Whether you use the IRS rate as your reimbursable amount or some other rate, here are some suggestions to manage these reimbursements:

1. Review the policies at least annually.
2. Ask staff how they interpret these policies, and address any ambiguities.
3. Usually organizations only reimburse employees for mileage in excess of the miles that would be driven to the place of employment. For example, a case worker drives directly to a client’s house, which is 10 miles from the employee’s house. Your office is 6 miles from the employee’s house. Typically, you would only reimburse the employee for 4 miles of travel.
4. As part of the hiring process, inform new staff of the organization’s policies and give examples of what is allowed and what is not.
5. Periodically review these policies at staff meetings.
6. Employees should keep a written log of the mileage, which should include at a minimum for each trip:  Date of travel, destination, purpose of trip, and miles driven.  If you receive federal or state grants, the granting agency may require you to keep more detailed records, such as odometer readings, address of the destination, or attach maps showing mileage.
7. Prior to reimbursement, the mileage logs should be approved by the employees’ supervisors who are knowledgeable of their activities. The logs should also be periodically reviewed for inconsistencies, errors, redundant trips, and abuse.

     What are you required to do? According to OMB Circular A-133 (which governs the administration of federal awards), organizations are required to:
“Maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.”
       To ensure that you have the proper controls in place, it is a good idea to perform an assessment of each of the compliance requirements that affect your federal grants. Here are a few questions you can ask yourself and others involved with the administration of the grant:
     “How do we know that case managers who are carrying out the program are fully informed of the provisions of the grant?”
     “What process do we have that would prevent an unallowable cost from being charged to the grant?
     “How do we know that participants in the program are eligible to receive services? Does anyone verify eligibility after the initial assessment?”
     “How do we make certain that we have paid for allowable costs before we request reimbursement from the grantor?”
     “How do we communicate changes involving the grant to those personnel who need to know?”
     “Do we routinely check the “Excluded Parties Listing System” to ensure that we are not doing business with any vendors that have been suspended or debarred?”
     “What process do we have in place to make sure that all reports were filed accurately and timely?”

     After doing this assessment, you may find that your internal controls need to be strengthened. If you need assistance with this, please give us a call.

It can be a daunting task to get individuals to engage in making changes to the processes and controls already in place at their organization but when they are educated on how important the controls really are they may be more willing to with stain from their resistance to change.

The 2008 report to the Nation on Occupational Fraud and Abuse estimated that US organizations lose 7% of their annual revenues to fraud which translates to approximately $994 billion in fraud losses. Losses were noted to be significantly lower in the cases where the organization had implemented controls. Small businesses were noted to be especially vulnerable to occupational fraud. The median loss suffered by organizations with fewer than 100 employees was $200,000 which is higher than the median loss in any other category, including the largest organizations. Lack of adequate internal controls was most commonly cited as the factor that allowed fraud to occur.  To read more on this report go to http://www.acfe.com/resources/publications.asp?copy=rttn

One of the key parts of the ‘self-test’ reads as follows: “Internal control is a process designed to…achieve effectiveness and efficiency of operations, reliability of financial reporting and compliance with applicable laws and regulations.” What organization doesn’t want to process transactions more efficiently, have accurate financial statements to their stakeholders or ensure they are in compliance with applicable laws and regulations? Properly designed internal controls can lead an organization in the right direction.

I have found the following to be a handful of a few good controls (this is not intended to be a list of the minimum controls an organization should have; simply it is a few of the controls that I think are very important):

1. Do not underestimate the power of “Tone at the Top” – if management skirts issues under the table their subordinates will assume they can do the same. This includes maintaining an oversight body (Board of Directors, etc) that has intimate knowledge of how the company operates and understands how to read and process financial information
2. Implement “Big Brother” approaches – people are less likely to stray from doing the right thing if they know someone is out there watching over their actions

Another step I highly recommend is to gain an in depth understanding of your company’s processes and procedures and see where the weaknesses are; then develop internal controls to address the identified risks.

To take the brief test to determine your level of understanding of internal controls go here:  http://www.journalofaccountancy.com/Issues/2010/Mar/20092240.htm

1. Determine if employee deferrals comply with current regulations (See limitations at: http://www.irs.gov/retirement/sponsor/article/0,,id=151925,00.html)
2. Determine if employee deferrals comply with the Plan’s maximum percentage requirements, if applicable (controls should be in place to ensure that employees are not allowed to elect to contribute more than the Plan’s elected maximum percentage as indicated in the Plan Document)
3. Controls should be in place to ensure that contributions are submitted to the Plan in a timely basis (Determine the who and the when to make sure it happens as required by law). Key – Timing should not be in excess of the number of days it takes an employer to transmit payroll taxes
4. Knowledgeable personnel should review and approve all loans and distributions made from the Plan . This knowledgeable person has read and fully understands the Plan document and requirements contained therein.
5. For loan approval – Understand the plan requirements for the following: loan amount complies; interest rate in loan agreement complies; condition for loan.
6. For distributions – Understand the following:  distribution complies with plan provisions and ensure all necessary documentation is retained (specifically for hardship distributions); distribution request includes the appropriate amount and the accurate amount of withheld taxes (10% and possibly an additional 20% if early distribution); ensure the appropriate vested percentage is utilized for employer contributions; determine if distributions required by law (required minimum distributions, etc) were completed during the year.

I hope the information is helpful in establishing a sound control environment for your organization’s employee benefit plan.  If there are areas that I have missed feel free to leave a comment to help out the other readers.  The controls that I have listed are coming from an auditor’s point of view and you may have insights related to your field of expertise that could be beneficial to others!

So what can churches do to weather this environment? Here’s a few suggestions:

1. Don’t abandon your mission, and certainly don’t abandon your message. Despite this economy, I believe (and have seen) that people still want to give generously to causes they are passionate about. The problem caused by the economy is that more nonprofit organizations are providing more services to more people in need with less available funding. That’s why it’s so important to trumpet a compelling vision to your contributors. There are simply more options for donors to consider, and with limited resources, they give to causes they are the most passionate about.
2. Communicate, communicate, communicate. Churches (and lots of other organizations) make the mistake of not wanting to communicate negative financial trends and results. But if you don’t communicate, how will your contributors know there’s a need? Many churches also make the mistake of talking about money only when the numbers are down. Generosity is ultimately a spiritual issue not a financial one, and that message is lost if you only talk about money in a bad economy.
3. Rethink budgets. Churches are generally very slow to make difficult decisions about (i.e. cutting) budgets, minstries, and staff. The line between faith and stewardship is often very faint, but in a giving environment like we’re experiencing now, churches must consider the efficiency of their ministries. When giving is up year after year after year, churches often add a little more “flair” to ministries than is really needed and let certain ministries linger on a little longer than they should. Spend some time thinking strategically about your ministries in light of your mission and your investment in those ministries, and you might be surprised what you find.

The economy we’ve been dealt presents its share of challenges for churches and ministries, but there are opportunities to impact the quality and direction of your ministries. And who knows – you might even find youself in the 9% next year.

If we can be of any help or answer any questions as you wrestle through these issues, please don’t hesitate to call me.

10. Begin working on your schedules weeks before the audit occurs, you might have questions and your auditor is just a phone call or email away.
9. Keep track of issues you struggled with during the year. It will help the auditor key in on important areas at the beginning of the audit.
8. Get the confirmations back to the auditors quickly! The more time there is to send these out the better chance the auditor receives the accurate information. Not getting them back causes more work for all parties involved.
7. Communicate your schedule to the auditors. This helps the auditor work around your normal responsibilities.
6. Make all your adjustments to your trial balance before you provide it to the auditor.
5. Those schedules we talked about earlier make sure they tie to that final trial balance.
4. Make needed documentation easy to access and provide it to the auditors as soon as possible.
3. Be available! Here’s a tip, set aside time on your calendar devoted to auditor questions and audit prepwork.
2. Implement good segregation of duties among your staff. The more checks & balances you have the less likely you are to have errors or issues.
1. Don’t do anything fraudulent or misleading during the year. (Always a plus). Tell the truth.

The key to success is communication and preparedness. If you apply these steps you should see a reduction in the amount of friction an audit can cause.

According to the organizations that responded to the survey, 60% are having difficulty managing cash flow, 30% have no lines of credit, and 67% have no endowment. Of the organizations that responded that had endowments, 73% saw decreases in their endowment. 53% of these organizations were forced to cut staff in order to cut costs. Some of these organizations have had to cut programs and those that have not are considering this option to cut costs.

While these statistics were gathered from organizations in the New York City metropoliation area, the current economic crisis is putting a great deal of strain on human service organizations around the country that rely a great deal on public funding.

The information above was summarized from the article “Governments Cutting Back on Social Service Spending” from NPT Weekly, a publication of The NonProfit Times. For more information, see www.nptimes.com. 

Generally, a required minimum distributions is an annual amount that must be withdrawn from an IRA or an employer sponsored plan beginning with the year the account owner reaches 70 ½.

The IRS said that in many cases, because the law was signed so late in the year, and many individuals and plan sponsors were confused about how to comply with the new rules, IRA owners and plan participants received distributions they were not required to take or did not want.

Retirees who made a withdrawal from an IRA, 401(k) or other qualifying retirement plan have until 11/30/09, or within 60 days of the distribution, whichever is later) to put the money back in the plan tax-free.

Notice 2009-82 assures plan administrators that a plan will not be treated as failing to satisfy the requirement that it be operated in accordance with its terms merely because, during the period 1/1/09 to 11/30/09 it:

1. Did (or did not) make required minimum distributions to participants
2. Did (or did not) give beneficiaries the option to receive required minimum distributions
3. Did (or did not) offer a direct rollover option for required minimum distributions

 FYI – the IRS has NOT suspended the one-rollover-per-year rule of IRC Section 408(d)(3) and no more than one IRA distribution will be eligible for rollover under Notice 2009-82.

Before you start, I wanted to let you know about a common misconception that the total revenues have to equal total expenses on the budget. This is not true. You can budget for a surplus or a deficit. “But I’m a non-profit”, you say. Well it’s not a requirement of a tax-exempt nonprofit to end up with no money at the end of the year. The requirement is that any surpluses you do finish the year with, don’t go to stockholders or owners, the surpluses stay within the organization to continue its mission.

The flip side is actually budgeting a deficit – which is more of a reality even as our economy starts to show small signs of revival.  Sometimes, it’s just not realistic to balance a budget.  However, I would not come to this conclusion lightly, and I would involve the Board and Finance Committee from the beginning when determining when/how/and more importantly why. Obviously, budgeting a deficit should be a rare occurrence in your organization and everyone needs to be on the same page, specifically how it affects the future of the organizaiton. Hopefully, it’s not a situation that you have to repeat.

The underlying theme here, is that a budget should be a tool to plan financial performance and evaluate results. Don’t have a balanced budget when you realistically should surplus $500,000. Your organization will tend to gravitate to low expectation. Conversely, if you have a balanced budget, and the best your group can hope for in the current environment is a $100,000 deficit, then you’re setting everyone up for failure – and possibly some rash decisions as a result of failure. Each of these scenarios also makes it difficult to evaluate performance and management because the goal was not properly set. You want to accurately define success with your budget, and then during the year be able to monitor performance against that definition.

Keep this in mind during the current process.  It might be best to get a bottom line number approved by the Board before starting.  Make sure your budgets reflect a realistic goal that will define success for your organization. You and your organization will be better off for it.

IFRS for SMEs applies to private companies or those that do have public accountability (i.e. companies that file, or are in the process of filing, with a securities commission or other regulatory organization for the purpose of issuing any class of instruments in a public market; or it holds assets in a fiduciary capacity for a broad group of outsiders such as banks, insurance companies, brokers and dealers in securities, pension and mutual funds).

For private companies that are owned by a foreign parent, have a significant foreign investor, supplier or venture partner, IFRS for SMEs is an alternative to the more complicated and voluminous US GAAP.  For such companies using a consistent global financial accounting and reporting standard will increase comparability and improve efficiencies of conducting business with their foreign counterpart.

The key differences in IFRS versus US GAAP:

• Disclosures are simplified in a number of areas including pensions, leases and financial instruments
• LIFO is prohibited
• Goodwill and indefinite life intangible assets are amortized over a period not exceeding ten years
• Depreciation is based on a components approach
• A simplified temporary difference approach to income tax accounting
• Reversal of impairment charges, if certain criteria are met, is allowed
• Accounting for financial assets and liabilities makes greater use of cost

 Key challenges if your company decides to use IFRS for SMEs:

• Understanding the differences between IFRS for SMEs and US GAAP
• The willingness of financial statement users to accept financial statements prepared under IFRS for SMEs
• Working with and accepting a more principles-based set of accounting standards compared to the more rules-based US GAAP
• The impact on taxes and tax planning strategies
• The impact on financial reporting metrics

 The final IFRS for SMEs can be obtained free, after registering, from the IASB website: http://www.iasb.org/IFRS+for+SMEs/IFRS+for+SMEs.htm

 Additional information about IFRS for SMEs and about activities of IASB can be found at www.ifrs.com