When the new revenue recognition standard came out, Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), it specifically excluded contribution revenue and investment returns. It appeared there would be little effect on many not-for-profit organizations. However, ASU 2014-09 resulted in renewed focus on certain revenue streams of NFPs, particularly U.S. Federal funding. In response, the Financial Accounting Standards Board (FASB) issued updated guidance in June 2018, Accounting Standards Update No. 2018-08, Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made. ASU 2018-08 reiterated existing U.S. GAAP for grants and contributions, and it added clarifying examples and definitions to reduce subjectivity in how and when revenue was recognized.
ASU 2018-08 is effective for many recipient organizations (grantees) in 2019 and applies to many resource providers (grantors) in 2020. What should you expect, whether you’re receiving contributions or making them? Following is a summary of the key aspects of ASU 2018-08, its implications, and tips on implementation.
ASU 2018-08 uses three basic steps to determine how and when revenue (and expense) is recognized:
1. Is commensurate value received in exchange for the resources provided?
If commensurate value is received by the resource provider, the transaction is typically an exchange transaction. In other words, the funder receives a direct benefit of roughly equal value to the resources it provides. In this case, the transaction is accounted for under ASU 2014-09, Revenue from Contracts with Customers. On the other hand, if the value the donor receives is incidental or indirect, and the true value of the funding is realized through benefit to others or society, the transaction is non-reciprocal, i.e., a grant or a contribution. Non-reciprocal transactions are accounted for under ASU 2018-08, Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made, and the evaluation continues in Step 2.
2. If the transaction is non-reciprocal, are conditions present?
Grants and contributions can include conditions that must be met for the NFP to either retain the funds it has received or be entitled to collect funds from the donor. When conditions are present, revenue is recognized only when the conditions are satisfied. In the past when an agreement included conditions, the recipient could apply a probability assessment to determine the likelihood of whether it would satisfy the conditions. If the chance of not satisfying the conditions was remote, the NFP could recognize revenue at the time the contribution was made. ASU 2018-08 removes that subjectivity by defining conditions more clearly. A condition must have both aspects: a performance barrier that must be overcome for the recipient to be entitled to the funding; and either a right of return of assets transferred or a right of release of a promisor’s obligation to transfer assets. Barriers are typically program focused. Administrative requirements, such as grantees providing annual informational reports, and in many cases budgets, are not considered conditions.
3. If the transaction is non-reciprocal, (i.e., a grant or contribution) has the donor placed restrictions on the contribution?
Once grant or contribution revenue is recognized, the recipient must determine whether the contribution is restricted based on how broad or narrow the purpose of the agreement is, and whether the resources are available for use only after a specified date. If the revenue is restricted, it is released from restriction when the funds are used for their intended purpose.
What are the Implications Observed to Date?
U.S. Federal Funding
Much of the U.S. Federal funding received by NFPs is now considered conditional grants versus “earned revenue.” In the past, many organizations considered their Federal funding to be earned revenue and recognized revenue as qualifying expenses were incurred. However, the FASB has clarified that the Federal government does not generally receive a direct benefit from the funding it provides, rather society is the true beneficiary. Therefore, much Federal funding is non-reciprocal. Since recipient organizations must satisfy conditions by complying with a variety of Federally imposed requirements and incurring qualifying expenses before being entitled to the funds, the timing of revenue recognition may not change significantly from past practices. In addition, there are still certain types of Federal funding that constitute exchange transactions, such as the government procuring goods and services or making third-party payments on behalf of an individual. Therefore, organizations receiving U.S. Federal funding will need to examine, and perhaps update, their revenue recognition policies to reflect the criteria included in ASU 2018-08.
Timing of Revenue Recognition
The specificity of what constitutes a condition is resulting in changes to the timing of revenue recognition, depending on organizations’ past policies. Some organizations that applied the probability approach and recognized revenue immediately because it was likely the organization would satisfy the conditions no longer have that subjectivity. Therefore, if grants include conditions as defined above (both factors present), revenue recognition is delayed until the conditions have been satisfied. Alternatively, grant agreements that contain terms which were considered conditions in the past may not be conditional now if they don’t include both the performance barrier and the right of return; thus, revenue may be recognized sooner than it had in the past.
Effects on Grantors
ASU 2018-08 applies to both contributions received and made. Grantors must apply the same criteria in Steps 1 and 2 above to determine the appropriate timing of expense recognition for U.S. GAAP financial reporting. Therefore, if donors award grants containing conditions as defined in ASU 2018-08, they will recognize the expense only as the conditions are satisfied, regardless of whether the grant has been funded or not. The FASB clarified there is not an expectation for donors to coordinate with grantees to match revenue and expense recognition; however, both entities should apply the concepts of ASU 2018-08.
Tips on Implementation
ASU 2018-08 is already applicable to many organizations in 2019. If your organization hasn’t already established a well-defined approach for implementation, consider the following:
- Read ASU 2018-08 whether you are a resource recipient or provider. It can be found here. The ASU incudes many helpful examples and clarifications.
- Consider whether your revenue and expense policies need to be updated to reflect the updates and clarifications of ASU 2018-08.
- Remember that if your organization both receives grants and contributions, and passes funds through to other organizations, it is both a resource recipient and resource provider. ASU 2018-08 applies to both revenue and expense recognition. Although the effective date for resource providers is one year later than for resource recipients, organizations may early adopt the ASU to coordinate expense recognition with revenue recognition.
- Review current and new funding agreements and apply the three step process above. Search the terms of the agreements for conditions as measured by the clarified definition of ASU 2018-08.
- If your organization receives funding from a variety of sources, categorize it by type, such as Federal, Private/Corporate, and Foundations. Determine the underlying characteristics of each category and the general appropriate revenue recognition for each. Establish a threshold over which every award will be reviewed in detail for variations from the norm. While classifications are helpful and expedient in applying revenue recognition, there are bound to be exceptions that need to be evaluated for appropriate treatment.
- If you are a grantor, review the terms of your organization’s grant agreements to determine if the agreements include conditions that may delay recognizing grant expense under U.S. GAAP. Conversely, ensure intended conditions include both required elements described above. Modify the language in your grant agreements, if necessary. Ensure that the language in your grant agreements reflects your organization’s actual intentions.
- Attend one of the Clark Nuber seminars on ASU 2018-08.
Public business entities or NFPs that have issued, or are conduit bond obligors for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market: periods beginning after June 15, 2018. All other entities, periods beginning after December 31, 2018.
Resource providers (grantors)
Public business entities or NFPs that have issued, or are conduit bond obligors for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market: periods beginning after December 15, 2018. All other entities, periods beginning after December 31, 2019.
The amendments in ASU 2018-08 should be applied on a modified prospective basis. Retrospective application is permitted but not required.
If you have questions regarding the implementation of ASU 2014-09, contact your Clark Nuber advisor.
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