Not-for-Profit Annual Accounting and Federal
Grant Update – New Rules for Now and Later
Presented by: Michelle Spriggs
and...
1#CBIZMHMwebinar#CBIZMHMwebinar
 To view this webinar in full screen mode, click on view options in the
upper right hand ...
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 This webinar is eligible for CPE
credit. To receive credit, you will
need to answer peri...
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Michelle E. Spriggs, CPA, MBA
Shareholder
774.206.8336 | mspriggs@cbiztofias.com
Michelle is a Shareholde...
4#CBIZMHMwebinar#CBIZMHMwebinar
The information in this Executive Education Series
course is a brief summary and may not i...
5#CBIZMHMwebinar#CBIZMHMwebinar
Today’s Agenda
1 Changes to Accounting and Auditing Standards –
What to Expect this Year
2...
CHANGES TO ACCOUNTING AND
AUDITING STANDARDS
What to expect this year
7#CBIZMHMwebinar#CBIZMHMwebinar
 Statement of Cash Flows Presentation – ASU 2012-05
 Classify donated financial assets a...
8#CBIZMHMwebinar#CBIZMHMwebinar
 Effective prospectively for fiscal years beginning after
June 13, 2013:
 Retrospective ...
9#CBIZMHMwebinar#CBIZMHMwebinar
 Definition of a Public Business Entity - FASB ASU No.
2013-12
 Minimizes the inconsiste...
10#CBIZMHMwebinar#CBIZMHMwebinar
 Amends the Glossary of the Codification to include one
definition of a public business ...
11#CBIZMHMwebinar#CBIZMHMwebinar
 Reminder on AICPA updates relevant to NFPs
 TIS Section 2130.38/2130.40 – Certificates...
12#CBIZMHMwebinar#CBIZMHMwebinar
 TIS Section 6140.23 – Changing Net Asset
Classifications Reported in a Prior Year
 Con...
CHANGES TO ACCOUNTING AND
AUDITING STANDARDS
What to expect going forward
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 Services Received from Personnel of an Affiliate –
FASB ASU No. 2013-06
 Clarifies the...
15#CBIZMHMwebinar#CBIZMHMwebinar
 How services from affiliates should be measured:
 At the cost recognized by the affili...
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 Financial statement presentation
 If health care entity, report the services as an equ...
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 FASB issued Exposure Draft in June 2013
 Provides a more systematic and consistent app...
18#CBIZMHMwebinar#CBIZMHMwebinar
 Proposed Approach
 Describes how management should evaluate going
concern uncertaintie...
19#CBIZMHMwebinar#CBIZMHMwebinar
 FASB Exposure Draft – Revenue from Contracts with
Customers
 Fundamental principle:
 ...
20#CBIZMHMwebinar#CBIZMHMwebinar
 Five-step model:
1. Identify contract(s) with customer
2. Identify separate performance...
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 Potential Impact on Not-for-Profits
 Grants and sponsored research
 Exchange transact...
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 Lease accounting continues to be a topic for discussion,
with continued Exposure Drafts...
23#CBIZMHMwebinar#CBIZMHMwebinar
 2013 Exposure Draft:
 For most leases other than real estate:
 Recognize the right of...
24#CBIZMHMwebinar#CBIZMHMwebinar
 Effect on Not-for-Profit Organizations
 Financial statement impact
 Increase in total...
CHANGES TO OMB CIRCULAR
A-133 AND COST CIRCULARS
What to expect under the new grant reform
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 December 26, 2013 – OMB issued Final Grant Reform
Rules
 Uniform Administrative Requir...
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OMB Grant Reform – Intent
Consolidate
Simplicity
Streamline
Consistency
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OMB Grant Reform – Chronology
Presidential
Direction
(Executive Order;
Memorandum to
Agen...
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OMB Grant Reform – Changes
Hello
• Uniform Administrative Requirements,
Cost Principles, ...
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OMB Grant Reform – Structure
Contents Reference Origin
A – Acronyms and Definitions 200.0...
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Appendix
Appendix III Indirect Cost Procedures for
Educational Institutions
Appendix IV I...
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OMB Grant Reform – Changes to Subpart F
Final Changes to A-133 Audits –
Effective for Dec...
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OMB Grant Reform – Changes to Subpart F -
Continued
Final Changes to A-133 Audits –
Effec...
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 2 CFR 200 – Subpart E
 2 CFR 200.400 – 475
 Applicable to States, Local Governments, ...
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 Recipient responsibility for employing sound
management practices
 Recipient autonomy ...
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General Tests of Allowability of Costs
Retained
Necessary,
reasonable,
allocable
Conform ...
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 421 Advertising and public
relations
 423 Alcoholic beverages
 424 Alumni(ae) activit...
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 427 Bonding costs
 430 Compensation –
personal services
 431 Compensation – fringe
be...
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 460 Proposal costs
 461 Publication and printing
costs
 462 Rearrangement and
reconve...
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 Time and distribution records must be maintained for all
employees whose salaries are:
...
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 New standards for documentation of personnel
expenses
1. Charges for salaries must be b...
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 Use allowance no longer allowed
 No depreciation on assets that are fully depreciated
...
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 Computing devices do not meet the threshold requirement
so are considered supplies
 Ta...
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 Allowable as an indirect cost
 Thank you OMB!
 This was in college and university and...
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 Salaries of administrative and clerical staff are normally
treated as indirect unless a...
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 Mandating (or encouraging) indirect charging of certain
allowable costs
 Required reco...
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 On annual and final fiscal reports or vouchers
requesting payment
 By an official who ...
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 Mandatory disclosures
 An entity must disclose in writing in a timely manner to a fede...
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Written Procedures for Allowable Costs –
Subpart D
New Rule
Must have written procedures ...
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 Now five procurement methods
1. Micro-purchases
 Acquisition of supplies or services v...
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 Now five procurement methods - continued
3. Procurement by sealed bids
 Publicly solic...
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 All these documents can be found at
http://www.whitehouse.gov/omb/grants_docs
 Uniform...
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 Uniform Guidance Cost Principles Text Comparisons
http://www.whitehouse.gov/sites/defau...
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 Uniform Guidance Administrative Requirements Text
Comparisons
http://www.whitehouse.gov...
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 There is no substitute for a “deep dive.”
 Read OMB’s commentary.
 Watch for the dead...
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 Review policies and procedures to determine if any changes
are needed
 Monitor OMB and...
THE NEW COSO FRAMEWORK
How will it impact your organization?
58#CBIZMHMwebinar#CBIZMHMwebinar
COSO Framework – 20 Years in the Making
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Updated COSO Framework
What is not changing... What is changing...
• Core definition of i...
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 NFPs are expected to establish and maintain effective
internal controls over federal aw...
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 Internal control objectives in A-133 built around COSO
framework
 No updates to Compli...
PROPOSED CHANGES TO THE
NOT-FOR-PROFIT REPORTING
MODEL AND OTHER
CONSIDERATIONS
What is to come
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FASB’s Proposed Changes to
Not-for-Profit Reporting Model
Impact/Recommendation
Defining ...
64#CBIZMHMwebinar#CBIZMHMwebinar
FASB’s Proposed Changes to
Not-for-Profit Reporting Model
Impact/Recommendation
Direct me...
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 Feedback/concerns on intermediate measure of operations
 Interest expense
 Gifts of l...
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Questions?
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Additional webinars:
 10/7 & 10/22: Potential Changes in the Not-for-Profit
Reporting Mo...
68#CBIZMHMwebinar#CBIZMHMwebinar
Connect with Us
linkedin.com/company/
mayer-hoffman-mccann-p.c.
@mhm_pc
youtube.com/
maye...
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Webinar Slides: Not-for-Profit Annual Accounting and Federal Grant Update

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This course provides an update regarding accounting and auditing standards that most commonly impact not-for-profit and educational organizations. In addition, we will provide details regarding final changes related to the OMB Cost Circulars — including major changes to OMB Circular A-133.

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Webinar Slides: Not-for-Profit Annual Accounting and Federal Grant Update

  1. 1. Not-for-Profit Annual Accounting and Federal Grant Update – New Rules for Now and Later Presented by: Michelle Spriggs and Lisa Wills April 17, 2014
  2. 2. 1#CBIZMHMwebinar#CBIZMHMwebinar  To view this webinar in full screen mode, click on view options in the upper right hand corner.  Click the Support tab for technical assistance.  If you have a question during the presentation, please use the Q&A feature at the bottom of your screen. Before We Get Started…
  3. 3. 2#CBIZMHMwebinar#CBIZMHMwebinar  This webinar is eligible for CPE credit. To receive credit, you will need to answer periodic participation markers throughout the webinar.  External participants will receive their CPE certificate via email immediately following the webinar. CPE Credit
  4. 4. 3#CBIZMHMwebinar Michelle E. Spriggs, CPA, MBA Shareholder 774.206.8336 | mspriggs@cbiztofias.com Michelle is a Shareholder in the Firm’s Not-For-Profit and Higher Education Audit Practice. Michelle is the not-for-profit subject matter expert in the Firm’s National Professional Standards Group. She has over 20 years of audit experience and is solely dedicated to serving not-for-profit organizations. Her experience includes managing financial statement and OMB Circular A-133 audits; assisting in bond offerings; providing recommendations on internal controls; and training other accounting and auditing professionals to provide support to not-for-profit clients. Today’s Presenters Lisa Wills, CPA Principal 401.626.3232 | lwills@cbiz.com Lisa is a Director in the Firm’s Not-For-Profit and Higher Education Audit Practice. She has over 20 years of experience providing accounting services to public and private educational institutions and not-for-profit entities. Lisa has extensive experience with FASB and GASB financial statement audits, OMB Circular A-133 audits, federal and state compliance audits, NCAA audits and agreed-upon procedures, tax-exempt bond offerings and related due diligence procedures.
  5. 5. 4#CBIZMHMwebinar#CBIZMHMwebinar The information in this Executive Education Series course is a brief summary and may not include all the details relevant to your situation. Please contact your service provider to further discuss the impact on your business. Disclaimer
  6. 6. 5#CBIZMHMwebinar#CBIZMHMwebinar Today’s Agenda 1 Changes to Accounting and Auditing Standards – What to Expect this Year 2 Changes to Accounting and Auditing Standards – What to Expect Going Forward 3 Changes to OMB Circular A-133 and Cost Circulars Proposed Changes to the Not-for-Profit Reporting Model and Other Considerations 5 Questions and Answers6 4 The New COSO Reporting Model
  7. 7. CHANGES TO ACCOUNTING AND AUDITING STANDARDS What to expect this year
  8. 8. 7#CBIZMHMwebinar#CBIZMHMwebinar  Statement of Cash Flows Presentation – ASU 2012-05  Classify donated financial assets as inflows from operating activities if:  Upon receipt, assets were directed for sale without any limitations  Assets were converted to cash nearly immediately  Donor did not restrict the use of the assets for long-term purposes  If donor restricted for long-term purpose, such as a capital expenditure, then the donation is classified in the financing section  In all other cases (i.e. not converted to cash), classify as investing activities Donated Financial Assets
  9. 9. 8#CBIZMHMwebinar#CBIZMHMwebinar  Effective prospectively for fiscal years beginning after June 13, 2013:  Retrospective application to all prior periods presented upon the date of adoption is permitted.  Early adoption from the beginning of the fiscal year of adoption is permitted. Donated Financial Assets – Continued
  10. 10. 9#CBIZMHMwebinar#CBIZMHMwebinar  Definition of a Public Business Entity - FASB ASU No. 2013-12  Minimizes the inconsistency and complexity of having multiple definitions of, or a diversity in practice as to what constitutes a nonpublic business entity and public entity within U.S. GAAP on a going-forward basis. Public Business Entity
  11. 11. 10#CBIZMHMwebinar#CBIZMHMwebinar  Amends the Glossary of the Codification to include one definition of a public business entity for future use in U.S. GAAP.  Excludes all not-for-profit entities from the definition (including holders of public debt securities or conduit debt).  Does not affect existing financial reporting guidance.  Effective for new standards going forward. Public Business Entity – Continued
  12. 12. 11#CBIZMHMwebinar#CBIZMHMwebinar  Reminder on AICPA updates relevant to NFPs  TIS Section 2130.38/2130.40 – Certificates of Deposit and Fair Value Disclosures  Certificates of deposit generally do not meet the definition of a security and are not subject to fair value disclosures  TIS Section 2130.39 – Balance Sheet Classification of Certificates of Deposit  Certificates of deposit with original maturities of 90 days or less are generally classified as cash and cash equivalents AICPA Technical Practice Aids
  13. 13. 12#CBIZMHMwebinar#CBIZMHMwebinar  TIS Section 6140.23 – Changing Net Asset Classifications Reported in a Prior Year  Consider individual net asset classes in determining a correction of an error  TIS Section 6140.24 – Contributions of Certain Nonfinancial Assets, Such as Fundraising Material, Informational Material, or Advertising, Including Media Time or Space for Public Service Announcements or Other Purposes  Explains how NFPs should evaluate whether such media services should be considered contribution revenue AICPA Technical Practice Aids – Continued
  14. 14. CHANGES TO ACCOUNTING AND AUDITING STANDARDS What to expect going forward
  15. 15. 14#CBIZMHMwebinar#CBIZMHMwebinar  Services Received from Personnel of an Affiliate – FASB ASU No. 2013-06  Clarifies the guidance that not-for-profit entities apply for recognizing and measuring services received from personnel of an affiliate.  Services provided by personnel of an affiliate under direct supervision of the recipient not-for-profit  Shared services of an affiliate group that the recipient would have to purchase if they were not provided Affiliated Services
  16. 16. 15#CBIZMHMwebinar#CBIZMHMwebinar  How services from affiliates should be measured:  At the cost recognized by the affiliate for the personnel providing the services  If recognizing at cost will significantly overstate the value of the services received, then recipient NFP may elect to recognize at either:  Cost recognized by affiliate for the personnel providing the service, or  Fair value of the service Affiliated Services – Continued
  17. 17. 16#CBIZMHMwebinar#CBIZMHMwebinar  Financial statement presentation  If health care entity, report the services as an equity transfer from the affiliate and increase in net assets.  All others:  Increase in contribution revenue  Corresponding decrease in net assets (expense or asset)  Effective for fiscal years beginning after June 15, 2014  Modified retrospective application permitted  Early adoption permitted Affiliated Services – Continued
  18. 18. 17#CBIZMHMwebinar#CBIZMHMwebinar  FASB issued Exposure Draft in June 2013  Provides a more systematic and consistent approach to how management should evaluate going concern uncertainties Going Concern Uncertainties
  19. 19. 18#CBIZMHMwebinar#CBIZMHMwebinar  Proposed Approach  Describes how management should evaluate going concern uncertainties and what information should be provided in the footnotes to the financial statements  New definitions and disclosure thresholds  Scalable reporting requirements allowing disclosures to evolve as the level of financial stress increases  Applies to all entities that use U.S. GAAP, though some disclosures would apply only to SEC filers that use U.S. GAAP  Multi-step evaluation process by management to determine whether going concern disclosures are necessary Going Concern Uncertainties – Continued
  20. 20. 19#CBIZMHMwebinar#CBIZMHMwebinar  FASB Exposure Draft – Revenue from Contracts with Customers  Fundamental principle:  An entity should recognize revenue from contracts with customers when it transfers goods or services to the customer in the amount of consideration the entity receives, or expects to receive, from the customer Revenue Recognition
  21. 21. 20#CBIZMHMwebinar#CBIZMHMwebinar  Five-step model: 1. Identify contract(s) with customer 2. Identify separate performance obligations in the contract(s) 3. Determine the transaction price 4. Allocate the transaction price 5. Recognize revenue when the performance obligation is satisfied Revenue Recognition – Continued
  22. 22. 21#CBIZMHMwebinar#CBIZMHMwebinar  Potential Impact on Not-for-Profits  Grants and sponsored research  Exchange transactions  Transfer of promised good or service vs. product delivery  Not-for-profit contracts which are not profitable  Tuition revenue  Contributions and collaborative arrangements are scoped out  Likely enhanced disclosures  Final standard was expected in first quarter 2014 Revenue Recognition – Continued
  23. 23. 22#CBIZMHMwebinar#CBIZMHMwebinar  Lease accounting continues to be a topic for discussion, with continued Exposure Drafts and deliberation  Current status:  Revised Exposure Draft released in May 2013, with comments due by third quarter of 2013  No proposed effective date Leases
  24. 24. 23#CBIZMHMwebinar#CBIZMHMwebinar  2013 Exposure Draft:  For most leases other than real estate:  Recognize the right of use asset and a lease liability, initially recognized at the present value of lease payments  Recognize and report the interest expense on the lease liability separately from the amortization of the right of use asset  For most real estate leases:  Recognize a right of use asset and a lease liability at the present value of lease payments  Recognize a single lease cost – that combines the interest on the lease liability with the amortization of the right of use asset – on a straight line basis Leases – Continued
  25. 25. 24#CBIZMHMwebinar#CBIZMHMwebinar  Effect on Not-for-Profit Organizations  Financial statement impact  Increase in total assets and total liabilities  Lease payment expense replaced by amortization of right-to-use asset and interest expense  Overall change in net assets  Could have an impact on financial ratios Leases – Continued
  26. 26. CHANGES TO OMB CIRCULAR A-133 AND COST CIRCULARS What to expect under the new grant reform
  27. 27. 26#CBIZMHMwebinar#CBIZMHMwebinar  December 26, 2013 – OMB issued Final Grant Reform Rules  Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards  Affects over $600 billion in annual Federal grants  Streamlining cost circulars and guidance OMB Grant Reform
  28. 28. 27#CBIZMHMwebinar#CBIZMHMwebinar OMB Grant Reform – Intent Consolidate Simplicity Streamline Consistency
  29. 29. 28#CBIZMHMwebinar#CBIZMHMwebinar OMB Grant Reform – Chronology Presidential Direction (Executive Order; Memorandum to Agencies) 2/28/12 – Advance Notice of Proposed Guidance 2/1/13 – Notice of Proposed Guidance (Rulemaking) 12/26/13 – Issue of Final Guidance (2 CFR Part 200) 6/26/14 – Federal Agency Draft Regulations to OMB 12/26/14 – Uniform Adoption by all Federal Agencies Fiscal years beginning after 12/26/14 – single audit requirement (Subpart F) Applies
  30. 30. 29#CBIZMHMwebinar#CBIZMHMwebinar OMB Grant Reform – Changes Hello • Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards • UARCPARFA • Super Circular • Omni Circular Goodbye • Administrative requirements: • A-102 State & Local Government • A-110 Colleges, Universities and Not-for- profits • A-89 Catalog of Federal Domestic Assistance • Cost circulars: • A-21 Colleges & Universities • A-87 State & Local Government • A-122 Not-for-profits • A-133
  31. 31. 30#CBIZMHMwebinar#CBIZMHMwebinar OMB Grant Reform – Structure Contents Reference Origin A – Acronyms and Definitions 200.0 – 200.99 All Circulars B – General Provisions 200.100 – 200.113 All Circulars C – Pre-Federal Award Requirements and Contents of Federal Awards 200.200 – 200.211 A-110 and A-89 D – Post-Federal Award Requirements 200.300 – 200.345 A-110 and A-102 E – Cost Principles 200.400 – 200.475 A-21, A-87 and A-122 F – Audit Requirements 200.500 – 200.521 A-133 Appendices
  32. 32. 31#CBIZMHMwebinar#CBIZMHMwebinar Appendix Appendix III Indirect Cost Procedures for Educational Institutions Appendix IV Indirect Cost Procedures for Nonprofit Organizations Appendices V-VII Procedures for State, Local and Tribal Governments OMB Grant Reform – Key Appendices
  33. 33. 32#CBIZMHMwebinar#CBIZMHMwebinar OMB Grant Reform – Changes to Subpart F Final Changes to A-133 Audits – Effective for December 31, 2015 Year-Ends Impact Single audit threshold to increase from $500,000 to $750,000 Allows for relief for entities doing modest business from federally derived funds. Type A/B program minimum threshold increase from $300,000 to $750,000 May reduce the number of programs considered major in an audit and therefore fewer programs audited. Major program determination focus on areas with internal control deficiencies that have been identified as material weaknesses Entities with strong internal controls and few audit findings could have fewer high-risk Type A programs and fewer programs audited.
  34. 34. 33#CBIZMHMwebinar#CBIZMHMwebinar OMB Grant Reform – Changes to Subpart F - Continued Final Changes to A-133 Audits – Effective for December 31, 2015 Year-Ends Impact Percentage of audit coverage decrease from 25% to 20% for low risk auditee and 50% to 40% for high risk auditee Could reduce the number of programs considered major in an audit. Threshold for reporting questioned costs to increase from $10,000 to $25,000 Could reduce the number of reported findings but more detail would be required for reported findings. Further changes to the compliance requirements required for audit are being considered by OMB We will keep you updated on developments; expecting guidance in summer/fall of 2014.
  35. 35. 34#CBIZMHMwebinar#CBIZMHMwebinar  2 CFR 200 – Subpart E  2 CFR 200.400 – 475  Applicable to States, Local Governments, Tribal Governments, Colleges and Universities and Nonprofit Organizations  Not applicable to Commercial Organizations and Hospitals  Maybe later The New Cost Principles “Package”
  36. 36. 35#CBIZMHMwebinar#CBIZMHMwebinar  Recipient responsibility for employing sound management practices  Recipient autonomy related to organizational structure, staffing and management  Recipient decision making related to charging practice (direct vs. indirect)  No profit in Federal assistance  Total recovery: allowable costs plus allocable indirect costs minus applicable credits Key Basic Concepts of Cost Principles Retained
  37. 37. 36#CBIZMHMwebinar#CBIZMHMwebinar General Tests of Allowability of Costs Retained Necessary, reasonable, allocable Conform to limitations Conform with Federal law and grant terms Consistent with organizational policies Consistently treated Determined in accordance with GAAP Not charged elsewhere Net of applicable credits Adequately documented
  38. 38. 37#CBIZMHMwebinar#CBIZMHMwebinar  421 Advertising and public relations  423 Alcoholic beverages  424 Alumni(ae) activities  425 Audit services  426 Bad debts  429 Commencement and convocation costs  445 Goods and services for personal use Cost Principles with Little or No Change  450 Lobbying  455 Organization costs  457 Plant and homeland security costs  458 Pre-award costs  459 Professional service costs  467 Selling and marketing costs  469 Student activity costs
  39. 39. 38#CBIZMHMwebinar#CBIZMHMwebinar  427 Bonding costs  430 Compensation – personal services  431 Compensation – fringe benefits  433 Contingency provisions  434 Contributions and donations  436 Depreciation  437 Employee morale, health and welfare costs Cost Principles with Changes  439 Equipment and other capital expenditures  441 Fines, penalties, damages and other settlements  447 Insurance and indemnification  449 Interest  453 Materials and supplies costs, including costs of computing devices  454 Memberships, subscriptions, and professional activity costs
  40. 40. 39#CBIZMHMwebinar#CBIZMHMwebinar  460 Proposal costs  461 Publication and printing costs  462 Rearrangement and reconversion costs  463 Recruiting costs  464 Relocation of employees  465 Rental costs of real property and equipment Cost Principles with Changes – Continued  468 Specialized service facilities  470 Taxes (including Value Added Taxes)  471 Termination costs  472 Training and education  474 Travel
  41. 41. 40#CBIZMHMwebinar#CBIZMHMwebinar  Time and distribution records must be maintained for all employees whose salaries are:  Paid in whole or in part with federal funds (200.430(i)(1))  Used to meet a match/cost share requirement (200.430(i)(4)) Compensation – Personal Services (200.430)
  42. 42. 41#CBIZMHMwebinar#CBIZMHMwebinar  New standards for documentation of personnel expenses 1. Charges for salaries must be based on records that accurately reflect the work performed 2. Must be supported by a system of internal controls which provides reasonable assurance the amounts charged are accurate, allowable and properly allocated 3. Be incorporated into official records 4. Reasonably reflect total activity for which employee is compensated  Not to exceed 100% Compensation – Personnel Services (200.430) – Continued
  43. 43. 42#CBIZMHMwebinar#CBIZMHMwebinar  Use allowance no longer allowed  No depreciation on assets that are fully depreciated Depreciation (200.436)
  44. 44. 43#CBIZMHMwebinar#CBIZMHMwebinar  Computing devices do not meet the threshold requirement so are considered supplies  Tablets  Laptops  Smart phones Equipment and Other Capital Expenditures (200.439)
  45. 45. 44#CBIZMHMwebinar#CBIZMHMwebinar  Allowable as an indirect cost  Thank you OMB!  This was in college and university and government cost circulars, but not NFP Proposal Costs (200.460)
  46. 46. 45#CBIZMHMwebinar#CBIZMHMwebinar  Salaries of administrative and clerical staff are normally treated as indirect unless all of the following are met: 1. Such services are integral to the activity 2. Individuals can be specifically identified with the activity 3. Such costs are explicitly included in the budget or have prior written approval 4. Costs not also recovered as indirect Key Changes to Indirect Costs – Subpart E
  47. 47. 46#CBIZMHMwebinar#CBIZMHMwebinar  Mandating (or encouraging) indirect charging of certain allowable costs  Required recognition by federal agencies of federally negotiated rates  Introduction of de minimis 10% rate in lieu of negotiation  Procedures for recognition of subrecipient indirect costs  Authorization to continue use of a negotiated rate for up to four years Key Changes to Indirect Costs – Subpart E – Continued
  48. 48. 47#CBIZMHMwebinar#CBIZMHMwebinar  On annual and final fiscal reports or vouchers requesting payment  By an official who is authorized to legally bind the entity  Subject to criminal, civil or administrative penalties for fraud, false statements or false claims Required Certifications – Subpart E
  49. 49. 48#CBIZMHMwebinar#CBIZMHMwebinar  Mandatory disclosures  An entity must disclose in writing in a timely manner to a federal agency or pass-through:  All violations of federal criminal law involving fraud, bribery or gratuity violations potentially affecting the Federal award Changes to Subpart B
  50. 50. 49#CBIZMHMwebinar#CBIZMHMwebinar Written Procedures for Allowable Costs – Subpart D New Rule Must have written procedures for determining the allowability of costs in accordance with the new grant circular Prior Rule Must follow applicable cost principle to determine reasonableness, allowability and allocability of all costs
  51. 51. 50#CBIZMHMwebinar#CBIZMHMwebinar  Now five procurement methods 1. Micro-purchases  Acquisition of supplies or services value not to exceed $3,000  Awarded without soliciting competitive quotations if price is considered reasonable 2. Small purchase procedures  Subject to simplified acquisition threshold ($150,000)  Price or rate quotations must be obtained from an adequate number of qualified sources Procurement – Subpart D
  52. 52. 51#CBIZMHMwebinar#CBIZMHMwebinar  Now five procurement methods - continued 3. Procurement by sealed bids  Publicly solicited  Preferred for procuring construction 4. Competitive proposals  Used when conditions are not appropriate for sealed bids 5. Noncompetitive proposals  Sole source Procurement – Subpart D – Continued
  53. 53. 52#CBIZMHMwebinar#CBIZMHMwebinar  All these documents can be found at http://www.whitehouse.gov/omb/grants_docs  Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards - 2 CFR 200 http://www.ecfr.gov/cgi-bin/text- idx?SID=d6d9a62155484b2fb6176d7d01a640cc&node=2:1. 1.2.2.1&rgn=div5 Links to Helpful Documents
  54. 54. 53#CBIZMHMwebinar#CBIZMHMwebinar  Uniform Guidance Cost Principles Text Comparisons http://www.whitehouse.gov/sites/default/files/omb/fedreg/201 3/uniform-guidance-cost-principles-requirements-text- comparison.pdf  Uniform Guidance Audit Requirements Text Comparisons http://www.whitehouse.gov/sites/default/files/omb/fedreg/201 3/uniform-guidance-audit-requirements-text-comparison.pdf Links to Helpful Documents – Continued
  55. 55. 54#CBIZMHMwebinar#CBIZMHMwebinar  Uniform Guidance Administrative Requirements Text Comparisons http://www.whitehouse.gov/sites/default/files/omb/fedreg/2 013/uniform_guidance_administrative_requirements_text_ comparison.pdf  COFAR’s FAQ for New Uniform Guidance on 2 CFR 200 https://cfo.gov/wp-content/uploads/2013/01/2-C.F.R.-200- FAQs-2-12-2014.pdf  E-mail COFAR at cofar@omb.eop.gov Links to Helpful Documents – Continued
  56. 56. 55#CBIZMHMwebinar#CBIZMHMwebinar  There is no substitute for a “deep dive.”  Read OMB’s commentary.  Watch for the deadlines.  If something is working and isn’t specifically prohibited or mentioned in the new cost principles then don’t stop.  Personnel time and distribution records What To Do Now
  57. 57. 56#CBIZMHMwebinar#CBIZMHMwebinar  Review policies and procedures to determine if any changes are needed  Monitor OMB and federal agency actions  Stay tuned for OMB’s plans for changes to the Compliance Supplement  Subscribe to our monthly e-newsletter What To Do Now – Continued
  58. 58. THE NEW COSO FRAMEWORK How will it impact your organization?
  59. 59. 58#CBIZMHMwebinar#CBIZMHMwebinar COSO Framework – 20 Years in the Making
  60. 60. 59#CBIZMHMwebinar#CBIZMHMwebinar Updated COSO Framework What is not changing... What is changing... • Core definition of internal control • Three categories of objectives and five components of internal control • Each of the five components of internal control are required for effective internal control • Important role of judgment in designing, implementing and conducting internal control, and in assessing its effectiveness • Changes in business and operating environments considered • Operations and reporting objectives expanded • Fundamental concepts underlying five components articulated as principles • Additional approaches and examples relevant to operations, compliance, and non-financial reporting objectives added
  61. 61. 60#CBIZMHMwebinar#CBIZMHMwebinar  NFPs are expected to establish and maintain effective internal controls over federal awards  No current expectation or requirement to document or evaluate internal controls in accordance with the COSO framework  Primarily a source for best practices  However… What Does This Mean for NFPs?
  62. 62. 61#CBIZMHMwebinar#CBIZMHMwebinar  Internal control objectives in A-133 built around COSO framework  No updates to Compliance Supplement for new COSO  There could be changes coming! What Does This Mean for NFPs? – Continued
  63. 63. PROPOSED CHANGES TO THE NOT-FOR-PROFIT REPORTING MODEL AND OTHER CONSIDERATIONS What is to come
  64. 64. 63#CBIZMHMwebinar#CBIZMHMwebinar FASB’s Proposed Changes to Not-for-Profit Reporting Model Impact/Recommendation Defining and presenting a measure of operations in the Statement of Activities. Organizations that do not already provide a measure of operations should evaluate which activities would be presented In the Statement of Activities as operating vs. non-operating. Three net asset classes replaced with two classes: ― Those with donor restrictions and those without; ― Removing the distinction between temporary and permanent restrictions; ― Requiring a description of the differences in the nature of the restrictions and how and when those resources could be used. Organizations should begin to review footnote disclosures to determine that: ― Footnotes contain sufficient detail to enable users to understand how and when donor- restricted net assets can be used; ― Restricted net assets not permanently restricted are highlighted; ― Footnotes explain that all net assets not restricted in perpetuity are expendable for mission-related activities into the future. Proposed Changes to the Not-for-Profit Reporting Model
  65. 65. 64#CBIZMHMwebinar#CBIZMHMwebinar FASB’s Proposed Changes to Not-for-Profit Reporting Model Impact/Recommendation Direct method requirement for presentation of cash flows from operating activities in the Statement of Cash Flows. Initial preparation of the direct method will require some additional effort in mapping cash information to the various operating activities. Presentation of expenses by both functional and natural classifications within the financial statements along with an analysis of the relationship between natural and functional expenses. Preparation of an analysis of functional and natural classifications will require additional effort since most not-for-profit entities still present expenses by function on the Statement of Activities. Proposal on other communications, such as Management’s Discussion & Analysis (MD&A), removed from FASB’s agenda. No further action needed. Proposed Changes to the Not-for-Profit Reporting Model – Continued
  66. 66. 65#CBIZMHMwebinar#CBIZMHMwebinar  Feedback/concerns on intermediate measure of operations  Interest expense  Gifts of long-lived (capital) assets and related expirations of restricted gifts  Discussion of NPF-specific note disclosures  Applicability of recent PCC proposals to NFPs  Intangibles  Goodwill Other Considerations by the NAC
  67. 67. 66#CBIZMHMwebinar#CBIZMHMwebinar Questions?
  68. 68. 67#CBIZMHMwebinar#CBIZMHMwebinar Additional webinars:  10/7 & 10/22: Potential Changes in the Not-for-Profit Reporting Model  Recorded Webinar: Major Changes in Federal Reporting for Nonprofits Though leadership:  MHM Messenger: Federal OMB Grant Rules Overhauled  FASB Recommends Changes to Cash Flow Statements and Statements of Functional Expenses Reporting  Sign up for our Not-for-Profit Viewpoint e-newsletter If You Enjoyed This Webinar…
  69. 69. 68#CBIZMHMwebinar#CBIZMHMwebinar Connect with Us linkedin.com/company/ mayer-hoffman-mccann-p.c. @mhm_pc youtube.com/ mayerhoffmanmccann slideshare.net/mhmpc linkedin.com/company/ cbiz-mhm-llc @cbizmhm youtube.com/user/ BizTipsVideos slideshare.net/CBIZInc

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