Compare and contrast the conceptual framework for business, governmental and not for profits 2. Select an exposure draft on any

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Statement No. 29 of the Governmental Accounting Standards Board The Use of Not-for-Profit Accounting and Financial Reporting Principles by Governmental Entities

STATUS

Issued: August 1995

Effective Date: For periods beginning after December 15, 1994 (earlier application encouraged; however, the modification of the AICPA Not-for-Profit model for certain GASB pronouncements is effective for entities that previously have not applied those pronouncements for periods beginning after December 15, 1995)

Affects: Amends GASBS 4, ¶10

Amends GASBS 8, ¶11

Amends GASBS 20, ¶7

Affected by: Paragraph 1 superseded by GASBS 34, ¶3 Paragraph 2 superseded by GASBS 62 Paragraph 3 superseded by GASBS 34, ¶3 Paragraph 4 amended by GASBS 34, ¶3 and ¶94; superseded by GASBS 62 Paragraph 5 amended by GASBS 34, ¶3, ¶134–¶141, and ¶147; superseded by GASBS 62 Paragraph 6 and fn3 superseded by GASBS 34, ¶3 and ¶134–¶141 Paragraph 7 amended by GASBS 34, ¶94; superseded by GASBS 62

Primary Codification Section Reference: None Summary

This Statement provides interim guidance concerning the use of not-for-profit accounting and financial reporting principles by state and local governmental entities pending one or more GASB pronouncements on the accounting and financial reporting model for governmental entities, including proprietary activities. This Statement provides that governmental entities that heretofore have applied not-for-profit accounting and financial reporting principles by following the American Institute of Certified Public Accountants' (AICPA) Statement of Position (SOP) 78-10, Accounting Principles and Reporting Practices for Certain Nonprofit Organizations, or Industry Audit Guide, Audits of Voluntary Health and Welfare Organizations, should apply the Governmental model or the AICPA Not-for-Profit model. The AICPA Not-for-Profit model consists of the accounting and financial reporting principles contained in SOP 78-10 or Audits of Voluntary Health and Welfare Organizations—except for the provisions relating to the joint costs of informational materials and activities that include a fund-raising appeal—as modified by all applicable Financial Accounting Standards Board (FASB) pronouncements issued through November 30, 1989, and as modified by most applicable GASB pronouncements. This Statement also provides guidance for proprietary activities—that is, proprietary funds and other governmental entities that use proprietary fund accounting—that apply the provisions of paragraph 7 of GASB Statement No. 20, Accounting and Financial Reporting for Proprietary Funds and Other Governmental Entities That Use Proprietary Fund Accounting. It provides that those activities should apply only those FASB Statements and Interpretations issued after November 30, 1989, that are developed for business enterprises. They should not apply FASB Statements and Interpretations whose provisions are limited to not-for-profit organizations or address issues concerning primarily such organizations (such as FASB Statements No. 117, Financial Statements of Not-for-Profit Organizations, and No. 116, Accounting for Contributions Received and Contributions Made, respectively). The provisions of this Statement generally are effective for financial statements for periods beginning after December 15, 1994; the modification of the AICPA Not-for-Profit model for certain GASB pronouncements is effective for entities that previously have not applied those pronouncements for periods beginning after December 15, 1995. Earlier application is encouraged.

Unless otherwise specified, pronouncements of the GASB apply to financial reports of all state and local governmental entities, including general purpose governments, public benefit corporations and authorities, public employee retirement systems, utilities, hospitals and other healthcare providers, and colleges and universities. Paragraph 4 discusses the applicability of this Statement.

INTRODUCTION

♦1. Some governmental entities apply not-for-profit accounting and financial reporting principles by following the American Institute of Certified Public Accountants' (AICPA) Statement of Position (SOP) 78-10, Accounting Principles and Reporting Practices for Certain Nonprofit Organizations, or Industry Audit Guide, Audits of Voluntary Health and Welfare Organizations. Questions arose about the appropriate accounting and financial reporting for those governmental entities. Many of those questions concerned whether those entities should change their accounting and financial reporting to apply the provisions of Financial Accounting Standards Board (FASB) Statements No. 116, Accounting for Contributions Received and Contributions Made, and No. 117, Financial Statements of Not-for-Profit Organizations; others concerned whether those entities should discontinue using not-for-profit principles and follow only governmental accounting and financial reporting standards.

2. Some of the governmental entities that had questions about applying the provisions of FASB Statements 116 and 117 are proprietary activities—that is, proprietary funds and other governmental entities that use proprietary fund accounting. GASB Statement No. 20, Accounting and Financial Reporting for Proprietary Funds and Other Governmental Entities That Use Proprietary Fund Accounting, provides interim guidance on business-type accounting and financial reporting for proprietary activities pending the issuance of one or more GASB pronouncements on the accounting and financial reporting model for those activities. Paragraph 7 of Statement 20 allows proprietary activities to apply allFASB Statements and Interpretations issued after November 30, 1989, except for those that conflict with or contradict GASB pronouncements. Those questions concerned whether the intent of paragraph 7 of Statement 20 was that proprietary activities should apply only those new FASB Statements and Interpretations that are developed for business enterprises, or whether they also should apply those FASB standards whose provisions are limited to not-for-profit organizations or address issues concerning primarily not-for-profit organizations.

♦3. This Statement provides interim guidance pending one or more GASB pronouncements on the accounting and financial reporting model for governmental entities.

STANDARDS OF GOVERNMENTAL ACCOUNTING AND FINANCIAL REPORTING

Scope and Applicability of This Statement

♦4. ♦This Statement establishes requirements for applying not-for-profit accounting and financial reporting principles to state and local governmental entities. The requirements of paragraphs 5 and 6 apply to all governmental entities that heretofore have applied the accounting and financial reporting principles of SOP 78-10 or Audits of Voluntary Health and Welfare Organizations. The requirements of paragraph 7 of this Statement apply to all proprietary activities that apply paragraph 7 of Statement 20.

The Use of Not-for-Profit Principles

5. ♦Both the AICPA Not-for-Profit model and the Governmental model are acceptable for accounting and financial reporting by governmental entities that heretofore have applied not-for-profit accounting and financial reporting principles by following SOP 78-10 or Audits of Voluntary Health and Welfare Organizations. These entities should use one or the other of these models. For purposes of this Statement, these models are defined as:

a. The AICPA Not-for-Profit model—the accounting and financial reporting principles contained in SOP 78-10 or Audits of Voluntary Health and Welfare Organizations—except for the provisions relating to the joint costs of informational materials and activities that include a fund-raising appeal—as modified by all applicable FASB pronouncements issued through November 30, 1989, and as modified by:

(1) All applicable GASB pronouncements 1 issued after Statement No. 1, Authoritative Status of NCGA Pronouncements and AICPA Industry Audit Guide, except for those discussed in

paragraph 6 below.

(2) The note disclosure requirements of Codification Section 2300, "Notes to Financial Statements." 2

♦b. The Governmental model—the accounting and financial reporting standards established by NCGA Statement 1, Governmental Accounting and Financial Reporting Principles, as modified by subsequent NCGA and GASB pronouncements.

♦6. A governmental entity that uses the AICPA Not-for-Profit model is not required to apply GASB Statement No. 5, Disclosure of Pension Information by Public Employee Retirement Systems and State and Local Governmental Employers, if not previously applied. Also, if the entity has implemented FASB Statement No. 87, Employers' Accounting for Pensions, or No. 93, Recognition of Depreciation by Not-for-Profit Organizations, it is not required to apply GASB Statement No. 4, Applicability of FASB Statement No. 87, `Employers' Accounting for Pensions,' to State and Local

Governmental Employers, 3 or No. 8, Applicability of FASB Statement No. 93, `Recognition of Depreciation by Not-for-Profit Organizations,' to Certain State and Local Governmental Entities, respectively.

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7. ♦Proprietary activities that apply the provisions of paragraph 7 of Statement 20 should apply only those FASB Statements and Interpretations issued after November 30, 1989, that are developed for business enterprises. They should not apply FASB Statements and Interpretations whose provisions are limited to not-for-profit organizations, such as FASB Statement 117, or address issues concerning primarily such organizations, such as FASB Statement 116.

Effective Date and Transition

8. Except as discussed in the following paragraphs, the provisions of this Statement are effective for financial statements for periods beginning after December 15, 1994. Earlier application is encouraged. Entities that have applied the provisions of FASB Statements 116 and 117 should change their accounting and financial reporting principles to conform to the provisions of this Statement. If those entities present comparative financial statements, restatement of prior-year financial statements is required.

9. For entities that have applied the AICPA Not-for-Profit model but previously have not followed the governmental accounting and financial reporting standards required by paragraphs 5 and 6 of this Statement, the provisions of those governmental standards are effective for financial statements for periods beginning after December 15, 1995 (unless the original pronouncement has a later effective date). Earlier application is encouraged.

10. Accounting changes adopted to conform to the provisions of those previously effective governmental standards should be applied retroactively, if practical, by restating financial statements for all prior periods presented. If restatement of financial statements for prior periods presented is not practical, the cumulative effect of applying this Statement, if any, should be reported as a restatement of beginning fund balance or retained earnings, as appropriate, for the earliest period restated. In the period this Statement is first applied, the financial statements should disclose the nature of any restatement and its effect. Also, the reason that it was not practical to restate prior periods presented should be explained.

The provisions of this Statement need not be applied to immaterial items.

This Statement was adopted by unanimous vote of the five members of the Governmental Accounting Standards Board:

Tom L. Allen, Chairman

Robert J. Freeman

Barbara A. Henderson

Edward M. Klasny

Paul R. Reilly

Appendix A

BACKGROUND INFORMATION

11. In March 1995, the Board issued an Exposure Draft (ED) of a proposed Statement, The Use of Not-for-Profit Accounting and Financial Reporting Principles by Governmental Entities. The Board received thirty-nine comment letters on the ED, a large majority of which supported its provisions. Certain changes have been made to this Statement, however, as a result of respondent recommendations.

Governmental Entities That Have Applied Not-for-Profit Principles

12. In June 1993, the FASB issued Statements 116 and 117 to provide standards for accounting for contributions received and made and for general purpose external financial statements provided by not-for-profit organizations. Those two Statements are effective for fiscal years beginning after December 15, 1994 (1995 for smaller entities). Some governmental entities have questioned whether they should apply those FASB pronouncements.

13. Statement on Auditing Standards No. 69, The Meaning of`Present Fairly in Conformity with Generally Accepted Accounting Principles' in the Independent Auditor's Report (SAS 69), issued by the Auditing Standards Board of the AICPA, established a new hierarchy of generally accepted accounting principles (GAAP) in 1992. Under SAS 69, category (a) in the GAAP hierarchy applicable to state and local governmental entities "consists of GASB Statements and Interpretations, as well as AICPA and FASB pronouncements specifically made applicable to state and local governmental entities by

GASB Statements or Interpretations." 4 FASB pronouncements not made applicable by the GASB are considered other accounting literature (below category (d) in the GAAP hierarchy) for state and local governmental entities. Prior to the issuance of SAS 69, pronouncements of the FASB were presumed to apply to state and local governmental entities if no applicable GASB pronouncements existed on a

given subject. 5

14. Questions about the applicability of FASB Statements 116 and 117 arose in two situations in which governmental entities have followed not-for-profit accounting and financial reporting principles. First, some entities, especially those incorporated under Section 501 of the Internal Revenue Code, have only recently identified their status as governmental. To apply SAS 69, entities have to determine whether they are governmental or nongovernmental. Further, the implementation of GASB Statement No. 14, The Financial Reporting Entity, has caused governmental entities to consider the inclusion of various not-for-profit organizations in their financial reports and to consider whether those organizations are governments. Determining whether an entity is governmental is a matter of judgment based on an assessment of all of the facts and circumstances, including the entity's creation, structure, and operation—there are no authoritative standards that define when an entity is a government. In November 1993, the GASB staff issued, as advisory guidance only, a paper titled "Applicability of GASB Standards." That nonauthoritative paper is intended to be helpful in resolving questions about whether a particular entity should follow the hierarchy of accounting standards applicable to state and local governmental entities or the hierarchy applicable to nongovernmental entities. It discusses various characteristics that one may consider in evaluating whether an entity is a government.

15. Second, some entities previously identified as governmental have followed not-for-profit principles because they conduct the types of activities that are conducted by the organizations that are within the scope of SOP 78-10 and Audits of Voluntary Health and Welfare Organizations. Previous governmental accounting and financial reporting principles directed only certain proprietary activities to follow certain not-for-profit principles. The AICPA 1986 Audit and Accounting Guide, Audits of State and Local Governmental Units (1986 ASLGU), paragraph 5.26, observed that a number of not-for-profit activities—for example, libraries, museums, cemeteries, and zoological parks—also are conducted by some governmental entities. The 1986 ASLGU indicated that if the governmental activity is

conducted in a fashion that meets the criteria for a proprietary activity, the AICPA Audit and Accounting Guide, Audits of Certain Nonprofit Organizations, and SOP 78-10 would provide useful guidance. 6

Proprietary Activities

16. As discussed above, some of the governmental entities that have followed not-for-profit principles are proprietary activities. Proprietary activities are usually thought to be business-type activities, rather than not-for-profit activities. Codification Section 1300, "Fund Accounting," paragraph .102b, which is based on NCGA Statement 1, paragraph 18, as amended, provides that proprietary funds (enterprise funds and internal service funds) "are used to account for a government's ongoing organizations and activities that are similar to those often found in the private sector. . . ." It further provides that "the generally accepted accounting principles here are generally those applicable to similar businesses in the private sector . . . " and that "the measurement focus is on determination of net income, financial position, and cash flows. . . ."

17. Codification Section 1600, "Basis of Accounting," paragraph .126, which is based in part on NCGA Statement 1, paragraph 74, as amended, adds that "revenues earned and expenses incurred are recognized in a government's proprietary funds in essentially the same manner as in commercial accounting. . . . However, where the GASB has issued pronouncements applicable to entities and activities recognized in a government's proprietary funds, those entities and activities should be guided by the GASB pronouncements. Only minor adaptations are involved in applying the revenue realization and expense recognition principles in the government environment" (footnote references omitted). Business-type (commercial) accounting is generally defined by FASB pronouncements, Accounting Principles Board (APB) Opinions, and Accounting Research Bulletins (ARBs) of the Committee on Accounting Procedure.

18. In September 1993, the GASB issued Statement 20 as interim guidance on business-type accounting and financial reporting for proprietary activities. Paragraph 6 of that Statement requires proprietary activities to apply all applicable GASB pronouncements as well as all FASB Statements and Interpretations, APB Opinions, and ARBs issued on or before November 30, 1989, unless those pronouncements conflict with or contradict GASB pronouncements. Paragraph 7 of that Statement allows proprietary activities to apply allFASB Statements and Interpretations issued after November 30, 1989, except for those that conflict with or contradict GASB pronouncements.

Appendix B

BASIS FOR CONCLUSIONS

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19. This appendix discusses factors considered significant by Board members in reaching the conclusions in this Statement. It includes discussion of the alternatives considered and the Board's reasons for accepting some and rejecting others. Individual Board members gave greater weight to some factors than to others.

Governmental Entities That Have Applied Not-for-Profit Principles

20. Some of the governmental entities that apply not-for-profit accounting and financial reporting principles rather than governmental standards may be doing so because they conduct the type of activities addressed by those principles or because they previously had not identified themselves as governmental; others are doing so because they were directed to the guidance by the 1986 ASLGU.Before the issuance of this Statement, GASB standards did not specifically encompass the application of not-for-profit accounting and financial reporting principles. The GASB is adopting the AICPA Not-for-Profit model for governmental entities that have used those principles because the Board does not believe these entities should have to make significant changes in their accounting and financial reporting now when more changes may be required in the near future as a result of the Board's projects on the financial reporting model and nonexchange transactions.

21. This Statement allows governmental entities that have followed SOP 78-10 or Audits of Voluntary Health and Welfare Organizations to apply the Governmental model. Some entities may find the Governmental model more appropriate (or more complete) than the AICPA Not-for-Profit model.

22. A few ED respondents disagree with the provisions of paragraph 5; most of them believe that certain governmental entities other than proprietary activities should be permitted or required to apply FASB Statement 117. They are concerned about the continued use of the "outmoded" AICPA Not-for-Profit model for more than a short time while the Board completes its financial reporting model project. However, a large majority of ED respondents agree with the provisions of paragraph 5 as interim guidance. They believe that allowing governmental entities to continue to apply the AICPA Not- for-Profit model until the Board's financial reporting model project is complete is a needed and practical solution to the problem.

23. Some respondents believe that the fundamental issue underlying this Statement—identifying those entities that should apply the GAAP hierarchy applicable to state and local governmental entities —will continue to be troublesome until there is an authoritative definition of such "governmental entities." The Board agrees—but does not have the authority to unilaterally establish a definition—and intends to continue to explore alternatives for resolving the issue.

24. Although this Statement allows governmental entities that have followed SOP 78-10 or Audits of Voluntary Health and Welfare Organizations to continue to do so, it also requires entities to apply certain GASB standards they may not have applied previously. The governmental standards required by paragraphs 5 and 6 of this Statement are essentially the same standards required for governmental colleges and universities that follow the AICPA College Guide model established in GASB Statement No. 15, Governmental College and University Accounting and Financial Reporting Models. There are, however, four differences.

a. The first relates to the provisions of Statement 5, which will be superseded when Statement 27 becomes effective for financial statements for periods beginning after June 15, 1997. The Board sees no reason for these entities to implement disclosures that will no longer be effective two years after application.

b. The second and third relate to employer accounting for pensions and to special termination benefits. This Statement does not require these entities, including those that have applied FASB Statement 87, to change their accounting for pensions until they apply Statement 27. (GASB Statement 4 precluded governmental entities from applying the provisions of FASB Statement 87.) This Statement also does not require entities that have applied FASB Statement 88 to change their accounting for special termination benefits until they apply Statement 27.

c. The fourth relates to depreciation accounting. This Statement does not require entities that have applied FASB Statement 93 to conform to the guidance on depreciation accounting contained in SOP 78-10 and Audits of Voluntary Health and Welfare Organizations. 7

25. Respondents also agree that governmental entities that apply the AICPA Not-for-Profit model should apply the GASB standards required by paragraphs 5 and 6. They noted that this approach is consistent with GASB Statement 15. One specifically agreed with permitting those entities that apply the AICPA Not-for-Profit model to continue their accounting practices for pensions and special termination benefits until the implementation of GASB Statement 27, finding that provision practical and cost-beneficial.

26. The ED had proposed to require that the AICPA Not-for-Profit model include the provisions of SOP 87-2, Accounting for Joint Costs of Informational Materials and Activities of Not-for-Profit Organizations That Include a Fund-Raising Appeal. This Statement does not include the provisions of SOP 87-2 or those in SOP 78-10 and Audits of Voluntary Health and Welfare Organizations relating to such costs as part of the AICPA Not-for-Profit model. That is because the Board does not want to elevate those provisions to category (a) in the GAAP hierarchy; the AICPA expects to establish new accounting and financial reporting standards for those costs in an upcoming SOP that specifically applies to governmental entities. The AICPA issued an ED of a proposed SOP, Accounting for Costs of Materials and Activities of Not-for-Profit Organizations and State and Local Governmental Entities That Include a Fund-Raising Appeal, in September 1993. When the final SOP becomes effective, provided the final scope includes governmental entities, it will be category (b) in the GAAP hierarchy for all governmental entities, including those that apply the AICPA Not-for-Profit model.

27. The Board agreed to use the November 30, 1989, issuance date of FASB pronouncements for the provisions in paragraph 5 for various reasons. This is the date of the 1989 Jurisdictional Determination, in which the Financial Accounting Foundation trustees reaffirmed the GASB's status as the standards setter for all state and local governmental entities. The 1989 Jurisdictional

Determination prompted the issuance of SAS 69. This cut-off date also is consistent with paragraph 4a of Statement 15 8 and paragraph 6 of Statement 20.

28. The effect of this cut-off date is that FASB pronouncements beginning with Statement No. 103, Accounting for Income Taxes—Deferral of the Effective Date of FASB Statement No. 96, and Interpretation No. 39, Offsetting of Amounts Related to Certain Contracts, should not be applied by entities that follow the AICPA Not-for-Profit model except as other accounting literature. Some entities that have applied not-for-profit accounting and financial reporting principles may have applied certain FASB pronouncements issued after November 30, 1989, such as Statements No. 105, Disclosure of Information about Financial Instruments with Off-Balance-Sheet Risk and Financial Instruments with Concentrations of Credit Risk, and No. 106, Employers' Accounting for Postretirement Benefits Other Than Pensions. If FASB pronouncements conflict with or contradict GASB pronouncements, the entity should instead apply the appropriate GASB standards. In particular, entities that apply the AICPA Not-for-Profit model should not change their accounting and financial reporting to apply FASB Statements 116 and 117, which contradict this Statement's paragraph 5 requirement to follow SOP 78-10 or Audits of Voluntary Health and Welfare Organizations.

29. From time to time, FASB pronouncements are issued to amend or supersede pronouncements that had been issued on or before November 30, 1989. Unless the GASB specifically adopts the new FASB Statement or Interpretation, entities that apply the AICPA Not-for-Profit model should apply the FASB pronouncement as originally issued.

30. The Board presumes that the logic of the provisions of paragraph 5 will be applied to other sources of accounting guidance. For example, if a new AICPA pronouncement (SOP or Industry Audit and Accounting Guide) does not specifically include governmental entities in its scope, then it is other accounting literature in the GAAP hierarchy for entities that follow the AICPA Not-for-Profit model. (If the effects of any of these new pronouncements conflict with or contradict GASB pronouncements, the entity should not apply them.) An AICPA SOP or Industry Audit and Accounting Guide that specifically includes governmental entities in its scope and that has been cleared by the GASB is category (b) guidance for all applicable governmental entities.

31. A respondent to the ED questioned whether this Statement could be applied by new governmental entities created after the Statement is issued—that is, whether those entities could choose to use the AICPA Not-for-Profit model. Because this Statement authorizes the use of that model only by entities that heretofore have applied certain not-for-profit accounting and financial reporting principles, new governmental entities should apply the Governmental model.

Proprietary Activities

32. Three positions had developed regarding the application of FASB Statements 116 and 117 to proprietary activities that apply paragraph 7 of Statement 20. Some believed that those proprietary activities should or could apply Statements 116 and 117 because nothing in Statement 20 prohibits their application. Others believed that some of the provisions of those Statements should not be applied by proprietary activities because they conflict with or contradict the provisions of certain GASB standards, such as those pertaining to the recognition of grant revenue, the reporting of contributed capital, and financial statement display.

33. Still others believed that proprietary activities that apply the provisions of FASB Statements and Interpretations issued after November 30, 1989, should apply only the FASB's business-type or commercial standards. Therefore, they believed that it would be inconsistent with Statement 20 for proprietary activities to apply FASB Statement 117 or the provisions of FASB Statement 116 that are limited to not-for-profit organizations (paragraphs 14 through 17 and portions of paragraphs 8 and 20). They also believed that, although the other provisions of Statement 116 do apply to business enterprises, it would be inconsistent for proprietary activities to apply any provisions of the Statement because its primary focus is on the recognition of contributions received by not-for-profit organizations. (Paragraph 1 of Statement 116 states that "accounting for contributions is an issue primarily for not-for-profit organizations because contributions are a significant source of revenues for many of those organizations.")

34. The Board's intent in paragraph 7 of Statement 20 in allowing proprietary entities to apply FASB Statements and Interpretations issued after November 30, 1989, was to permit those entities that traditionally have been accounted for in the same manner as similar businesses in the private sector to continue to do so, pending the GASB's issuance of accounting and financial reporting standards for proprietary activities. After considering the application of Statement 20 in light of the positions that had developed about applying FASB Statements 116 and 117, the Board concluded that entities that use proprietary fund accounting should apply only those FASB pronouncements that are developed for business enterprises, not those pronouncements whose provisions are limi

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