any donated assets). The related contribution revenue is usually the PV of the amounts expected to become available to the organization, discounted from the expected date(s) of such availability (in the case of a remainder interest, the actuarial death date of the last remaining life tenant.) The difference between these two numbers is, in the case of a lead interest, the PV of the amount to be distributed at the end of the term of the agreement according to the donor's directions, and, under a remainder agreement, the PV of the actuarial liability to make payments to life tenants.

(iv) Transfers of Assets to a Not-for-Profit Organization or Charitable Trust that Raises or Holds Contributions for Others.

An intermediary, as defined in SFAS No. 116, that receives cash or other financial assets, as defined in SFAS No. 125, should report the assets received and a liability to the specified beneficiary, both measured at the fair value of the assets received. An intermediary that receives nonfinancial assets may but need not report the assets and the liability, provided that the intermediary reports consistently from period to period and discloses its accounting policy. A specified beneficiary of a charitable trust agreement having a trustee with a duty to hold and manage its assets for the benefit of the beneficiary should report as an asset its rights to trust assets—an interest in the net assets of the recipient organization, a beneficial interest, or a receivable—unless the recipient organization is explicitly granted variance power in the transferring instrument—unilateral power (power to act without approval from any other party) to redirect the use of the assets to another beneficiary.

If the beneficiary and the recipient organization are financially interrelated, the beneficiary should report its interest in the net assets of the recipient organization and adjust that interest for its share of the change in the net assets of the recipient organization, similar to the equity method. They are financially interrelated if both of the following are present:

  1. One has the ability to influence the operating and financial decisions of the other. That may be demonstrated in several ways:

    • The organizations are affiliates.

    • One has considerable representation on the governing board of the other.

    • The charter or bylaws of one limit its activities to those that are beneficial to the other.

    • An agreement between them allows one to actively participate in policy making of the other, such as setting priorities, budgets, and management compensation.

  2. One has an ongoing economic interest in the net assets of the other.

If the beneficiary has an unconditional right to receive all or a portion of the specified cash flows from a charitable trust or other identifiable pool of assets, the beneficiary should report that beneficial interest, measuring and subsequently remeasuring it at fair value, using a technique such as PV. In all other cases, a beneficiary should report its rights to the assets held by a recipient organization as a receivable and contribution revenue in conformity with the provisions of SFAS No. 116, paragraphs 6, 15, and 20, for unconditional promises to give.

If the recipient organization is explicitly granted variance power by the donor, the beneficiary should not report its potential for future distributions from the assets held by the recipient organization.

In general, a recipient organization that accepts assets from a donor and agrees to use them on behalf of them, or transfer them, or both to a specified beneficiary is not a donee. It should report its liability to the specified beneficiary and the cash or other financial assets received from the donor, all measured at the fair value of the assets received. In general, a recipient organization that receives nonfinancial assets may but need not report its liability and the assets, as long as the organization reports consistently from period to period and discloses its accounting policy.

A recipient organization that has been explicitly granted variance power acts as a donee.

A resource provider should report as an asset and the recipient organization should report as a liability a transfer of assets if one or more of the following is present:

  • The transfer is subject to the resource provider's unilateral right to redirect the use of the assets to another beneficiary.

  • The resource provider's promise to give is conditional or otherwise revocable or repayable.

  • The resource provider controls the recipient organization and specifies an unaffiliated beneficiary.

  • The resource provider specifies itself or its affiliate as the beneficiary and the transfer is not an equity transaction, as discussed next.

A transfer of assets to a recipient organization is an equity transaction if all of the following are present:

  • The resource provider specifies itself or its affiliate as the beneficiary.

  • The resource provider and the recipient organization are financially interrelated.

  • Neither the resource provider nor its affiliate expects payment of the assets, though payment of return on the assets may be expected.

A resource provider that specifies itself as beneficiary should report an equity transaction as an interest in the net assets of the recipient organization or as an increase in a previously reported interest. If a resource provider specifies an affiliate as beneficiary, it should report an equity transaction as a separate line in its statement of activities, and the affiliate should report an interest in the net assets of the recipient organization. A recipient organization should report an equity transaction as a separate line item in its statement of activities.

A not-for-profit organization that transfers assets to a recipient organization and specifies itself or its affiliate as the beneficiary should disclose the following for each period for which a statement of financial position is presented:

  • The identity of the recipient organization

  • Whether variance power was granted to the recipient organization and, if so, its terms

  • The terms under which amounts will be distributed to the resource provider or its affiliate

  • The aggregate amount reported in the statement of financial position for the transfers and whether it is reported as an interest in the net assets of the recipient organization or as another asset, such as a beneficial interest in assets held by others or a refundable advance

Exhibit 35.1 demonstrates the process that should be followed to decide how to account for such transfers and the related accounting for them.

SFASNo. 136, "Transfers of Assets to a Not-for-Profit Organization or Charitable Trust that Raises or Holds Contributions for Others."

Figure 35.1. SFASNo. 136, "Transfers of Assets to a Not-for-Profit Organization or Charitable Trust that Raises or Holds Contributions for Others."

(k) RELATED ORGANIZATIONS.

Practice has varied regarding when not-for-profit entities combine the financial statements of affiliated organizations with those of the central organization. Part of the reason for this is the widely diverse nature of relationships among such organizations, which often creates difficulty in determining when criteria for combination have been met.

(i) Definition of the Reporting Entity.

There are two issues here, but they involve the same concepts. First is the question of gifts to affiliated fund-raising entities and whether the affiliate should record the gift as its own revenue, followed by gift or grant expense when their money is passed on to the parent organization, or should record the initial receipt as an amount held on behalf of the parent. Such gifts are often called pass-through gifts since they pass through one entity to another entity. Second is the broader question of when the financial data of affiliated entities should be combined with that of a central organization for purposes of presenting the central organization's financial statements. If the data are combined, the question of pass-through gifts need not be addressed since the end result is the same regardless of which entity records gifts initially.

The concept underlying the combining of financial data of affiliates is to present to the financial statement reader information that portrays the complete financial picture of a group of entities that effectively function as one entity. In the business setting, the determination of when a group of entities is really just a single entity is normally made by assessing the extent to which the "parent" entity has a controlling financial interest in the other entities in the group. In other words, can the parent use for its own benefit the financial resources of the others without obtaining permission from any party outside the parent? When one company owns another company, such permission would be automatic; if the management of the affiliate refused, the parent would exercise its authority to replace management.

In the not-for-profit world, such "ownership" of one entity by another rarely exists. Affiliated organizations are more often related by agreements of various sorts, but the level of control embodied in such agreements is usually far short of ownership. The "Friends of the Museum" may exist primarily to support the Museum, but it is likely a legally independent organization with only informal ties to its "parent." The Museum may ask, but the Friends may choose its own time and method to respond. Further, the Museum may have no way to legally compel the Friends to do its bidding if the Friends resist.

The issue for donors is, if I give to the Friends, am I really supporting the Museum? Or if I am assessing the financial condition of the Museum, is it reasonable to include the resources of the Friends in the calculation? Even though the Friends is legally separate, and even though the Friends does not have to turn its assets over to the Museum, isn't it reasonable to assume that if the Museum got into financial trouble, the Friends would help?

Examples of other types of relationships often found among not-for-profits include: a national organization and local affiliates; an educational institution and student and alumni groups, research organizations, and hospitals; a religious institution and local churches, schools, seminaries, cemeteries, broadcasting stations, pension funds, and charities. Since each individual relationship may be different, it requires much judgment to decide which entities should be combined and which should not.

Existing accounting literature includes some guidance, but more is needed. The basic rules for businesses are:

  • ARB Opinion No. 51, "Consolidated Financial Statements"

  • APB Opinion No. 18, "The Equity Method of Accounting for Investments in Common Stock"

  • SFAS No. 94, "Consolidation of All Majority-Owned Subsidiaries"

While, strictly speaking, these rules apply to not-for-profits only in the context of a for-profit subsidiary, the concepts embodied therein and the related background discussions are helpful to someone considering the issue. Rules for not-for-profits are in the AICPA SOP 94-3. These rules focus largely on the question of whether one not-for-profit controls another. Exhibit 35.2 is designed to help not-for-profits and their accountants decide whether sufficient control exists to require combination.

Factors related to control that may indicate that an affiliated organization (A) should be combined with the reporting organization (R), if other criteria for combination are met.

Figure 35.2. Factors related to control that may indicate that an affiliated organization (A) should be combined with the reporting organization (R), if other criteria for combination are met.

In 1994, the AICPA issued a new SOP (94-3) on combining related entities when one is a not-for-profit organization. This SOP requires:

  • When a not-for-profit organization owns a majority of the voting equity interest in a for-profit entity, the not-for-profit must consolidate the for-profit into its financial statements, regardless of how closely related the activities of the for-profit are to those of the not-for-profit.

  • If the not-for-profit organization owns less than a majority interest in a for-profit but still has significant influence over the for-profit, it must report the for-profit under the equity method of accounting, except that the not-for-profit may report its investment in the for-profit at market value if it wishes. If the not-for-profit does not have significant influence over the for-profit, it should value its investment in accordance with the applicable audit guide.

  • When a not-for-profit organization has a relationship with another not-for-profit in which the "parent" both exercises control over the board appointments of and has an economic interest in the affiliate, it must consolidate the affiliate.

  • If the not-for-profit organization has either control or an economic beneficial interest but not both, disclosure of the relationship and significant financial information is required.

  • If the parent controls the affiliate by means other than board appointments, and has an economic interest, consolidation is permitted but not required. If the affiliate is not consolidated, extensive footnote disclosures about the affiliate are required.

(ii) Pass-Through Gifts.

When one organization (C, in Exhibit 35.3) raises funds for another organization (R, in the exhibit), and either C is not required to be consolidated into R under the above rules, or C is consolidated into R, but C also issues separate financial statements, the question of whether C should record amounts raised by it on behalf of R should be reported by C as its revenue (contribution income) or as amounts held for the benefit of R (a liability). If such amounts are reported by C as a liability, C's statement of revenue and expenses will not ever include the funds raised for R. This issue is of considerable concern to organizations such as federated fund-raisers (such as United Ways), community foundations, and other organizations such as foundations affiliated with universities, which raise (and sometimes hold) funds for the benefit of other organizations. Paragraphs 4 and 53 of SFAS No. 116 indicate that when the pass-through entity has little or no discretion over the use of the amounts raised (i.e., the original donor—D in the exhibit—has specified that C must pass the gift on to R), C should not report the amount as a contribution to it. FASB Interpretation No. 42 clarifies that if a resource provider specifies a third-party beneficiary or beneficiaries and explicitly grants the recipient organization the unilateral power to redirect the use of the assets away from the specified beneficiary or beneficiaries—grants it variance power—the organization acts as a donee and a donor rather than as an agent, trustee, or intermediary and should report the amount provided as a contribution. Exhibit 35.3 is a list of factors to be considered in assessing whether a pass-through entity should record amounts raised for others as revenue or as a liability.

"Economic interest" generally means four kinds of relationship: an affiliate that raises gifts for the parent, an affiliate that holds assets for the parent, an affiliate that performs significant functions assigned to it by the parent, or the parent has guaranteed the debt of or is otherwise committed to provide funds to the affiliate.

(I) CASH FLOWS.

SFAS No. 95, which requires businesses to present a statement of cash flows (in lieu of the former statement of changes in financial position), did not apply to not-for-profits. The new FASB standard on financial statements (No. 117) requires the presentation of a statement of cash flows. A sample statement of cash flows, following the example in the Statement, is illustrated in Exhibit 35.4.

(m) GOVERNMENTAL VERSUS NONGOVERNMENTAL ACCOUNTING.

In 1989, the Financial Accounting Foundation, overseer of the FASB and its counterpart in the governmental sector, the (see discussion in "State and Local Government Accounting") resolved the question of the jurisdiction of each body. A question related to several types of organizations, mainly not-for-profits, that exist in both governmental and nongovernmental forms. These types include institutions of higher education, museums, libraries, hospitals, and others. The issue is whether it is more important to have, for example, all hospitals follow a single set of accounting principles, or to have all types of governmental entities do so. This matter was resolved by conferring on GASB jurisdiction over all governmental entities.

SPECIFIC TYPES OF ORGANIZATIONS

In 1993, the FASB issued two new accounting pronouncements, SFAS No. 116, Accounting for Contributions Received and Contributions Made, and No. 117, Financial Statements of Not-for-Profit Organizations, which supersede many provisions of the old AICPA Audit Guides.

This chapter summarizes the accounting and reporting principles discussed in the new FASB standards, and, the provisions of the new AICPA not-for-profit Audit Guide. For the most part, the FASB standards prescribe the same accounting treatment for a given transaction by all types of not-for-profit organizations. One exception to that rule is a requirement that voluntary health and welfare organizations continue to present a statement of functional expenses. Other types of organizations are not required to present this statement, although they may if they wish. More detailed discussions of certain accounting and reporting standards in the new FASB documents will also be found elsewhere in this chapter. For example, a full discussion of accounting for contributions is in Subsection 35.2(j)(iii).

Factors to be considered in deciding whether a "pass-through" gift is truly revenue and expense to charity (C).

Figure 35.3. Factors to be considered in deciding whether a "pass-through" gift is truly revenue and expense to charity (C).

Statement of Cash Flows, derived from data included in Exhibits 35.5 and 35.6.

Figure 35.4. Statement of Cash Flows, derived from data included in Exhibits 35.5 and 35.6.

(a) VOLUNTARY HEALTH AND WELFARE ORGANIZATIONS.

The term "voluntary health and welfare organization" first entered the accounting world with the publication in 1964 of the first edition of the so-called "Black Book," Standards of Accounting and Financial Reporting for Voluntary Health and Welfare Organizations, by the National Health Council and the National Social Welfare Assembly. The term has been retained through two successor editions of that book and was used by the American Institute of Certified Public Accountants in the title of its "audit guide," Audits of Voluntary Health and Welfare Organizations, first published in 1967.

In 1974, the AICPA issued a revised Audit Guide, prepared by its Committee on Voluntary Health and Welfare Organizations. This Audit Guide was prepared to assist the independent auditor in examinations of voluntary health and welfare organizations.

"Voluntary health and welfare organizations" are those not-for-profit organizations that "derive their revenue primarily from voluntary contributions from the general public to be used for general or specific purposes connected with health, welfare, or community services."[7] Note that there are two separate parts to this definition: first, the organization must derive its revenue from voluntary contributions from the general public, and second, the organization must be involved with health, welfare, or community services.

Many organizations fit the second part of this definition, but receive a substantial portion of their revenues from sources other than public contributions. For example, an opera company would not be a voluntary health and welfare organization because its primary source of income is box office receipts, although it exists for the common good. A YMCA would be excluded because normally it receives most of its revenues from dues and program fees. On the other hand, a museum would be excluded, even if it were to receive most of its revenue from contributions, since its activities are educational, not in the areas of health and welfare.

(i) Financial Statements.

SFAS No. 117 provides for four principal financial statements for voluntary health and welfare organizations, thus superseding the financial statements discussed in the Guide. Examples are shown in this chapter. These four statements are:

  1. Balance Sheet (Exhibit 35.5)

  2. Statement of Support, Revenue and Expenses, and Changes in Net Assets (Exhibit 35.6)

  3. Statement of Cash Flows (Exhibit 35.4)

  4. Statement of Functional Expenses (Exhibit 35.7)

The sample financial statements presented in SFAS No. 117 are for illustrative purposes only, and some variation from the ones presented may be appropriate, as long as the required disclosure elements are shown.

(ii) Balance Sheet.

Exhibit 35.5 shows a Balance Sheet for the National Association of Environmentalists. Although SFAS No. 117 only requires (and illustrates) a single-column balance sheet showing the totals of assets, liabilities, and net assets (and net assets by class), many organizations will wish to show more detail of assets and liabilities, but not necessarily by class. This is acceptable.

Funds versus Classes.

Note that the columns on the balance sheet reflect the funds used for bookkeeping purposes. This is permissible, as long as the net asset amounts for each of the three classes defined in SFAS No. 117 are shown in the net assets section of the balance sheet.

Comparison Column.

In Exhibit 35.5 we have shown the totals for the previous year to provide a comparison for the reader. SFAS No. 117 does not require presentation of a comparison column, but it is recommended.

Designation of Unrestricted Net Assets.

While it is a little more awkward to show when the balance sheet is presented in a columnar fashion as in Exhibit 35.5, it is still possible to disclose the composition of the unrestricted net assets of $135,516.

For example, the unrestricted net assets of the National Association of Environmentalists of $135,516 (Exhibit 35.5) could be split into several amounts, representing the board's present intention of how it plans to use this amount. Perhaps $50,000 of it is intended for Project Seaweed, and the balance is available for undesignated purposes. The net assets section of the Balance Sheet would appear:

A balance sheet prepared in columnar format.

Figure 35.5. A balance sheet prepared in columnar format.

Income statement that meets the requirements of SFAS No. 117.

Figure 35.6. Income statement that meets the requirements of SFAS No. 117.

Income statement that meets the requirements of SFAS No. 117.
An analysis of the various program expenses showing the natural expense categories making up each of the functional or program categories

Figure 35.7. An analysis of the various program expenses showing the natural expense categories making up each of the functional or program categories

As monies are expended for Project Seaweed in subsequent periods, they would be recorded as an expense in the Statement of Support, Revenue and Expenses, and Changes in Net Assets. At the same time, the amount of the net assets designated by the board for Project Seaweed would be reduced and the amount "undesignated" would be increased by the same amount.

(iii) Statement of Support, Revenue and Expenses, and Changes in Net Assets.

Exhibit 35.6 shows a Statement of Support, Revenue and Expenses, and Changes in Net Assets for the National Association of Environmentalists. This is the format shown in SFAS No. 117, with some modifications (discussed below).

Reporting of Expenses

Functional Classification of Expenses. Exhibit 35.6 shows the expenses of the National Association of Environmentalists reported on a functional basis. This type of presentation requires management to tell the reader how much of its funds were expended for each program category and the amounts spent on supporting services, including fund raising.

SFAS No. 117 states that this functional reporting is not optional. SFAS No. 117 requires that disclosure of expenses by function must be made either in the primary financial statements or in the footnotes.

In many instances, the allocation of salaries between functional or program categories should be based on time reports and similar analyses. Other expenses such as rent, utilities, and maintenance will be allocated based on floor space. Each organization will have to develop time and expense accumulation procedures that will provide the necessary basis for allocation. Organizations have to have reasonably sophisticated procedures to be able to allocate expenses between various categories. An excellent reference source is the third edition (1988) of the "Black Book," Standards of Accounting and Financial Reporting for Voluntary Health and Welfare Organizations.

Program Services. Not-for-profit organizations exist to perform services either for the public or for the members of the organization. They do not exist to provide employment for their employees or to perpetuate themselves. They exist to serve a particular purpose. The Audit Guide re-emphasizes this by requiring the organization to identify major program services and their related costs. Some organizations may have only one specific program category, but most will have several. Each organization should decide for itself into how many categories it wishes to divide its program activities.

Supporting Services. Supporting services are those expenses that do not directly relate to performing the functions for which the organization was established, but that nevertheless are essential to the continued existence of the organization.

The Statement of Support, Revenue and Expenses, and Changes in Net Assets must clearly disclose the amount of supporting services. These are broken down between fund raising and administrative (management and general) expenses. This distinction between supporting and program services is required, as is the separate reporting of fund raising.

Management and General Expenses. This is probably the most difficult of the supporting categories to define because a major portion of the time of top management usually will relate more directly to program activities than to management and general. Yet many think, incorrectly, that top management should be considered entirely "management and general." The AICPA Audit Guide defines management and general expenses as follows:

those that are not identifiable with a single program, fund-raising activity, or membership-development activity but that are indispensable to the conduct of those activities and to an organization's existence. They include oversight, business management, general record keeping, budgeting, financing, soliciting revenue from exchange transactions, such as government contracts and related administrative activities, and all management and administration except for direct conduct of program services or fund-raising activities. The costs of oversight and management usually include the salaries and expenses of the governing board, the chief executive officer of the organization, and the supporting staff. (If such staff spend a portion of their time directly supervising program services or categories of other supporting services, however, their salaries and expenses should be allocated among those functions.) The costs of disseminating information to inform the public of the organization's "stewardship" of contributed funds, announcements concerning appointments, and the annual report, among other costs, should similarly be classified as management and general expenses. The costs of soliciting funds other than contributions, including exchange transactions (whether program-related or not), should be classified as management and general expenses.

Fund-Raising Expenses. Fund-raising expenses are a very sensitive category of expense because a great deal of publicity has been associated with certain organizations that appear to have very high fund-raising costs. The cost of fund raising includes not only the direct costs associated with a particular effort, but a fair allocation of the overhead of the organization, including the time of top management.

Fund-raising activities involve inducing potential donors to contribute money, securities, services, materials, facilities, other assets, or time. They include publicizing and conducting fund-raising campaigns; maintaining donor mailing lists; conducting special fund-raising events; preparing and distributing fund-raising manuals, instructions, and other materials; and conducting other activities involved with soliciting contributions from individuals, foundations, governments, and others. The financial statements should disclose total fund-raising expenses.

Fund-raising expenses are normally recorded as an expense in the Statement of Activity at the time they are incurred. It is not appropriate to defer such amounts. Thus the cost of acquiring or developing a mailing list that has value over more than one year would nevertheless be expensed in its entirety at the time the list was purchased or the costs incurred. The reason for this conservative approach is the difficulty accountants have in satisfying themselves that costs that might logically be deferred will in fact be recovered by future support related thereto. Further, if substantial amounts of deferred fund-raising costs were permitted, the credibility of the financial statements would be in jeopardy, particularly in view of the increased publicity surrounding fund-raising expenses.

If fund raising is combined with another function it may be possible to allocate the costs among the functions. In order to allocate any such costs to other than fund raising, criteria of purpose, audience and content as defined in SOP 98-2 must be met. These criteria are discussed in the next section.

Cost of Obtaining Grants. Organizations soliciting grants from governments or foundations have a cost that is somewhat different from fund-raising costs. Where such amounts are identifiable and material in amount, they should be separately identified and reported as a supporting service.

Allocation of Joint Costs of Multipurpose Activities.

In 1998, the ACIPA issued a SOP 98-2 now included in the Audit Guide. This SOP, "Accounting for Cost of Activities of Not-for Profit Organizations and State and Local Government Entities that Include Fund Raising," replaced SOP 87-2. Compliance with SOP 87-2 had been much criticized by charity watchdogs such as the National Charities Information Bureau and the Philanthropic Advisory Services of the Council of Better Business Bureaus (now merged into the BBB Wise Giving Alliance) and by state attorneys general. Charities were criticized that they were allocating costs to program that were really fund raising in nature. The greatest criticism was leveled against charities using significant direct mail campaigns that allocated a significant portion of those costs to program on the basis that it met the program goal of providing educational literature to recipients.

The new SOP, while similar in many ways to the old one, provides a clear step-by-step analysis that must be followed in determining whether costs can be allocated to other than fund raising. If any of the criteria of purpose, audience, and content are not met, all costs of the joint activity must be reported as fund raising. This is so even if some of the costs, if incurred in an activity without fund raising, would be properly allocated to program or management and general costs. One important change from the prior rules is that education about the cause of an organization does not meet the purpose criterion unless it is part of a call for specific action by the audience that will help accomplish the entity's mission. Previously, educational information about the cause was routinely allocated to program costs.

The criteria that must be met for allocation are as follows:

  • The purpose criterion is met if the purpose of the joint activity includes accomplishing program or management and general functions. To accomplish a program function, there must be a specific call for action, as noted in the previous paragraph. The SOP provides a number of examples and tests for judging whether the purpose criterion is met. Asking the audience to make contributions is indeed a call for action, but not one that helps accomplish the organization's mission.

  • The audience criterion is designed to ensure that the audience is relevant for the non-fund-raising purpose of the activity. In particular, there is a rebuttable presumption that the audience criterion is not met if the audience includes prior donors or has been selected based on its ability or likelihood to contribute.

  • The content criterion requires that the content meet the program or management and general function and that for program purposes there be a call for specific action to help accomplish the entity's mission.

The SOP does not prescribe or prohibit any specific allocation methods although it does describe some acceptable methods. General cost accounting principles should be used in allocating costs, and they should be consistently applied.

All Expenses Reported as Unrestricted. This is a new requirement in SFAS No. 117, and a significant change for almost all not-for-profit organizations (except hospitals). In the past, expenses were reported in the same fund as the revenue that was used to pay for the expenses. Thus unrestricted revenue, and expenses paid for out of that revenue were shown together in the unrestricted fund. Current restricted revenue, and the expenses paid for out of that revenue, were in the current restricted fund. (No expenses could ever be paid out of the permanent endowment fund, due to the nature of the restriction of those amounts.)

With the adoption of SFAS No. 117, all expenses, regardless of the origin of the resources used to finance the expenses, will be shown in the unrestricted class of net assets; no expenses will be in the temporarily restricted class. This is shown in Exhibit 35.6 The method of relating the restricted revenue to the expenses financed out of that revenue is to reclassify an amount of temporarily restricted net assets equal to the expenses to the unrestricted net assets class ($26,164 in Exhibit 35.6).

Columnar Presentation. The statement presentation is in a columnar format and, as can be observed in Exhibit 35.6, includes all three classes on one statement. It is also possible to present the information in a single column. In this format, information for the three classes is shown sequentially, including the change in net assets for the class, followed by the total change in net assets for the year. An advantage of such a format is the ease of showing comparative prior year information for each class; a disadvantage is the inability to present a total column.

It should be noted that this statement provides a complete picture of all activity of this organization for the year—not just the activity of a single class or fund. Further, by including a "total" column on the statement, the reader is quickly able to see the overall activity and does not have to add together several amounts to get the complete picture. This represents a major advance in not-for-profit accounting.

Unrestricted Activity in a Single Column. One of the most significant features of this presentation is that all legally unrestricted revenues and all expenses are reported in the single column representing the unrestricted class of net assets. The use of a single column in which all unrestricted activity is reported greatly simplifies the presentation and makes it more likely that a nonaccountant will be able to comprehend the total picture of the organization.

Many organizations, of course, will want to continue to keep board-designated accounts within their bookkeeping system. This is fine. But, for reporting to the public, all unrestricted amounts must be combined and reported as indicated in this exhibit.

While not recommended, there would appear to be no prohibition to an organization's including additional columns to the left of this total "unrestricted" column to show the various unrestricted board-designated categories of funds that make up the total unrestricted class. However, where an organization does so, it must clearly indicate that the total unrestricted column represents the total unrestricted activity for the year and that the detailed columns to the left are only the arbitrarily subdivided amounts making up this total. Probably an organization is better advised to show such detail in a separate supplementary schedule, if at all.

Where an organization chooses to show its unrestricted class broken into two columns and has only one class with restricted resources, it may be acceptable to eliminate the total unrestricted column in the interest of simplicity. An example of the column headings might be:

Allocation of Joint Costs of Multipurpose Activities.

The key to whether this would be acceptable is the extent of activity in the various columns. For example, if the temporarily restricted class in the above illustration were relatively minor in amount, then the total column would largely reflect the unrestricted class (i.e., the general fund and the investment fund). This is a judgment call.

Temporarily Restricted Column. The "temporarily restricted" column represents those amounts that have been given to the organization for a specified purpose other than for permanent endowment. It should be observed that the amounts reported as revenues in this fund represent the total amount the organization received during the year, and not the amount that was actually expended.

Use of Separate Fixed Asset (Plant) Fund. SFAS No. 117 does not mention a separate fixed asset category; rather it includes amounts related to fixed assets in the three classes of net assets discussed earlier. Even though a fixed asset fund is maintained in the organization's bookkeeping system, for external financial reporting purposes, the organization would include most of the amounts of the fixed asset fund in the unrestricted class. This has the additional advantage of reducing the number of columns and eliminating the need for certain reclassifications.

Appreciation of Investments.

Appreciation (or depreciation) of investments is shown on the Statement of Support, Revenue and Expenses, and Changes in Net Assets. In this instance, the net appreciation of investments was $33,025. Assuming there were no sales or purchases of investments during the year, this amount would have been determined by comparing the market value of the investments at the end of the year with the market value at the beginning of the year. Normally, however, there will be some realized gain or loss during the year. While there is no technical objection to reporting the realized gain or loss separately from the unrealized appreciation (or depreciation), there seems little significance to this distinction.

Operating Statement. A variation on this statement that some may wish to use is to present a subtotal of "operating" revenue in excess of "operating" expenses. This would focus the reader's attention on what the organization considers its core "operations," as distinguished from matters that it considers peripheral or incidental to its operations. SFAS No. 117 permits, but does not require, this presentation. If an organization chooses this presentation, it will decide for itself what it considers to be its operations, versus other activities. Appendix 35.6 contains a checklist to help organizations decide what they wish to consider as operating versus nonoperating transactions.

(iv) Statement of Cash Flows (Formerly Changes in Financial Position).

A Statement of Cash Flows is a summary of the resources made available to an organization during the year and the uses made of such resources. SFAS No. 117 requires presentation of a Statement of Cash Flows by all not-for-profit organizations. Full discussion of preparation of this statement is in SFAS No. 95.

Exhibit 35.4 shows a Statement of Cash Flows. In some ways it is similar to a Statement of Cash Receipts and Disbursements, in that it presents cash received and spent. It differs by grouping transactions into three groups: Operating, Investing, and Financing cash flows. Also, there is less detail of specific types of operating cash flows, since such detail is already shown for revenue and expenses in Exhibit 35.6.

(v) Statement of Functional Expenses.

Exhibit 35.7 is a statement that analyzes functional or program expenses and shows the natural expense categories that go into each functional category. It is primarily an analysis to give the reader insight as to the major types of expenses involved. In order to arrive at the functional expense totals shown in the Statement of Support, Revenue and Expenses, and Changes in Net Assets, an analysis must be prepared that shows all of the expenses going into each program category. The Statement of Functional Expenses merely summarizes this detail for the reader.

(b) COLLEGES AND UNIVERSITIES.

The AICPA Industry Audit Guide, "Audits of Colleges and Universities," issued in 1973, had been the most authoritative pronouncement on accounting principles and reporting practices for colleges and universities. With the issuance of FASB Statement Nos. 116 and 117, some of the accounting and reporting rules for colleges and universities have changed, as discussed elsewhere in this chapter.

(i) Fund Accounting.

Fund accounting is a prominent element of college and university accounting. Colleges and universities have historically followed fund accounting procedures. Fund accounting continues to find favor at colleges and universities because many gifts and grants that colleges receive possess external restrictions that must be carefully monitored, and also because many colleges voluntarily set aside some current unrestricted funds as "endowment" to produce future income.

The following six fund groupings are generally used for internal bookkeeping by colleges and universities:

Current funds are resources available for carrying out the general activities of an institution. In public reporting, current unrestricted funds are usually reported separately from current restricted funds, that is, funds restricted by donors or grantors for specific current purposes.

Loan funds are resources available for loans to students, faculty, and staff. If only the investment income from restricted endowment funds can be used for loans, only the income should be reported in the loan fund.

Endowment and similar funds consist of three types of endowment resources:

  1. True endowment, where the donor stipulates that the principal must be maintained inviolate and in perpetuity, and only the income earned thereon may be expended

  2. Term endowment, where the donor stipulates that, upon the passage of time or the incidence of an event, the principal may be used for current operations or specific purposes

  3. Quasi-endowment, where the board of trustees voluntarily retains as principal a portion of current funds to produce current and future income

Annuity and life income funds are endowment resources of which the college owns only the principal and not the income earned thereon. In accepting an annuity or life income gift, the college agrees to pay the contributor all income earned or a specific amount for a stated period of time. [See the discussion of split-interest gifts at Subsection 35.2(j)(iii).]

Plant funds consist of four fund groupings, and separate financial data for each are often reported:

  1. Unexpended plant funds are used for plant additions or improvements.

  2. Renewal and replacement funds are transferred from current funds for future renewal or replacement of the existing plant. These funds provide for the future integrity of the physical plant.

  3. Retirement of indebtedness funds are set aside to service debt interest and principal. It is often appropriate to designate which funds are set aside under mandatory contractual agreements with lenders and which funds are voluntarily designated.

  4. Investment in plant records the actual cost of all land, buildings, and equipment owned by the college. Donated plant is recorded at market value at the date of the gift.

Agency funds are funds over which an institution exercises custodial but not proprietary authority. An example is funds that are owned by a student organization but are deposited with the college.

(ii) Encumbrance Accounting.

Encumbrance accounting is not acceptable for financial statements of colleges and universities. It is inappropriate to report, as expenditures or liabilities, commitments for materials or services not received by the reporting date. A portion of the current unrestricted fund may be designated to satisfy purchase orders, provided that the designation is made only in the fund balances (net assets) section of the balance sheet.

(c) OTHER NOT-FOR-PROFIT ORGANIZATIONS

(i) Accounting Principles.

Not-for-profit organizations not covered by another AICPA Industry Audit Guide were covered by SOP 78-10. Organizations in this group include professional and trade associations, private and community foundations, religious organizations, libraries, museums, private schools, and performing arts organizations. Most accounting principles applicable to these organizations are discussed elsewhere in this chapter.

Subscription and Membership Income.

Subscription and membership income should be recognized in the periods in which the organization provides goods or services to subscribers or members. This usually requires deferring such amounts when received and recognizing them ratably over the membership or subscription period. Special calculations, based on life expectancy, are required when so-called life memberships are involved.

Grants to Others.

Organizations that award grants should record a grant as a liability and an expense in the period in which the recipient is entitled to the grant. This is usually the period in which the grant is authorized, even though some of the payments may not be made until later periods.

Under SFAS No. 116, grantors account for grants in the same way as grantees—except backward–expense and liability instead of revenue and receivable. See Subsection 35.2(j) for a discussion of accounting for restricted gifts and pledges.

AUDIT CONSIDERATIONS FOR A NOT-FOR-PROFIT ORGANIZATION

(a) GENERAL CONSIDERATIONS.

An audit of the financial statements of a not-for-profit organization is similar to an audit of a for-profit enterprise, and generally accepted auditing standards should be followed. A not-for-profit organization, however, seeks to provide an optimal level of services, rather than to maximize profits, and its financial statements, accordingly, focus on the activity and balances of different classes and funds. This in turn influences the conduct of the audit.

(b) INTERNAL CONTROL.

Some not-for-profit organizations do not have effective internal control. The size of staff may be inadequate to achieve a proper segregation of duties, and the nature of some transactions often precludes sufficient checks and balances. Internal control deficiencies are often mitigated by adoption of procedures including the following: (1) involvement of senior management and directors in the operation of the organization; (2) restricting check signing to senior management and directors; (3) implementing effective bank reconciliation procedures; (4) preparing annual budgets and promptly investigating variances from budget estimates; and (5) depositing investment securities with independent custodians.

(c) MATERIALITY.

The issue of what is material is equally important for not-for-profit and for-profit organizations. In for-profit enterprises, evaluating materiality involves considering the effect of alternate accounting treatments and disclosures on decisions by investors, and it relates to net income and earnings per share. These measures are generally not applicable to not-for-profit organizations. Instead, evaluating materiality involves considering the effects of accounting treatments and disclosures on decisions by contributors, and it relates to revenue, expenditures, and the cost of individual programs.

(d) TAXES.

Not-for-profit organizations are generally exempt from income taxes and are often exempt from property and sales taxes. Tax liabilities, however, may arise from tax on unrelated business income, tax on net income resulting from a loss of tax-exempt status, or certain excise taxes applicable to private foundations.

(e) CONSOLIDATION.

Not-for-profit organizations do not "own" other organizations in the sense that businesses own other businesses. Not-for-profit organizations, however, may exercise effective control over affiliates or related organizations; in such instances, preparation of combined financial statements may be appropriate.

(f) COMPLIANCE AUDITING.

In recent years, federal and state governments have become more active in requiring recipients of government money to submit auditor reports on various aspects of financial operations. These usually include opinions on financial data for the organization as a whole and, for government grants, reports on internal controls and compliance with laws and regulations. The exact requirements may differ depending on the type of recipient (college, hospital, etc.), the agency that made the grant, whether the money was received directly or through another level of government, and the amount of money received. It is important for the auditor to ascertain any compliance auditing requirements prior to beginning fieldwork, so that the auditor can perform the work necessary to issue the required reports. Specific requirements are contained in a number of different documents including SAS No. 74, "Compliance Auditing Considerations in Audits of Governmental Entities and Recipients of Governmental Financial Assistance"; the Department of Health and Human Services audit guide, "Guidelines for Audits of Federal Awards to Nonprofit Organizations"; various circulars issued by the Office of Management and Budget (principally A-21, A-110, A-122, A-133); and "Government Auditing Standards," issued by the GAO (generally referred to as the "Yellow Book"). Compliance auditing requirements are also found in the OMB "Compliance Supplement" (Revised 1997).

Additional guidance for compliance auditing is in a new AICPA SOP to replace SOP 92-9, "Audits of Not-for-Profit Organizations Receiving Federal Awards." Compliance auditing is discussed further in Chapter 32, "State and Local Government Accounting."

(g) UNIQUE AUDITING AREAS.

Auditing areas unique to not-for-profit organizations include the following:

  • Collections of museums, libraries, zoological parks, and similar organizations. Auditing considerations include valuation of assets, capitalization, accessions and deaccessions, security, insurance coverage, and observation of inventory. Certain procedures are appropriate even though the collection is not capitalized.

  • Contributions. Auditing considerations include ascertaining that amounts reported as contributions are properly stated. Audit tests for noncash contributions include testing their assigned value. Auditors are particularly concerned about the possibility that contributions that were intended for the organization may never have been received and recorded.

  • Fees for performance of services, including tuition, membership dues, ticket revenue, and patient fees. Auditing considerations include confirming that revenue is computed at proper rates, collected, and properly recorded for all services provided.

  • Functional allocation of expenses. Auditing considerations include appropriateness of allocations among functions, reasonableness of allocation methods, accuracy of computations, and consistency of allocation bases with bases of prior periods. These considerations are especially important when joint costs of multipurpose activities (discussed above) are involved.

  • Restricted resources. Auditing considerations include ascertaining that transactions are for the restricted purpose and are recorded in the proper restricted fund.

  • Grant awards to others. Auditing considerations include confirming grant awards with recipients and ascertaining that grants are recorded in the proper accounting period.

  • Tax compliance. Not-for-profits are subject to IRC sections that differ from those regularly applicable to businesses. Auditors must review compliance with these sections. Areas of particular concern are conformity with exempt purpose, unrelated business income, lobbying, status as a public charity (if applicable), and special rules applicable to private foundations.

SOURCES AND SUGGESTED REFERENCES

American Institute of Certified Public Accountants, Accounting Standards Division, "Accounting for Joint Costs of Informational Materials and Activities of Not-for-Profit Organizations that Include a Fund-Raising Appeal," Statement of Position No. 87-2, 1987. (In process of revision.)

———, Accounting Standards Division, "The Application of the Requirements of Accounting Research Bulletins, Opinions of the Accounting Principles Board, and Statements and Interpretations of the Financial Accounting Standards Board to Not-for-Profit Organizations," Statement of Position No. 94-2, 1994.

———, Accounting Standards Division, "Reporting of Related Entities by Not-for-Profit Organizations," Statement of Position No. 94-3, 1994.

———, Auditing Standards Division, "Compliance Auditing Considerations in Audits of Governmental Entities and Recipients of Governmental Financial Assistance," Statement on Auditing Standards No. 74, 1995.

———, Committee on Not-for-Profit Organizations, "Audits of Not-for-Profit Organizations Receiving Federal Awards," Statement of Position No. 92-9, 1992.

———, Committee on Not-for-Profit Organizations, "Audit and Accounting Guide, Not-for-Profit Organizations," 1996.

———, Health Care Committee, "Health Care Organizations Audit and Accounting Guide, 1996.

Anthony, R. N., Financial Accounting in Nonbusiness Organizations: An Exploratory Study of Conceptual Issues. Financial Accounting Standards Board, Norwalk, CT, 1978.

Anthony, R. N., and Young, D. W., Management Control in Nonprofit Organizations, Third ed. Richard D. Irwin, Homewood, IL, 1984.

Blazek, J., Tax Planning and Compliance for Tax-Exempt Organizations: Forms, Checklists, Procedures. John Wiley & Sons, New York, Second ed., 1993.

Cary, W. L., and Bright, C. B., The Law and the Lore of Endowment FundsReport to the Ford Foundation. New York, 1969.

Daughtrey, W. H., Jr., and Gross, M. J., Jr., Museum Accounting Handbook. American Association of Museums, Washington, DC, 1978.

Evangelical Joint Accounting Committee, "Accounting and Financial Reporting Guide for Christian Ministries," Revised edition. Christian Management Association, Diamond Bar, CA, 1997.

Financial Accounting Standards Board, Norwalk, CT:

Statements of Financial Accounting Concepts:

  • No. 4, "Objectives of Financial Reporting By Nonbusiness Organizations," 1980.

  • No. 6, "Elements of Financial Statements," 1985

  • Statements of Financial Accounting Standards:

  • No. 93, "Recognition of Depreciation by Not-for-Profit Organizations," Norwalk, CT, 1987.

  • No. 95, "Statement of Cash Flows," 1987.

  • No. 116, "Accounting for Contributions Received and Contributions Made," 1993.

  • No. 117, "Financial Statements of Not-for-Profit Organizations," 1993.

  • No. 124, "Accounting for Certain Investments Held by Not-for-Profit Organizations," 1995.

FASB Interpretation No. 42, "Accounting for Transfers of Assets in Which a Not-for-Profit Organization Is Granted Variance Power," 1996.

Gross, Larkin, Bruttomesso, and McNally, Financial and Accounting Guide for Not-for-Profit Organizations, Fifth ed. New York, John Wiley & Sons, 1995.

Holder, W. W., The Not-for-Profit Organization Reporting Entity, Philanthropy Monthly Press, New Milford, CT, 1986.

Hopkins, B. R., A Legal Guide to Starting and Managing A Nonprofit Organization, Second ed. New York, John Wiley & Sons, 1993.

———, The Law of Fund-Raising, 2nd ed. New York, John Wiley & Sons, 1995.

———, The Law of Tax-Exempt Organizations, 7th ed. New York, John Wiley & Sons, 1998.

Hummel, J., Starting and Running a Nonprofit Organization, Minneapolis: University of Minnesota Press, 1980.

Larkin, R. F., "Accounting," Chapter 31 of The Nonprofit Management Handbook—Operating Policies and Procedures. New York, John Wiley & Sons, 1993; and 1994 Supplement.

———, "Accounting Issues Relating to Fundraising," Chapter 2 of Financial Practices for Effective Fundraising. San Francisco, Jossey-Bass, Inc., 1994.

National Association of College and University Business Officers, Financial Accounting and Reporting Manual for Higher Education. Washington, DC, 1990.

National Association of Independent Schools, Business Management for Independent Schools, Third ed., Boston: Author, 1987.

National Health Council, National Assembly for Social Policy and Development, Inc., and United Way of America, Standards of Accounting and Financial Reporting for Voluntary Health and Welfare Organizations, Third ed., NHC, NASPD, and UWA, New York, 1988.

———, Effective Internal Accounting Control for Nonprofit Organizations. New York, 1988.

———, The Audit Committee, the Board of Trustees of Not-for-Profit Organizations and the Independent Accountant. New York, 1992.

———, Not-for-Profit Organizations' Implementation Guide for SFAS Statements 116 and 117. New York, 1993.

United States General Accounting Office, "Government Auditing Standards." GAO, Washington, DC, 1994 Revision.

United States Office of Management and Budget Circulars, OMB, Washington:

No. A-21, "Cost Principles for Educational Institutions," 1996.

No. A-110, "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations," 1993.

No. A-122, "Cost Principles for Nonprofit Organizations," 1980. (In process of revision.)

No. A-133, "Audits of States, Local Governments, and Non-profit Organizations," 1997.

United Way of America, Budgeting: A Guide for United Ways and Not-for-Profit Human Service Organizations. Alexandria, VA, 1975.

Accounting and Financial Reporting: A Guide for United Ways and Not-For Profit Human Service Organizations, Second ed. Alexandria, VA, 1989.

APPENDIX 35.1: FACTORS TO BE CONSIDERED IN DISTINGUISHING CONTRACTS FOR THE PURCHASE OF GOODS OR SERVICES FROM RESTRICTED GRANTS

Following is a list of factors that may be helpful to not-for-profit organizations in deciding how to account for the receipt of payments that might be considered as being either for the purchase of goods or services from the organization, or as restricted-purpose gifts or grants to the organization (as contemplated in par. 3 of SFAS No. 116). These factors can also be used by auditors in assessing the reasonableness of the client's decision. Additional discussion of this distinction can be found in the instructions to IRS Form 990, lines 1a–c, and in IRS Regulation 1.509(a)–3(g). No one of these factors is normally determinative by itself; all relevant factors should be considered together.

Factors Whose Presence Would Indicate Payment Is for the Purchase of Goods or Services

Factors Whose Presence Would Indicate the Payment Is a Restricted Grant for a Specific Purpose

Factors related to the agreement between the payor and the payee:

  1. The expressed intent is for the payee to provide goods/services to the payor, or to other specifically identified recipients, as determined by the payor.

  2. There is a specified time and/or place for delivery of goods/services to the payor or other recipient

  3. There are provisions for economic penalties, beyond the amount of the payment, against the payee for failure to meet the terms of the agreement.

  4. The amount of the payment per unit is computed in a way that explicitly provides for a "profit" margin for the payee.

  5. The total amount of the payment is based only on the quantity of items delivered.

  6. The tenor of the agreement is that the payor receives approximately equivalent value in return for the payment.

  7. The items are closely related to commercial activity regularly engaged in by the payor.

  8. There is substantial benefit to the payor itself from the items.

  9. If the payor is a governmental unit, the items are things the government itself has explicitly undertaken to provide to its citizens; the government has arranged for another organization to be the actual service provider.

  10. The benefits resulting from the items are to be made available only to the payor or to persons or entities designated by the payor.

  11. The items are to be delivered to the payor or to other persons or entities closely connected with the payor.

  12. Revenue from sale of the items is considered unrelated business income (IRC Section 512) to the payee.

  13. In the case of sponsored research, the payor determines the plan of research and the desired outcome, and retains proprietary rights to the results.

  14. The payment supports applied research.

The expressed intent is to make a gift to the payee to advance the programs of the payee.

Time and/or place of delivery of any goods/services is largely at the discretion of the payee.

Any penalties are expressed in terms of required delivery of goods/services, or are limited to return of unspent amounts.

The payment is stated as a flat amount or a fixed amount per unit based only on the cost (including overhead) of providing the goods/services.

The payment is based on a line-item budget request, including an allowance for actual administrative costs.

The payor does not receive approximately equivalent value.

The items are related to the payee's program services.

The items are normally used to provide goods/services considered of social benefit to society as a whole, or to some defined segment thereof (e.g., children, persons having a disease, students), which might not otherwise have ready access to the items.

The government is in the role of subsidizing provision of services to the public by a nongovernmental organization.

The items, or the results of the activities funded by the payment, are to be made available to the general public, or to any person who requests and is qualified to receive them. Determination of specific recipients is made by the payee.

Delivery is to be made to persons or entities not closely connected with the payor.

Revenue is "related" income to the payee.

The research plan is determined by the payee; desired outcomes are expressed only in general terms (e.g., to find a cure for a disease), and the rights to the results remain with the payee or are considered in the public domain.

The payment supports basic research.

APPENDIX 35.2: FACTORS TO BE CONSIDERED IN ASSESSING WHETHER CONTRIBUTED SERVICES ARE CONSIDERED TO REQUIRE SPECIALIZED SKILLS (PER PARAGRAPH 9 OF STATEMENT OF FINANCIAL ACCOUNTING STANDARDS NO. 116, "ACCOUNTING FOR CONTRIBUTIONS RECEIVED")

Following is a list of factors that may be helpful to recipients of contributed services of volunteers in assessing whether the skills utilized by the volunteers in the performance of their services are considered to be "specialized" within the meaning of Paragraph 9 of SFAS No. 116. These factors may also aid auditors in assessing the appropriateness of the client's judgment. This list of factors is not intended to be used in determining how to value or account for such services. In some cases, no one of these factors is necessarily determinative by itself; all relevant factors should be considered together.

Eight factors whose presence is often indicative that skills are "specialized":

  1. Persons who regularly hold themselves out to the public as qualified practitioners of such skills are required by law or by professional ethical standards to possess a license or other professional certification, or specified academic credentials. Alternatively, if possession of such license/certification/credentials is optional, the person performing the services does possess such formal certification.

  2. Practitioners of such skills are required, by law or professional ethics, to have obtained a specified amount of technical prejob or on-the-job training, to obtain specified amounts of continuing professional education, a specified amount of practical work experience, or to complete a defined period of apprenticeship in the particular type of work.

  3. Proper practice of the skills requires the individual to possess specific artistic or creative talent and/or a body of technical knowledge not generally possessed by members of the public at large.

  4. Practice of the skills requires the use of technical tools or equipment. The ability to properly use such tools or equipment requires training or experience not generally possessed by members of the public at large.

  5. There is a union or professional association whose membership consists specifically of practitioners of the skills, as opposed to such groups whose members consist of persons who work in a broad industry, a type of company, or a department of a company. Admission to membership in such organization requires demonstrating one or more of the factors 1, 2, or 3. (Whether the person whose skills are being considered actually belongs to such organization is not a factor in assessing whether the skills are considered to be specialized, though it may be relevant in assessing whether the person possesses the skills.)

  6. Practitioners of such skills are generally regarded by the public as being members of a particular "profession."

  7. There is a formal disciplinary procedure administered by a government or by a professional association, to which practitioners of such skills are subject, as a condition of offering their skills to the public for pay.

  8. Practice of the skills by persons who do so in their regular work is ordinarily done in an environment in which there is regular formal review or approval of work done by supervisory personnel or by professional peers.

APPENDIX 35.3: CHECKLIST—FACTORS TO BE CONSIDERED IN DETERMINING WHETHER AN ORGANIZATION WOULD TYPICALLY NEED TO PURCHASE SERVICES IF NOT PROVIDED BY DONATION

The following is a list of factors that may be helpful to:

  • Not-for-profit organizations, in deciding whether contributed services meet the third part of the criterion in paragraph 9b of SFAS No. 116;

  • Auditors, in assessing the reasonableness of the client's decision.

No one of these factors is normally determinative by itself; all relevant factors and the strength of their presence should be considered together.

Factors Whose Presence Would Indicate the Services Would Typically Need to Be Purchased

Factors Whose Presence Would Indicate the Services Would Typically Not Need to Be Purchased

  1. The activities in which the volunteers are involved are an integral part of the reporting organization's ongoing program services (as stated in its IRS Form 1023/4, fund-raising material, and annual report), or of management or fund-raising activities that are essential to the functioning of the organization's programs.

  2. Volunteer work makes up a significant portion of the total effort expended in the program activity in which the volunteers are used.

  3. The program activity in which the volunteers function is a significant part of the overall program activities of the organization.

  4. The reporting organization has an objective basis for assigning a value to the services.

  5. The organization has formal agreements with third parties to provide the program services that are conducted by the volunteers.

  6. The reporting organization assigns volunteers to specific duties.

  7. The volunteers are subject to ongoing supervision and review of their work by the reporting organization.

  8. The organization actively recruits volunteers for specific tasks.

  9. If the work of the volunteers consists of creating or enhancing nonfinancial assets, the assets will be owned and/or used primarily by or under the control of the reporting organization after the volunteer work is completed. If the assets are subsequently given away by the organization to charitable beneficiaries, the organization decides who is to receive the assets.

  10. If there were to be a net increase in net assets resulting from the recording of a value for the services (even though in practice, there usually is not), the increase would better meet the criteria for presentation as revenue, rather than a gain, as set forth in SFAC No. 6, par. 78–79, 82–88, and 111–113.

  11. Management represents to the auditor that it would hire paid staff to perform the services if volunteers were not available.

The activities are not part of the reporting organization's program, or of important management or fundraising activities, or are relatively incidental to those activities; the services primarily benefit the program activities of another organization.

Volunteer work is a relatively small part of the total effort of the program.

The program activity is relatively insignificant in relation to the organization's overall program activities.

No objective basis is readily available.

Factor not present.

Assignment of specific duties to volunteers is done by persons or entities other than the reporting organization, or the volunteers largely determine for themselves what is to be done within broad guidelines.

The activities of the volunteers are conducted at geographic locations distant from the organization.

Volunteers are accepted but not actively recruited, or, if recruited, specific tasks are not mentioned in the recruiting materials.

The assets will immediately be owned or used primarily by other persons or organizations.

The net increase would better meet the criteria of a gain, rather than revenue.

Management represents that it would not hire paid staff; or it is obvious from the financial condition of the organization that it is unlikely that financial resources would be available to pay for the services.

Auditors are reminded that management representations alone do not normally constitute sufficient competent evidential matter to support audit assertions; however, they may be considered in conjunction with other evidence.

Factors particularly relevant in situations where the volunteer services are provided directly to charitable or other beneficiaries of the reporting organization's program services (e.g., Legal Aid Society) rather than to the organization itself:

  1. The reporting organization assumes responsibility for the volunteers with regard to workers' compensation and liability insurance, errors or omissions in the work, satisfactory completion of the work.

  2. The reporting organization maintains ongoing involvement with the activities of the volunteers.

The organization has explicitly disclaimed such responsibility.

The organization functions mainly as a clearinghouse for putting volunteers in touch with persons or other organizations needing help, but has little ongoing involvement.

APPENDIX 35.4: FACTORS TO BE CONSIDERED IN ASSESSING WHETHER A DONOR HAS MADE A BONA FIDE PLEDGE TO A DONEE

Following is a list of factors that may be helpful to donees, in assessing whether a pledge (unconditional promise to give, as contemplated in pars. 5–7, 22, 23 of SFAS No. 116) has, in fact, been made. These factors may also help auditors in assessing the appropriateness of the client's judgment. This list of factors is not intended to be used in deciding on proper accounting (for either the pledge asset or the related revenue/net assets) or to assess collectibility, although some of the factors may be relevant to those decisions as well. In many cases, no one of these factors is necessarily determinative by itself; all relevant factors should be considered together.

Factors Whose Presence May Indicate a Bona Fide Pledge Was Made

Factors Whose Presence May Indicate a Bona Fide Pledge Was Not Made

[a]

[b]

[c]

[d]

1. Factors related to the solicitation process:

  • _____a. There is evidence that the recipient explicitly solicited formal pledges.

  • _____b. Public announcement[a] of the pledge has been made (by donor or donee)

  • _____c. Partial payment on the pledge has been made (or full payment after balance sheet date).

  • The pledge was unsolicited, or the solicitation did not refer to pledges.

  • No public announcement has been made.

  • No payments have yet been made, or payments have been irregular, late, or less than scheduled amounts.

2. Factors related to the "pledge" itself:

  • _____a. Written evidence created by the donor clearly supports the existence of an unconditional promise to give. ((D)

  • _____b. The evidence includes words such as:

    • promise

    • agree

    • will

    • binding,

  • _____c. The pledge appears to be legally enforceable. (Consult an attorney if necessary.) (Note also factor 4a.)

  • _____d. There is a clearly-defined payment schedule stated in terms of either calendar dates or the occurrence of specified events whose occurrence is reasonably probable.

  • _____e. The calendar dates or events comprising the payment schedule will (are expected to) occur within a relatively short time[b] after the balance sheet date (or in the case of events, have already occurred).

  • _____f. The amount of the pledge is clearly specified or readily computable.

  • _____g. The donor has clearly specified a particular purpose for the gift, e.g., endowment, fixed assets, loan fund, retire long-term debt, specific program service. The purpose is consistent with ongoing done activities.

  • There is no written evidence;[b] the only written evidence was prepared by the donee, or written evidence is unclear.

  • Legal enforceability is questionable or explicitly denied.

  • A payment schedule is not clearly defined, or events are relatively unlikely to occur.

  • The time (period) of payment contemplated by the donor is relatively far in the future.

  • The amount is not clear or readily computable.

  • The purpose is vaguely or not specified, or inconsistent with donee activities.

3. Factors relating to the donor:

  • _____a. There is no reason to question the donor's ability or intent to fulfill the pledge.

  • _____b. The donor has a history of making and fulfilling pledges to the donee of similar or larger amounts.

  • Collectibility of the gift is questionable

  • Factor not present.

4. Factors relating to the donee:

  • _____a. The donee has indicated that it would take legal action to enforce collection if necessary, or has a history of doing so.

  • _____b. The donee has already taken specific action in reliance on the pledge or publicly[c] announced that it intends to do so.[d]

  • It is unlikely (based on donee's past practices) or uncertain whether the donee would enforce the "pledge."

  • No specific action has been taken or is contemplated.

(D) This factor, if present, would normally be considered determinative.

[a] The announcement would not necessarily have to be made to the general public; announcement in media circulated among the constituency of either the donor or donee would suffice. Examples include newsletters, fund-raising reports, annual reports, a campus newspaper, and so on. In the case of announcements by the donee, there should be a reasonable presumption that the donor is aware of the announcement and has not indicated any disagreement with it.

[b] Oral pledges can be considered bona fide under some circumstances. Clearly, in the case of oral pledges, much greater weight will have to be given to other factors if the existence of a bona fide pledge is to be asserted. Also, the auditor will have to carefully consider what audit evidence can be relied on.

[c] What constitutes a relatively short time has to be determined in each case. The longer the time contemplated, the more weight will have to be given to other factors (especially 2b, c, 3a and 4a) in assessing the existence of a pledge. In most circumstances, periods longer than three to five years would likely be judged relatively long.

[d] Types of specific action contemplated include:

  • Commencing acquisition, construction, or lease of capital assets or signing binding contracts to do so

  • Making public announcement of the commencement or expansion of operating programs used by the public (e.g., the opening of a new clinic, starting a new concert series, a special museum exhibit)

  • Indicating to another funder that the pledge will be used to match part of a challenge grant from that funder

  • Soliciting other pledges or loans for the same purpose by explicitly indicating that "x has already pledged"

  • Committing proceeds of the pledge in other ways such as awarding scholarships, making pledges to other charities, hiring new staff, and so on (where such uses are consistent with either the donee's stated purposes in soliciting the pledge or the donor's indicated use of the pledge)

  • Forbearing from soliciting other available major gifts (e.g., not submitting an application for a foundation grant) because, with the pledge in question, funding for the purpose is considered complete

  • Using pledge as collateral for a loan

APPENDIX 35.5: CHECKLIST—FACTORS TO BE CONSIDERED IN DECIDING WHETHER A GIFT OR PLEDGE SUBJECT TO DONOR STIPULATIONS IS CONDITIONAL OR RESTRICTED (AS DISCUSSED IN STATEMENT OF FINANCIAL ACCOUNTING STANDARDS NO. 116, PARS. 7, 22–23, 57–71, 75–81)

Donors place many different kinds of stipulations on pledges and other gifts. Some stipulations create legal restrictions that limit the way in which the donee may use the gift. Other stipulations create conditions that must be fulfilled before a donee is entitled to receive (or keep) a gift.

In SFAS No. 116, FASB defines a condition as an uncertain future event that must occur before a promise based on that event becomes binding on the promisor. In some cases, it is not immediately clear whether a particular stipulation creates a condition or a restriction. (Some gifts are both conditional and restricted.) Accounting for the two forms of gift is quite different, so it is important that the nature of a stipulation be properly identified so that the gift is properly categorized.

Following is a list of factors to be considered by:

  • Recipients (and donors) of gifts, in deciding whether a pledge or other gift that includes donor stipulations is conditional or restricted

  • Auditors, in assessing the appropriateness of the client's decision

In many cases, no one of these factors will be determinative by itself; all applicable factors should be considered together.

Factors Whose Presence in the Grant Document, Donor's Transmittal Letter, or Other Gift Instrument or in the Appeal by the Recipient Would Indicate the Gift May Be Restricted

Factors Whose Presence in the Communication from the Donor or the Donee-Prepared Pledge Card Would Indicate the Gift May Be Conditional

Factors related to the terms of the gift/pledge:

  1. The document uses words such as:

    • If*

    • Subject to*

    • When

    • Revocable*

  2. Neither the ultimate amount nor the timing of payment of the gift is clearly determinable in advance of payment.

  3. The pledge is stated to extend for a very long period of time (over, say, 10 years) or is open-ended. (Often found with pledges to support a needy child overseas or a missionary in the field.)

  4. The donor stipulations in the document refer to outcomes expected as a result of the activity (with the implication that if the outcomes are not achieved, the donor will expect the gift to be refunded, or will cancel future installments of a multiperiod pledge.1a)* (Such gifts are likely also restricted.)

  5. There is an explicit requirement that amounts not expensed by a specified date must be returned to the donor.

  6. The gift is in the form of a pledge.

  7. Payment of amounts pledged will be made only on a cost-reimbursement basis. (D)

  8. The gift has an explicit matching requirement (D), or additional funding beyond that already available will be required to complete the activity.

The document uses words such as:

Must

For

Purpose

Irrevocable

At least one of the amount and/or timing is clearly specified.

The time is short and/or specific as to its end.

The donor stipulations focus on the activities to be conducted. Although hoped-for outcomes may be implicit or explicit, there is not an implication that achievement of particular outcomes is a requirement.1b*

There is no such refund provision, or any refund is required only if money is left after completion of the specified activities.

The gift is a transfer of cash or other non-cash assets.

Payment of the gift will be made up front, or according to a payment schedule, without the necessity for the donee to have yet incurred specific expenses.

Factor not present.

Factors relating to the circumstances surrounding the gift:

  1. The action or event described in the donor's stipulations is largely outside the control of the management or governing board of the donee.2a*

  2. The activity contemplated by the gift is one which the donee has not yet decided to do, and it is not yet certain whether the activity will actually be conducted.*

  3. There is a lower probability that the donor stipulations will eventually be met.

  4. As to any tangible or intangible outcomes that are to be produced as a result of the activities, these products will be under the control of the donor. (In such cases, the payment may not be a gift at all; rather it may be a payment for goods or services.)

The action or event is largely within the donee's control.2a*

The donee is already conducting the activity, or it is fairly certain that the activity will be conducted.*

There is a higher probability.

Any outcomes will be under the control of the donee.

Presence of this factor would normally be considered determinative. Absence of the factor is not necessarily determinative.

*Factors that would generally be considered more important.

1aExamples of outcomes contemplated by this factor include:

  • Successful creation of a new vaccine

  • Production of a new television program

  • Commissioning a new musical composition

  • Establishing a named professorship

  • Reduction in the teenage pregnancy rate in a community

  • Construction of a new building

  • Mounting a new museum exhibit

1bExamples of activities contemplated by this factor include (but see Factor 10**):

  • conduct of scientific or medical research

  • Broadcasting a specified television program

  • Performing a particular piece of music

  • Paying the salary of a named professor

  • Counseling teenagers judged at risk of becoming pregnant

  • Operating a certain facility

  • Providing disaster relief

2aExamples of events contemplated by this factor include:

  • Actions of uncontrolled third parties, for example:

    • other donors making contributions to enable the donee to meet a matching requirement of this gift

    • a government granting approval to conduct an activity (e.g., awarding a building or land use permit, or a permit to operate a medical facility)

    • an owner of other property required for the activity making the property available to the organization (by sale or lease)

  • Natural and man-made disasters

  • Future action of this donor (such as agreeing to renew a multiperiod pledge in subsequent periods)

  • The future willingness and ability of a donor of personal services to continue to provide those services (See SFAS No. 116, par. 70, third sentence.)

(Events outside of the donee's control, but which are virtually assured of happening anyway at a known time and place (e.g., astronomical or normal meteorological events), and the mere passage of time, are not conditions.)

2bExamples of events contemplated by this factor include (but see Factor 10**):

  • Eventual use of the gift for the specified purpose (e.g., those listed in Note 1b above), or retention of the gift as restricted endowment

  • Naming a building for a specified person

  • Filing with the donor routine performance reports on the activities being conducted

**There is a presumption here that the right column of Factor 10 applies.

APPENDIX 35.6: CONSIDERATION OF WHETHER ITEMS MAY BE REPORTED AS OPERATING OR NONOPERATING (WITHIN THE CONTEXT OF PAR. 23 OF STATEMENT OF FINANCIAL ACCOUNTING STANDARDS NO. 117)

Paragraph 23 of SFAS No. 117 leaves it to each organization (if it wishes to present a subtotal of "operating" results) to determine what it considers to be operating versus nonoperating items in a statement of activity. If it is not obvious from the face of the statement what items are included or excluded in the operating subtotal, footnote disclosure of that distinction shall be made. Following are some items that might be considered as nonoperating. This is not intended to express any preferences, nor to limit the types of items that a particular organization might report as nonoperating, but merely to provide a list for consideration of various types of items.

Items that would usually be considered nonoperating as to the current period:

  • Extraordinary items

  • Cumulative effects of accounting changes

  • Correction of errors of prior periods

  • Prior period adjustments, generally

  • Results of discontinued operations

Items that many persons might consider nonoperating in some situations:

  • Unrealized capital gains on investments carried at market value

  • Unrelated business income (as defined in the Internal Revenue Code Section 512), and related expenses

  • Contributions that qualify as "unusual grants," as defined in IRS Regulation Section 1.509(a)–3(c)(3)

  • Items that meet some, but not all, of the criteria in APB No. 30/SFAS No. 4 for extraordinary items, or APB No. 30/SFAS No. 16 for prior period adjustments

Items that some persons might consider nonoperating in some situations:

  • Bequests and other "deferred gifts" (annuity, life income funds, etc.) received

  • Gains and losses, generally (as defined in SFAC No. 6, pars. 82–89)

  • Sales of goods/services that, although they are not considered unrelated under the Internal Revenue Code, are nevertheless peripheral to the organization's major activities

  • Some "auxiliary activities" of colleges

  • Revenue and expenses related to program activities not explicitly listed on the organization's IRS Form 1023

  • Revenue and expenses directly related to transactions that are reported as financing or investing cash flows in the statement of cash flows; for example, investment income not available for operating purposes, interest expense, write-offs of loans receivable, nonexpendable gifts (as contemplated by paragraph 30 d of SFAS No. 117), adjustment of annuity liability

  • Contributions having the characteristics of an "initial capital" contribution to an organization, even though they do not meet the requirements of an extraordinary item or an unusual grant

Notes: The characterization of an item of expense as operating versus nonoperating is not driven by its classification as program, management, or fund-raising expense.

In general, expenses should follow related revenue: For example, if contributions are considered operating, then fund-raising expenses normally would be also, and vice versa.



[5] SFAS No. 116 uses the term promise to give to refer to what is more commonly called a pledge.

[6] It is also possible to consider both a simple pledge and a permanent endowment fund as forms of lead interests. In both cases, the charity receives periodic payments, but never gains unrestricted use of the assets that generate the income to make the payments. A pledge is for a limited time; an endowment fund pays forever.

[7] Appendix D of SFAS No. 117.

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