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

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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

description

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.

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

Page 1: Webinar Slides: Not-for-Profit Annual Accounting and Federal Grant Update

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

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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…

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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

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Michelle E. Spriggs, CPA, MBA Shareholder 774.206.8336 | [email protected] 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 | [email protected]

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.

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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

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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 Answers 6

4 The New COSO Reporting Model

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CHANGES TO ACCOUNTING AND AUDITING STANDARDS

What to expect this year

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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

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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

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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

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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

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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

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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

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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 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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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 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

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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

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

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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

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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

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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

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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.

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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.

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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”

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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

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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

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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

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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

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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

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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)

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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

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Use allowance no longer allowed

No depreciation on assets that are fully depreciated

Depreciation (200.436)

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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

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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

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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

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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

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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

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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

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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

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Uniform Guidance Cost Principles Text Comparisons http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-cost-principles-requirements-text-comparison.pdf

Uniform Guidance Audit Requirements Text Comparisons http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-audit-requirements-text-comparison.pdf

Links to Helpful Documents – Continued

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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

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THE NEW COSO FRAMEWORK

How will it impact your organization?

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COSO Framework – 20 Years in the Making

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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

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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?

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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

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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 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

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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

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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

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Questions?

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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

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