Canadian Association of University Business Officers Financial Reporting Information Note–Contributions February 2012 Purpose Canadian colleges and universities hereinafter referred to as higher education Institutions (“Institutions”) will be adopting a new basis of accounting for fiscal years beginning on or after January 1, 2012. Depending on their provincial jurisdiction and control structure, Institutions will be preparing their financial statements using (1) Part III of the CICA Handbook – Accounting Standards for Not for Profit Organizations, (2) Public Sector Accounting Standards with the Section 4200 series, or (3) Public Sector Accounting Standards without the Section 4200 series. Institutions who are government not-for-profit organizations (GNPO) will be reporting under the Public Sector Accounting standards either with or without the 4200 series. The Public Sector Accounting standards alone (i.e. without the 4200 series) do not have a Section which specifically addresses accounting for contributions other than those received from governments. Section PS 3100, Restricted Assets and Revenues, establishes standards on how to account for and report restricted assets and revenues in an Institution’s financial statements. Section PS3410, Government Transfers, establishes standards on how to account for and report government transfers to Institutions. Within the 4200 series, section PS4210, Contributions – Revenue Recognition establishes standards for the recognition, measurement, presentation and disclosure of contributions. Part III of the CICA Handbook – Accounting Standards for Not for Profit Organizations includes section 4410, Contributions – Revenue Recognition on contributions received by not for profit organizations. The recognition, measurement, presentation and disclosure requirements with respect to contributions are identical under PS4210, and section 4410, and consistent with an Institution’s current existing standards in accounting for contributions. This financial reporting information note assesses the impact of adoption of each basis of accounting on the accounting for contributions by Canadian Institutions. Contributions CAUBO/ACPAU Page 1 of 12 March 2012 Key Topics This financial reporting information note will address the following key areas with respect to contributions: Purpose ____________________________________________________________________________ 1 Key Topics __________________________________________________________________________ 2 Contributions Received By Canadian Institutions____________________________________________ 3 Current Accounting for Contributions __________________________________________________ 3 Summary of Key Elements in the PSA Standards and Part III of the Handbook _____________________ 3 Analysis of Accounting Treatment under PSA and Part III _____________________________________ 4 Accounting Treatment Under PSA + 4200 and Part III ______________________________________ 4 Accounting Treatment under PSA (Without the 4200 Series) ________________________________ 9 Transitional Provisions _______________________________________________________________ 12 Contributions CAUBO/ACPAU Page 2 of 12 March 2012 Contributions Received By Canadian Institutions Canadian Institutions typically receive contributions such as grants, and pledges and donations from external parties including individuals, foundations, corporations and governments. Certain of these contributions are restricted in use by the external contributor, such as grants and donations for research or capital purposes. Institutions also receive restricted contributions which must be retained in perpetuity, such as endowments. Endowment contributions are addressed in a separate financial reporting information note, and are therefore excluded from the scope of this financial reporting information note. Section 4410, Contributions – Revenue Recognition defines a contribution as “…a non-reciprocal transfer to a not-for-profit organization of cash or other assets or a non-reciprocal settlement or cancellation of its liabilities. Government funding provided to a not-for-profit organization is considered to be a contribution.” Current Accounting for Contributions Prior to the requirement for adoption of a new basis of accounting for all entities for fiscal years beginning on or after January 1, 2012, an Institution’s accounting for contributions has been based upon the accounting standards issued by the Accounting Standards Board of the Canadian Institute of Chartered Accountants (hereinafter referred to as “preexisting GAAP”) contained in Section 4410, Contributions – Revenue Recognition with respect to the recognition, measurement, presentation and disclosure of contributions received by not-for-profit organizations. The accounting for certain contributions requires significant professional judgment to be exercised by Institutions with respect to the interpretation of the nature and characteristics of restrictions placed by the external party on the use of the contributed funds. In certain instances, government funding for example may be considered to be restricted based upon the nature of an Institution’s approved operating budget supporting the requested funding, as well as requirements to report back to the donor. Donors may also place restrictions on contributions with respect to the conduct of research by an Institution, the payment of scholarships and other student awards, the purchase of capital assets, or the construction and renovation of facilities. In each instance, Institutions must apply professional judgment to ensure that the accounting for the contributions at the time of receipt as well as the use of the funds over time is consistent with the imposed restriction. This information note does not endeavour to describe specific, potential scenarios of restrictions on contributions received or restrictions on related investment income. For those Institutions who have historically accounted for contributions under Section 4410 of the former Handbook, the accounting treatment of individual contributions should not change as a result of the transition to Part III of the Handbook, or to PSA + 4200. Summary of Key Elements in the PSA Standards and Part III of the Handbook The key elements of relevant sections of the PSA standards, and Part III of the Handbook are referenced throughout the analysis presented in this financial reporting information note. Contributions CAUBO/ACPAU Page 3 of 12 March 2012 Analysis of Accounting Treatment under PSA and Part III Accounting Treatment Under PSA + 4200 and Part III Since the recognition, measurement, presentation and disclosure requirements with respect to contributions are identical under PSA Section PS4210, and Section 4410 of Part III of the CICA Handbook, the accounting for contributions under both Part III– Accounting Standards for Not for Profit Organizations, and the Public Sector Accounting Standards with the Section 4200 series are considered together in this financial reporting information note. Contributions The recognition, measurement, presentation and disclosure of contributions, and related investment income under each of PS4210 and Section 4410 are exactly the same with an Institution’s present treatment of contributions under preexisting GAAP with the 4400 series of standards for not-for-profit organizations. Consequently, for those Institutions who have historically accounted for contributions under Section 4410 of the former Handbook, the accounting treatment of contributions should not change as a result of the transition to Part III of the Handbook or to PSA + 4200. An Institution’s accounting for contributions is dependent upon whether the Institution follows the deferral method or the restricted fund method of accounting for contributions. Institutions applying the deferral method of accounting for contributions recognize unrestricted contributions as revenue when received or receivable if the amount to be received can be reasonably estimated and collection is reasonably assured. Contributions which are externally restricted for purposes other than endowments and capital assets are deferred and recognized as revenue in the year in which related expenses are recognized. Institutions must apply professional judgment in determining whether external restrictions have been placed upon certain contributions received. With respect to contributions received from governments, Sections 4410 and PS4210 both note that “…The assessment of whether government funding in a particular situation represents a restricted or an unrestricted contribution depends on the characteristics of the contribution. Restrictions on government funding may be indicated by the fact that the funding is provided based on the organization's approved operating budget. Another indication that funding is restricted may be a requirement to report to the funder as to how the resources were actually used.” Contributions which are externally restricted for the purchase of capital assets are deferred and recognized as revenue on the same basis as the related capital asset’s amortization. Contributions which are externally restricted for the purchase of capital assets that will not be amortized (such as land) should be recognized as a direct increase in net assets. Institutions applying the restricted fund method of accounting for contributions recognize unrestricted contributions as revenue of the general fund in the year received or receivable, if the amount to be received can be reasonably estimated and collection is reasonably assured. Restricted contributions for which a corresponding restricted fund is present are recognized as revenue of that fund in the year received or receivable. Sections 4410 and PS4210 define a restricted fund as “…a self-balancing set of accounts the elements of which are restricted or relate to the use of restricted resources. Only restricted contributions, other than endowment contributions, and other externally restricted revenue would be reported as revenue in a restricted fund. Allocations of resources that result from the imposition of internal Contributions CAUBO/ACPAU Page 4 of 12 March 2012 restrictions are recorded as interfund transfers to the restricted fund.” Contributions which are externally restricted for the purchase of capital assets may be recognized as revenue in a capital asset fund, if one exists. Where no corresponding restricted capital asset fund is presented, the restricted contributions would be recognized in the general fund in accordance with the deferral method. Net Investment Income An Institution’s accounting for investment income is significantly influenced by whether the Institution adopts Part III of the CICA Handbook – Accounting Standards for Not for Profit Organizations, or the Public Sector Accounting Standards with the Section 4200 series. For institutions reporting under the PSA standards, unrealized net investment income would only be recognized in the Statement of Remeasurement Gains and Losses, as discussed in the following section. For institutions reporting under Part III of the Handbook, net investment income is defined to include revenue, and gains or losses on investments regardless of whether they are realized or unrealized. Both remeasurement gains and losses and realized gains and losses without external restrictions are recognized in net income through the Statement of Operations. Whether an Institution follows the deferral or restricted fund method of accounting also has a significant influence on how investment income is accounted for. These accounting considerations related to investment income are highlighted in the following table: Contributions CAUBO/ACPAU Page 5 of 12 March 2012 Deferral Method Externally restricted net investment income related to a contribution for the purchase of capital assets that will not be amortized. (such as land) Restricted Fund Method PSA + 4200 Series Part III Not-ForProfit Standards PSA + 4200 Series Part III Not-ForProfit Standards Net investment income initially recorded as a deferred contribution on the Statement of Financial Position. Once the contribution plus any accumulated net investment income is applied for the purchase of the capital asset that will not be amortized, the aggregate amount of the contribution and accumulated net investment income would be recorded in net assets. Net investment income, including both realized and unrealized gains or losses on investments accounted for as direct increases, or decreases, in net assets. Net investment income recognized as revenue of the capital asset fund, or if there is no applicable fund in the general fund as a deferred amount. Net investment income, including both realized and unrealized gains or losses on investments recognized as revenue of the capital asset fund, or if there is no applicable fund in the general fund as a deferred. The change in unrealized externally restricted net investment income related to a contribution for the purchase of capital assets which will not be amortized would be recorded in the Statement of Remeasurement Gains and Losses, and flow Contributions CAUBO/ACPAU Page 6 of 12 The change in the unrealized externally restricted net investment income related to a contribution for the purchase of capital assets which will not be amortized would be recorded in the Statement of Remeasurement Gains and Losses, and flow through the Statement of Operations once the gain or loss is realized. March 2012 Deferral Method Restricted Fund Method through the Statement of Operations once the gain or loss is realized. Restriction is placed on the use of net investment income earned on a contribution for a specific purpose Net investment income is recorded as a deferred contribution on the Statement of Financial Position, and recognized in income on the Statement of Operations as the net investment income is used for that specific purpose (in a manner consistent with the nature of the external restriction imposed on the original contributed funds.) The change in the unrealized externally restricted net investment income for a specific purpose would be recorded in the Statement of Remeasurement Gains and Losses, and flow through the Statement of Contributions CAUBO/ACPAU Net investment income, including both realized and unrealized gains or losses on investments recorded as a deferred contribution on the Statement of Financial Position, and recognized in income on the Statement of Operations as the net investment income is used for that specific purpose (in a manner consistent with the nature of the external restriction imposed on the original contributed funds.) Page 7 of 12 Net investment income recognized as revenue of the most applicable fund, or if there is no applicable fund in the general fund as a deferred amount. The change in the unrealized externally restricted net investment income for a specific purpose would be recorded in the Statement of Remeasurement Gains and Losses, and flow through the Statement of Operations once the gain or loss is realized. Net investment income, including both realized and unrealized gains or losses on investments recognized as revenue of the most applicable fund, or if there is no applicable fund in the general fund as a deferred amount. March 2012 Deferral Method Restricted Fund Method Operations once the gain or loss is realized. No external restriction placed on the net investment income Net investment income (excluding any unrealized fair value gains and losses) recognized in the Statement of Operations in the period earned. Net investment income (including both realized and unrealized fair value gains and losses) recognized in the Statement of Operations in the period earned. The change in unrestricted net investment income which has not yet been realized would be recorded in the Statement of Remeasurement Gains and Losses, and flow through the Statement of Operations once the gain or loss is realized. Net investment income (excluding any unrealized fair value gains and losses) recognized as revenue of the general fund. Net investment income (including both realized and unrealized fair value gains and losses) recognized as revenue of the general fund. The change in unrestricted net investment income which has not yet been realized would be recorded in the Statement of Remeasurement Gains and Losses, and flow through the Statement of Operations once the gain or loss is realized. Disclosure With respect to disclosure requirements, PS4210 and Section 4410 each indicate that Institutions must disclose the following with respect to contributions: (a) the policy followed in accounting for restricted contributions; and (b) the Institution’s contributions by major source (restricted and non-restricted). Institutions must also disclose the policy followed in accounting for contributed materials and services, and the nature and amount of any contributed materials and services recognized in the financial statements. Contributions CAUBO/ACPAU Page 8 of 12 March 2012 Institutions following the deferral method of accounting for contributions must disclose the nature and amount of changes in deferred contributions balances for the period. Institutions following the restricted fund method of accounting for contributions must disclose the nature and amount of changes in deferred contributions balances for the period, if restricted contributions were recognized in the general fund. Accounting Treatment under PSA (Without the 4200 Series) As noted above, PSA (without the 4200 series) does not have specific guidance with respect to the accounting of contributions other than contributions received from governments. Currently, there is significant debate as to the appropriate accounting treatment for contributions under public sector accounting standards. A definitive consensus has not been developed by practitioners across the country at this time. While Sections PS 3100, Restricted Assets and Revenues, and PS3410, Government Transfers provide guidance which can be considered when accounting for contributions, these sections do not specifically address the unique nature of contributions received by Institutions. In this section, a description of the available accounting treatments using these existing PSA standards is provided. Section PS 3100, Restricted Assets and Revenues, and Section PS3410, Government Transfers each provide ways to account for contributions under PSA depending on the nature of the contribution. Discussion on each of these methods of accounting is provided below. Contributions from non-government entities Section PS3100 establishes standards on how to account for and report restricted revenues such as contributions received from individuals, foundations or corporations in an Institution’s financial statements. Contributions which are not restricted would be recognized by Institutions as revenue in the Statement of Operations in the period received. PS3100 defines external restrictions as “…stipulations imposed by an agreement with an external party, or through legislation of another government, that specify the purpose or purposes for which resources are to be used. “ Externally restricted contributions would be recognized by Institutions as revenue in the Statement of Operations in the period that the resources are used for the purpose or purposes specified. Prior to recognition as revenue, the contribution would be reported as a liability by the Institution. Contributions from governments Section PS3410, Government Transfers, which applies to fiscal periods beginning on or after April 1, 2012 specifies the accounting for Institutions for the transfer of monetary assets or tangible capital assets from a government for which the government making the transfer does not receive anything in return, expect to be repaid, or expect a return. Grants received by Institutions from governments for general operations, or restricted purposes such as research would be included within the definition of a Government Transfer for purposes of application of PS3410. Contributions CAUBO/ACPAU Page 9 of 12 March 2012 PS3410 establishes recognition criteria to be applied by Institutions based upon the terms of the transfer, with specific consideration given to the authorization of the transfer by the transferor government, and eligibility criteria and stipulations attached to the transfer. PS3410.08 distinguishes between these two terms: “Eligibility criteria describe who a recipient must be or what it must do in order to be able to get a government transfer. Stipulations describe how a recipient must use transferred resources or the actions it must perform in order to keep the transfer.” Irrespective of whether a transfer is for operating or capital purposes, revenue would be recognized in the period the transfer is authorized and eligibility criteria, if any, have been met by an Institution, except when and to the extent that the transfer is considered to give rise to a liability through transferor-imposed stipulations. Institutions must carefully examine the nature of any restrictions placed on contributions received through government transfers, to fully assess the economic substance of the transfer. Institutions must apply significant professional judgment in assessing whether the stipulations associated with a transfer, taken together with their actions and communications before the financial statement date, create a liability. Transfers which are deferred by Institutions under PS3410 must be demonstrated to give rise to a liability through transferor-imposed stipulations. PSAB is not prescriptive in PS3410 in specifying when a liability would arise for a recipient so the liability definition in PS3200 should be used. By including in PS3410 the consideration of the recipient’s actions and communications in evaluating whether there is evidence that an obligation exists, PSAB is allowing the application of professional judgment in applying PS3200. Essentially, the new standard acknowledges that in certain circumstances, stipulations set out in transfer agreements may not be explicit enough on their own to create a liability and hence recipient actions and communications need to be considered in determining whether a liability exists. PS3200, Liabilities, defines the essential characteristics of a liability as follows in PS3200.05: “Liabilities are present obligations of a government to others arising from past transactions or events, the settlement of which is expected to result in the future sacrifice of economic benefits. Liabilities have three essential characteristics: (a) they embody a duty or responsibility to others, leaving a government little or no discretion to avoid settlement of the obligation; (b) the duty or responsibility to others entails settlement by future transfer or use of assets, provision of goods or services, or other form of economic settlement at a specified or determinable date, on occurrence of a specified event, or on demand; and (c) the transactions or events obligating the government have already occurred.” Where a liability is determined to exist, revenue is recognized when, and in proportion to how, the liability is settled by the Institution through the use of the funds. While PS3200 does provide additional guidance on an entity’s loss of discretion (characteristic (a) above), it does not specifically address how the nature and type of stipulations inherent in government transfer agreements may impact revenue recognition and also when a stipulation would give rise to an obligation that meets the definition of a liability. Therefore, professional judgment is required to interpret the standards and it is encouraged that all Institutions discuss treatment of government contributions with their auditors for their individual circumstances. Contributions CAUBO/ACPAU Page 10 of 12 March 2012 Investment income For Institutions adopting the Public Sector Accounting standards alone without the 4200 series, the Public Sector Accounting standards must be adopted in their entirety as an Institution’s basis of accounting. Institutions adopting the Public Sector Accounting standards alone may not adhere to select standards within the 4200 series. Consequently, under PSA without 4200, fund accounting for contributions as under PS4210 is not allowed. However, Section PS 3100, Restricted Assets and Revenues deals with external restrictions or stipulations imposed by an agreement with an external party. This section would be applicable when analyzing the accounting treatment for investment income on restricted contributions. If no external restrictions are placed on the net investment income (defined to include revenue, and realized gains or losses on investments), the net investment income would be recognized in the Statement of Operations in the period earned. If external restrictions are placed on the net investment income such as in circumstances where they have been restricted to be spent by the Institution only on certain activities, these realized net investment income amounts would be recorded as a restricted asset on the Statement of Financial Position. In both cases above, all unrealized net investment income earned on the contributions, such as fair value changes on investments, would be recorded in the Statement of Remeasurement Gains and Losses until such time that the related investments are disposed of, or a write-down for permanent impairment is required. PS3410, Government Transfers, does not specifically address accounting for net investment income on transfers received. These agreements may put stipulations on the use of the net investment income earned on a transfer (e.g. for the funded project) while other agreements may not put any stipulations on the use of the net investment income. Where agreements do put stipulations on the use of the net investment income, Institutions would be required to account for net investment income on a consistent basis with the imposed stipulations. Where agreements do not put stipulations on the use of the net investment income, it would be recognized as revenue as earned. Disclosures PS3100, Restricted Assets and Revenues, requires an Institution to disclose in the notes or schedules to their financial statements: (a) a general description of the nature and source of any external restrictions; (b) the amounts of externally restricted inflows by major source; (c) the amount of, and changes in, the deferred revenue balance attributable to each major category of external restrictions; and (d) any externally restricted assets that are segregated, including an explanation of the relationship of those assets to the related liability. PS3410, Government Transfers requires an Institution to disclose all major kinds of government transfers recognized in the accounting period. An Institution’s financial statements should also disclose information about the nature and terms of liabilities, if any, arising from government transfers received. Contributions CAUBO/ACPAU Page 11 of 12 March 2012 Transitional Provisions PS4210 and Section 4410 For Institutions who are government not-for-profit organizations (GNPO) and reporting under the Public Sector Accounting standards with the 4200 series, and for Institutions following Part III of the CICA Handbook – Accounting Standards for Not for Profit Organizations, no transitional provisions need to be considered as PS4210 and Section 4410 in Part III are both identical to the accounting standards currently followed by Institutions using preexisting GAAP. PSA Standards For Institutions adopting the Canadian Public Sector Accounting standards without the 4200 series, the transitional provisions will depend largely on the conclusions reached on the treatment of accounting for contributions discussed above. Institutions have the option of applying PS3410, Government Transfers, on a retroactive or prospective basis upon transition for the fiscal year beginning on or after April 1, 2012. If an Institution chooses to apply PS3410 on a retroactive basis, it would be required to review any government transfers deferred at the date of transition, and verify if the deferred amounts represent liabilities based upon transferor imposed stipulations considering the characteristics specified in PS3200, Liabilities. If the deferred amount is determined to not represent a liability, it would be reversed by the Institution, and adjusted through the opening accumulated surplus or deficit of the Institution upon transition. If an Institution chooses to apply PS3410 on a prospective basis, it would still be required to review any government transfer agreements effective at the date of transition, which are to remain in place going forward as the Institution reports under the PSA standards. As with retroactive application, the Institution would need to verify if any deferred amounts in relation to these agreements represent liabilities based upon transferor imposed stipulations considering the characteristics specified in PS3200, Liabilities. If the deferred amount is determined to not represent a liability, it would be reversed by the Institution, and adjusted through the opening accumulated surplus or deficit of the Institution upon transition. Contributions CAUBO/ACPAU Page 12 of 12 March 2012