GASB Statement No. 34

advertisement

1

Association of College and

University Auditors

(ACUA)

James E. Morley, Jr.

September 23, 2002

Salt Lake City, Utah

2

Presentation Overview

• Part I - Higher education in transition

• Part II - Current national issues

• Part III - Internal audit: Today and the future

3

Higher education in transition

• Rapid change: Industry

• Cost/price increases: Funding shortfalls

• Accountability

• Competition

• Rapid change: Expectations

4

Higher education in transition

Rapid change: Industry

5

Enrollment in Higher Education,

1940-2002

Source: Department of Education via Chronicle of Higher Education Almanac

18000

16000

14000

12000

10000

8000

6000

4000

2000

0

19

40

19

45

19

50

19

55

19

60

19

65

19

70

19

75

Year

19

80

19

85

19

90

19

95

20

00

20

02

Public

Private

Total

6

Growth in Higher Education

• Square Footage

– 1950s - 500 million

– 1980s - 3 billion

– 1990s - 4 billion

• New Construction

– Between 1994 & 1996 - $12 billion

– Projections for 2010

• Additional $200+ billion to build

Higher education in transition

Cost/price increases: Funding shortfalls

8

Undergraduate Tuition at Colleges and

Universities, 1940 - 2001

16000

14000

12000

10000

8000

6000

4000

2000

0

19

40

19

45

19

50

19

55

19

60

19

65

19

70

19

75

19

80

19

85

19

90

19

95

20

01

Year

Source: Chronicle of Higher Education Almanac 2001

Public

Private

9

Comparison of revenue from major sources for public institutions

Source: Digest of Education Statistics, 1999, National Center for Education Statistics

%

50

40

30

20

10

0

1980-81 1985-86 1990-91 1996-97

Tuition and Fees

State Appropriations

Sales and Services

Other

10

Average Tuition Discount:

Full Time Freshmen

45%

40%

35%

30%

25%

20%

15%

SCLT

SCHT

LCU

All

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000

11

Higher education in transition

Accountability

12

Accountability

• Scrutiny of costs, salaries, tenure, graduation rates, and curriculum

• School-to-work transition

– rise in professional education

• Minority retention

• For-profit comparisons

– inefficient operations

– unresponsive structure

– underutilized technology

Higher education in transition

Competition

14

A Competitive Environment

• Competition for students and for resources

– Increase in tuition discounting and faculty salaries as a result

• Customers (students) expecting and demanding more from institution

– Increased attention to student services

• Market segments fragmenting

– Increasing niche competition

• Competition from distance learning

• Rise of for-profit schools

15

Higher education in transition

Rapid change: Expectations

16

Higher education in transition

• A consumer-driven marketplace

• Consumers (better called stakeholders) place constant and competing demands

• Technology overlay

• Globalization

– Terrorism

– Disease

– Culture

17

Current national issues

18

Current national issues

• War against terrorism & homeland security

• Tax issues and accounting-related

• Federal regulations

• Technology

19

National issues

War against terrorism and homeland security

20

Homeland security:

Impact on colleges and universities

• Foreign students and visitors

• Sharing of information with law enforcement and privacy concerns

• IT security

• Laboratory security and treatment of biohazards

21

Homeland security:

New federal laws

• USA Patriot Act (enacted October 26, 2001)

• Enhanced Border Security and Visa Entry Reform Act

(enacted May 14, 2002)

• Public Health Security and Bioterrorism

Preparedness Act (enacted June 12, 2002)

22

Homeland security:

USA Patriot Act

Information sharing:

This legislation provides simplification for federal officials to receive court orders for student records and amends FERPA to permit “emergency disclosure.”

• Calls for full implementation of INS foreign student tracking system (SEVIS)

• With court order, Feds investigating terrorism may obtain business and student records

23

Homeland security:

USA Patriot Act (cont’d)

Information sharing:

Updates surveillance laws to cover today’s communications —e-mail, voice mail, etc.

• Makes it easier for law enforcement to acquire

“routing” information (pen registers, trap and trace), and relieves institutions of liability

• May result in increased requests for information

24

Homeland security:

Enhanced Border Security and

Visa Entry Reform Act

• Enhancements to SEVIS

– Re-certification of all institutions w/ biennial reviews

– Additional information on foreign students

– Notification requirements between Department of

State, INS, and institutions to track student entry, enrollment, and changes in status

• Interim notification system by 9/14/02

• New background checks for visa applicants from countries that sponsor terrorism

25

Homeland security:

Student and Exchange Visitor

Information System (SEVIS)

• Problems for campuses with large foreign student populations

• Batch interface not yet available for institutions that will not key information directly into system

• Web-based system for preliminary enrollment went live July 1; institutional reporting not mandatory before January 30

26

Homeland security:

Public Health Security & Bioterrorism Preparedness Act of 2002

– Select agent list to be reviewed at least biennially

– Regulations will cover possession and use, not just transfers, of select agents

– Tighter controls, including federal background checks on persons allowed access to select agents

– Broad inspection authority for HHS

27

Homeland security:

Social security requirements for

INS verification

• New guidance asks INS to issue verification based on review of passports and related documents for foreign applicants for SSNs

• SSA estimates new step will add 3-12 weeks to receipt of SSN

• Campus issuance of “temporary” nine-digit identifiers to address internal payroll unofficially acknowledged by SSA

• Check SSA website for up-to-date guidance

28

Department of Homeland Security:

Proposed

 The administration’s five organizational categories proposed for the new department include 24 government entities

 Border and Transportation

 Emergency Preparedness and Response

Chemical, Biological, Radiological and Nuclear Countermeasures

 Information Analysis and Infrastructure Protection

 Secret Service

Sixty-one Congressional committees and subcommittees now have authority over the 24 organizations likely to be merged into the new department

 And, at present, the House Government Reform and Senate Governmental

Affairs committees have general oversight authority

• Source: Congressional Quarterly

29

National issues

Tax issues and accounting-related

30

Tax issues:

Recent IRS actions

• Memo on FICA withholding for medical residents

• Final rules published for:

– Intermediate sanctions

– Corporate Sponsorships

• Re-proposed rules on 1098-T reporting

31

Tax issues:

FICA Rules for medical residents

• Memo from IRS chief counsel indicates residents not eligible for student FICA exemption (January 24,

2002)

• Rationale:

– Most services provided by residents are treated as on-the-job training, not part of study program

– Therefore not eligible for student FICA withholding exemption

32

Tax issues:

Final rules on corporate sponsorships

• Safe harbor for qualified sponsorship payments

• Exclusive sponsorships allowed

• Exclusive provider arrangements not in safe harbor— but not automatically subject to UBIT

• EO’s web site can link to sponsor’s site, but not endorse it

• Rules published 4/25/02 Federal Register, and are applicable for payments solicited or received after

December 31, 1997

33

Tax issues:

IRS Re-proposes 1098-T reporting requirements

• Eases reporting burden

• Repeals requirement to collect name / SSN of individuals claiming student as dependent

• Allows reporting of aggregate amount of qualified tuition / expenses or amounts billed

• Prior year reporting limited to adjustments to amounts previously reported —not all refunds

• Removes requirement to report on individuals ineligible for benefit

34

Tax issues:

IRS Re-proposes 1098-T reporting requirements (cont’d)

• Comments due July 29 – see web site for NACUBO response

• Effective date of new regulations will be for tax year

2003 (1098-Ts that will be filed in early 2004)

• Final rules expected by end of 2002

35

Accounting-related: GASB Standards

• GASB Statement No. 34

• Basic Financial Statements-And Management’s

Discussion & Analysis-for State and Local

Governments

• GASB Statement No. 35

• Amends GASB34 to include Public Colleges and Universities

36

GASB Standards (cont’d)

• GASB Reporting Model Implementation Guides

– Two separate guides developed by GASB staff

(April 2000 and January 2002)

– Special NACUBO guide issued January 2001 for public colleges and universities

• GASB Statement No. 37 - Omnibus Statement

– Addresses problems created by GASB34 and

GASB35

37

GASB Standards (cont’d)

• GASB Statement No. 38 - Note Disclosures

• Significantly modifies required disclosures

• Eliminates some, adds others

• Debt, legal issues, payables/receivables

• GASB Statement No. 39 – Affiliated

Organizations

• Applies to foundations and other entities supporting public institutions

38

Accounting-related: GASB Projects

• Deposit and investment risk disclosure

• Other post-employment benefits

• Conceptual framework

39

Accounting-related: FASB Standards

• FASB Statement No. 141 - Business Combinations

– Excludes not-for-profits

• FASB Statement No. 142 - Goodwill and Intangible

Assets

– Application to NFPs deferred until NFP combination project is complete

40

FASB Standards (cont’d

)

• Not-for-profit business combinations

• Measuring financial instruments at fair value

41

Accounting-related: AICPA Project

• Exposure draft revises rules for Property,

Plant & Equipment accounting

• Specifies expenditures which qualify for capitalization

42

Accounting-related:

Sarbanes-Oxley Act of 2002

• Creates new, independent regulatory body, the Public Company

Accounting Oversight Board (PCOAB)

• Changes to ensure FASB independence in setting national accounting standards

• Auditor independence requirements mandated for audits of publicly traded companies

• New corporate responsibilities and restrictions for CEOs and

CFOs

• Focus on greater disclosure and transparency in financial reporting, internal controls, ethics, audit committee expertise

• Stricter provisions and for corporate fraud and white-collar crime

43

Possible future actions

• Increased disclosure: GASB Statement 39 (issued

2002)

• GASB performance measures “experiment”—coming

(end —2002)

• FASB mandated study of principles-based accounting financial reporting system (due July 2003)

44

Professional & standards-setting groups

• AICPA

• FASB

• GASB

• PCAOB

45

National issues

Federal regulations

46

Federal regulations: ED – Title IV

Program eligibility rules

• Replace the 12-hour rule with a one-day rule

• Clarify provisions for incentive compensation and identifies “safe harbor” activities for student recruiters

• Clarify need to take attendance in order to comply with return of

Title IV funds requirements

• Amend overpayment rules to permit students owning small amounts to retain their program eligibility

• Expand from 90 to 120 days for making late disbursements and require institutions to offer them to students who complete the period of enrollment

• Eliminate the rule for institutions to confirm the receipt of notices sent to borrowers (or parents for PLUS loans) that loan funds have been credited to students’ accounts

47

Federal regulations:

OMB Federal Financial Assistance

Management Improvement Act of 1999

• Proposed revisions to Circular A-133, Audits of States, Local

Governments, and Non-Profit Organizations

• Proposal for a standard format for federal agency use in announcing discretionary grant and cooperative agreement funding opportunities

• Proposed standard data elements for federal agency use in creating grant funding opportunity announcement summaries under the E-Grants initiative

• Proposed revisions to three OMB cost principles circulars (A-21,

A-87, A-122) to clarify ambiguous language in the interpretation of similar costs

• Proposed revision to Circular A-110, Uniform Administrative

Requirements for Grants and Agreements with Institutions of

Higher Education, et al

48

Federal regulations: New opportunity to assess regulatory costs, impacts

• A new administrative policy will allow regulated entities and the public to challenge agency rules and the accuracy of the data behind them.

• A little-known provision included as a rider in the

FY2001 appropriations bill for Treasury and General

Government requires all federal agencies to ensure

“the quality, objectivity, utility, and integrity of information” they produce.

49

Issues in 2002:

Status of Congress

• Late July initiatives included approval of new

Homeland Security Agency and passage of

Corporate Accountability Bill

– Corporate Accountability Bill affects only corporations directly, including creation of an independent oversight board loosely attached to the SEC

50

National issues

Technology

51

Technology: 2002 Issues

• Broadband access

• Distance education and federal student aid

• Information technology authorization

• Intellectual property

• Network security

• Privacy

• Workforce development

• FY’03 funding priorities

52

Technology:

Higher Education Information

Technology Alliance (HEIT)

• Five years old; convened by NASULGC and

EDUCAUSE

• Represents higher education’s collective interests in federal information technology policy

• Hosts annual forum to share information and formulate legislative issues agenda

• USA Patriot Act, cyber security legislation, and homeland security activities have far-reaching implications for higher education

53

Technology: HEIT Alliance members

AACC

AASCU

ACE

AAU

Association of

Research Libraries

NAICU

EDUCAUSE NASULGC

Internet2 University Continuing

Education

Association

NACUBO

54

Could there ever be a better time to be an internal auditor?

55

Internal audit: Today and the future

Two key themes…

• Senior financial/business officers’ perspectives on internal audit

• Adding value as an internal auditor

56

Senior business/financial officers’ perspectives

• Budget range: $140 million to $2.4 billion (most over

$1 billion)

• Five publics, five privates

• Staff size (professional)

– 1-12

– One institution fully outsourced except for Director

– One institution had no internal audit function

57

Senior business/financial officers’ perspectives (cont’d)

• Reporting relationships

– Nine of ten IA directors report to a senior staff member for administrative purposes

– One reports directly to the Audit Committee

• In-house or outsourced?

– One is fully outsourced but Director is internal staff

– All have considered at one time

58

Senior business/financial officers’ perspectives (cont’d)

Yearly plan development

– Internal development and review, Audit Committee approval

– Each has various approaches to risk assessment – many with multi-year planning

– Increasing emphasis on advisory and investigation work

– Proactive follow-up by senior management

59

Adding value as an internal auditor

• Be a partner

– Identifying risks

– Identify solutions

– Propose appropriate controls

• Follow best practices

– Be “the” expert on process and good management practices

• Effective communications

60

Adding value as an internal auditor

(cont’d)

• Provide management advisory services

– Enterprise wide risk assessment

– Policy interpretation and early procedural guidance

• Educational resource

– Training

– Systems development

• Member of cross functional teams

– Support recommendation implementation

61

Adding value as an internal auditor

(cont’d)

From “The Extraordinary Higher Education Leader”

– Think like the President/Chancellor/CFO

– Unlearn what has made you successful

– Develop your total intelligence

– Build and manage key relationships

62

Think like the

President/Chancellor/CFO

• Effective resource gathering, allocation, and control

– State and federal grants

– Tuition discounting

– Development

• Compliance

– Tax-related

– Research

– Social legislation

• Technology related

• Homeland security

– Business continuity

63

Unlearn what has made you successful

• Ask others for feedback

• Let go of detail – think systemically

• Focus on design, facilitation, and motivation

• From problem-solving to capacity-building

• Build support before issuing a report

64

Develop your total intelligence

• Develop and maintain a balanced lifestyle

• Heart knowledge

– Know yourself emotionally

– Ability to understand others’ intentions and behaviors

– Build on your strengths

65

Build and manage key relationships

• Who are they? Find out!

– Audit committee, plus

– President

– CFO and senior staff

– Departmental staff

– External auditors

– State and federal auditors

– Regulators

66

Success depends on:

• Regular, systematic innovation and change

• Influencing senior management and the governance process

67

NACUBO Website http://www.nacubo.org/presidents_corner

68

69

Download