IRS Announces First Round of Revocations for Nonprofits that Failed to File Form 990

The IRS is conducting the biggest crack-down on nonprofits in my memory.  I believe part of this is an attempt to make up sluggish revenues due to our recession.  The implication for nonprofits is great and the burden falls greater on small nonprofits.  Think garden club or the local Kiwanis Club.  Those with revenues below $25,000 per year are now required to file a 990 (pick the form).

According to Nonprofit Times, "In 2008, nonprofits known as “nonprofit institutions serving households,” a broad subset of the sector, generated 5.2 percent of U.S. GDP, representing $751.2 billion worth of output. Nonprofits’ share of GDP grew 0.4 percentage points from 1998 to 2008."

As a friend pointed out the other day, nonprofits are domestic because most work to benefit their local communities.  That means nonprofits typically are not shipping jobs off shore, but instead keeping them local, very local.

I get it...we need revenue, but cracking down on the small nonprofits may not be exactly the most efficient way to get there.  Thanks to the folks at Venable for another great article on trends in the nonprofit sector.  Bunnie

Audra J. Heagney

Kristalyn J. Loson

 

IRS Announces First Round of Revocations for Nonprofits that Failed to File Form 990 

by Audra J. Heagney and Kristalyn J. Loson 

On June 10, 2011, the Internal Revenue Service ("IRS") released the complete list of approximately 275,000 nonprofit organizations that have lost their tax-exempt status for failure to file Form 990, Form 990-N, Form 990-EZ, or Form 990-PF for three consecutive years. The list of revoked entities is available on the IRS website.

The list includes the organization’s name, Employer Identification Number, last known address, and effective date of revocation of exempt status; it will be updated monthly. In its announcement, the IRS indicated that it believes most of these organizations are likely defunct, however, it has issued guidance regarding the steps such organizations must take to apply for reinstatement of their tax-exempt status.

This is the first group of revocations resulting from the passage and implementation of the Federal Pension Protection Act (the "Act"), passed by Congress in 2006. The Act mandated annual filing requirements for virtually all tax-exempt organizations, including tax-exempt organizations with gross receipts of $25,000 or less that were not previously required to file an annual return with the IRS. The Act also provided for the automatic revocation of any tax-exempt organization that does not file the required returns or notices for three consecutive years, and requires the IRS to publish and maintain a list of all such organizations that are so revoked.

In conjunction with its recent publication of the names of the first wave of organizations with revoked tax-exempt status, the IRS also issued guidance regarding the impact that the revocations have on charitable contributions to revoked organizations, and the manner in which organizations may seek reinstatement of tax-exempt status, including retroactive reinstatement. The IRS also announced transition relief for certain small tax-exempt organizations.

In connection with the announcement and publication of revocations of exempt status, the IRS issued the following guidance:

Revenue Procedure 2011-33 (Contributions to Revoked Organizations) states that where an organization listed in Publication 78 ceases to qualify as an organization to which contributions are deductible under Section 170 of the Internal Revenue Code (the “Code”), as a result of loss of exempt status due to failure to file annual reports for three consecutive years, grants and contributions made to the organization by persons unaware of the change in the status of the organization generally will be considered allowable if made on or before the date of publication of the list of revoked organizations. The IRS may disallow a deduction for any contribution made after revocation of exempt status but prior to the published notice of the revocation where the grantor had knowledge of the revocation prior to publication, was aware that revocation was imminent, or was, in part, responsible for the revocation. Publication on the list of organizations whose tax-exempt status has been revoked is intended to serve as a notice to donors and others that they may no longer rely on a prior listing in Publication 78.

Revenue Procedure 2011-36 (Reduced Fee for Reinstatement) reduces to $100 the user fee charged for the reinstatement of exempt status of small exempt organizations that normally have annual gross receipts of not more than $50,000 whose exemption was automatically revoked pursuant to Code Section 6033(j).

Notice 2011-43 (Transitional Relief) provides transitional relief for small organizations that had their exempt status revoked because they failed to file a required annual electronic notice for the last three consecutive years. An organization with annual gross receipts of less than $50,000 that qualifies for transitional relief pursuant to the criteria set forth in this Notice, and applies for reinstatement of exempt status by December 31, 2012, will be treated as having established reasonable cause for failure to file annual returns and exempt status will be reinstated retroactive to the date it was revoked.

Notice 2011-44 (Process for Reinstatement) sets forth the steps that an organization must take to apply for reinstatement of exempt status and request retroactive reinstatement after an organization's tax-exempt status was automatically revoked under Code Section 6033(j). An organization must use the same form filed by other applications for recognition of tax exemption to seek reinstatement, and must pay the applicable user fee. If an organization is seeking retroactive reinstatement, it must submit information demonstrating reasonable cause for failure to file an annual report, among other supporting materials.

The Treasury Department and the IRS intend to issue regulations under Section 6033(j) of the Internal Revenue Code, implementing rules regarding the application for reinstatement of tax-exempt status and the request for retroactive reinstatement. Comments are currently being solicited on the materials and issues addressed in Notice 2011-44. Comments are due August 19, 2011. 

You can contact the folks at Venable, LLP at http://www.venable.com.

Preparing for Stricter 990 Filing Requirements

For those of us here in the U.S., it's tax time!  Tax time causes a certain amount of angst, whether it's business, personal or nonprofit filings.  But new rules at the Internal Revenue Service regarding small nonprofits will potentially derail nonprofit efforts.  Whether it's the local Kiwanis Club or the Boy Scout troop, leadership and board members need to know the new rules regarding fundraising and reporting.  Lynne Leavitt lays out what you need to know simply and easily.  In my own experience, I have found the IRS fairly helpful and easy to work with as long as you are straightforward and honest.  It's okay to tell an IRS agent that you don't know the rules or how to do something.  Really, if you have a question, pick up the phone and call.  Bunnie


Preparing for Stricter 990 Filing Requirements

by Lynne Leavitt, CPA with Brakensiek Leavitt Pleger LLP

From neighborhood baseball leagues to local senior centers, thousands of small nonprofits across the country are at risk for stiff penalties or even loss of their federal tax-exempt status. 

Such organizations may not be aware of the recent IRS changes that are responsible for this situation. 

A critical redesign of the IRS form known as the 990 now requires nonprofits to reexamine their tax reporting procedures to make certain that anyone filing forms on the organization's behalf is aware of the new tax provisions.

The new 990 filing requirements went into effect at the beginning of 2008 for tax-exempt organizations with gross revenues of $1 million or more. 

A 990-EZ, or short form, was required of all other nonprofits with revenues over $25,000. 

A progressive lowering of the gross revenue threshold over the past three years has caused significant concern among nonprofit personnel and their financial advisors. 

In 2009, the threshold for filing the new 990 long form dropped to $500,000 in nonprofit gross revenues. In 2010, the 990 form is required from nonprofits earning $200,000 or more. 

Fees for simply preparing the revised 990 form can easily reach $6,000, a cost that could represent a significant expense to a small nonprofit. 

The 990-EZ form, which costs substantially less and saves a considerable amount of time, can only be used by nonprofits under the standard form 990 gross income threshold. Nonprofits with gross revenues under $25,000 are required to file an electronic Form 990-N (e-Postcard) online. 

On July 26, 2010 the IRS announced that it is providing a one-time relief for organizations grossing less than $1 million that have tax filing dates before October 15, 2010 and that have failed to correctly file in the past three years, allowing them to retain their tax-exempt status.  

This one-time exemption only applies to organizations required to file Form 990-N and Form 990-EZ.
Adding to the challenges now faced by nonprofits, the IRS has hired an additional 100 tax examiners whose job is to audit nonprofit returns in order to ensure compliance with the new requirements. 

Clearly, the IRS is not taking the new filing requirements lightly - it has already revoked the tax-exempt status of many nonprofits for non-compliance. When such organizations lose their tax-exempt status, they must shoulder the time and expenses of reapplying. 

In the interim, any income earned during that process could be taxed, and donations to the group would not be tax deductible to the donor.

The IRS rationale for imposing these strict new requirements on nonprofits is simple: Past abuses, such as inflated salaries and unsound conflicts-of-interest have raised public concern over governance of these organizations. 

On the other hand, a nonprofit with gross revenues under $500,000 may have a volunteer board and the staff may not have the necessary expertise to keep up with esoteric tax-filing requirements, and their accountants may not possess the necessary skills and expertise required. 

The new Form 990 is designed to promote transparency and disclosure, thus making the nonprofit's operations open to public scrutiny. 

The questions posed are extremely detailed, and will require organizations to draft new disclosure policies and procedures in order to meet filing requirements.

For most nonprofits, the key to staying in compliance and retaining the trust of watchful donors is to become familiar with IRS requirements and to take appropriate measures to ensure that IRS filings are as accurate and detailed as possible. 

This may mean seeking out a tax accounting firm with extensive nonprofit experience.  In view of the implications for nonprofits who fail to meet the IRS expectations, such action may be the best investment that organizations could make.

Lynne Leavitt, CPA with Brakensiek Leavitt Pleger LLP, has more than 25 years of accounting and tax knowledge with extensive experience assisting nonprofit organizations with all of their financial-service needs.

Want to Avoid Fraud? Look to Your Board

While we would like to think that fraud doesn't happen as often in the nonprofit community as in the business community, it simply is not true.  I still remember the story of the national religious organization whose Treasurer walked off (for a period of time) with $2 million dollars.  While speaking to someone who knew the story I asked "How could that have happened?"  The response was that the Treasurer had buried the Board in paperwork, creating confusion and a subterfuge to mask her thievery.

In my own experience, I caught an attempt at fraud by an employee who had given her resignation.  She had lifted at least one check and might have cashed it had I not discovered the check was missing.  Could she have done major damage?  Not really, but it was a lesson for me to do better at checking potential employees' backgrounds.  Seems she had done the same thing on more than one occasion at her previous job.  The following article by Dr. Eugene Fram and Dr. Bruce Oliver provides excellent advice on what you need to do in order to protect your nonprofit against fraud.  Enjoy!  Bunnie

Want to Avoid Fraud? Look to Your Board:

Dr. Eugene Fram


Here’s a guide board members can use to keep fraud away from your door.
By Eugene H. Fram & Bruce L. Oliver

The board of the Association for Underprivileged Children is meeting in the aftermath of a dreadful situation. The police report summarizes what happened:

Over $50,000 designated for camping scholarships for the Association for Underprivileged Children has been stolen. The perpetrators are John Roe, the Association’s chief financial officer and his wife, Nancy, the camp director. The couple pilfered assets over a three year period. Nancy requested camp expenses, such as athletic equipment, for nonexistent campers. John then approved payment to a shell company operated by Nancy. Both are currently thought to be in South America. The organization doesn’t have fraud insurance. Funding for the current camping program is in jeopardy.



Dr. Bruce Oliver

 While the above scenario is fictional, it approximates an alarmingly common occurrence. One estimate, by Harvard University’s Houser Center for Nonprofit Organizations, suggests that fraud losses among U.S. nonprofits are approximately $40 billion a year.

How can nonprofits avoid such traumatic situations? The first step is to make certain that board members have the knowledge necessary to keep fraud at bay. Here are some suggestions for doing just that:

Be sure your board has the following committees:

(1) A finance committee charged with these tasks:

• Review the overall results of a yearly independent audit, conducted by an outside auditor.

• Oversee executive compensation, pension benefits, and other finance activities.

(2) A separate dedicated audit committee containing only independent board members. (Since nonprofit board members aren’t compensated by the organization, all directors are, by definition, independent. However, some directors may have strong social, family, or political links to management personnel. It’s prudent to exclude such people from serving on the audit committee.) The board members on this committee should be reasonably financially competent, with at least one having a strong finance background who is able to overview audit issues in detail. In particular, the committee should do the following:

• Conduct a yearly review of conflict-of-interest policies.
• Make certain that all employees and board members sign a conflict-of- interest statement.
• Assure that new hires are vetted for honesty.
• Meet every four to six months. (In times of organizational emergency or stress, meetings may be required more frequently.)
• Be sure that a certified audit is completed at least every two years – once a year if at all possible.

Hire an external auditing firm

In the past, it was common for managers to select the external auditing firm with “rubber stamp” approval by the board. In today’s more vigilant environment, the board must be more involved. Hiring an auditing firm should be a partnership effort between management and board. The task is as serious as hiring a CEO and should be given the same amount of time and care.

The board audit committee should review the following information when hiring the auditing firm:

• the nonprofit audit experience of those who will be performing the audit
• the history and client list of the auditing firm
• the proportion of the firm’s clients that are nonprofits
• the size of the firm and whether it has the ability to serve a new client well
• the estimated costs for each audit 
• the firm’s suggestion for a financial consulting firm if your organization needs such counseling. (It’s a conflict of interest for an auditing firm to do both auditing and financial consulting.)

Meet with external auditors

When your board’s audit committee meets with the external auditors, the organization’s CFO and other key financial personnel will be present. At some point in each meeting, however, board members need to meet with the auditors in executive session without the CFO, CEO, and other managers. At these private sessions, board members need to ask the auditors, “Do you have anything to tell the board without management present?” This gives auditors a chance to report any concerns that need board consideration, such as unusual travel, entertainment, or other expenses or any transactions that raise red flags. Audit committee members also have an opportunity to raise questions about the professional competence of the organization's internal financial personnel.

Some larger organizations may employ one or more internal auditors. The audit committee should meet with these people several times a year.

Unless specified in the audit agreement, fraud detection is a secondary purpose of the external audit. The main purpose is to assure that information in financial statements is a fair representation of financial activities. However, auditors can -- and often do -- uncover indications of fraud during a routine audit, and it’s their duty to report it.

Develop a conversation with external auditors

In the typical nonprofit, only one or two audit committee members will be able to formulate detailed technical questions for the external auditors. However, to help uncover fraud, every board member should be familiar with six audit- related topics and be able to pose questions about these six topics:

(1) Are internal controls adequate? The organization’s control system needs to be divided into operating functions. Then, each operating function must be performed by someone different so that each person checks the others’ work. For example, a sales associate completes a retail sale, but a sales audit person deposits the cash to the bank account. In addition, all financial people need to take scheduled vacations so that another employee is responsible for the vacationer’s work for at least two consecutive weeks a year. (In the fraud case that begins this article, the transactions between husband and wife shouldn’t have been allowed. At the very least, the transactions should have been reviewed in detail by a qualified independent third party. Proper internal controls would have brought the fraudulent situation to light.)

(2) Are financial records accurate? External auditors must certify that the following records are in proper form: financial statements, management contracts, sales of major assets, bonus payments, and long term lease agreements.

(3) Are activities and expenditures properly authorized? For example, have any extensive changes in plans been approved by the board? Have major expenses been properly budgeted? Have travel costs over a prescribed level been approved by a senior officer? Depending on the size of the organization, do all expenditures over a certain amount require two signatures from senior officers?

(4) Do all reported assets actually exist? This question is especially important to answer if the organization holds any physical assets at a distance from its main offices.

(5) Is the organization performing any activities that might endanger its tax-exempt status? Smaller nonprofits sometimes let licenses or even tax-exempt certificates lapse. It’s vital to certify that such documents are up to date and that taxable income and charitable donations are reported separately.

(6) Is the organization paying its payroll taxes, sales taxes, and license fees on time? Does the organization file its financial reports, like the IRS 990 report, on time? Many fraudulent cases involve failure to report and pay employee withholding taxes.

Trust but verify

Since fraud is such a pervasive cancer in the nonprofit environment, it needs intense board attention. Cases of nonprofit fraud undermine the good work of the organization and the nonprofit sector.

Every board member should know enough about finance to spot suspicious activity when it occurs. Everyone involved in the organization should be alerted to the fact that board members are giving serious attention to the fraud issue. That knowledge, in itself, may deter someone from trying to steal.

Prime Reading for Your Board

Be sure all board members have read the following Nonprofit World articles (available at www.snpo.org/members):

How to Have an Audit without Breaking the Bank (Vol. 20, No. 4)

New Internal Control Guidance (Vol. 28, No. 1)

Nonprofits without Audit Committees Risk Disaster (Vol. 22, No. 2)

Fraud: How to Prevent It in Your Organization (Vol. 26, No. 3)

Make Good Use of the Treasurer and Finance Committee (Vol. 27, No. 2)

Protecting Your Organization against Financial Misuse (Vol. 17, No. 4)

The Audit Committee: Why You Need one, How to Form One (Vol. 6, No. 6)

Setting Up a Control System for Your Organization (Vol. 16, No. 3)

New IRS Employment Tax Initiative: What Does It Mean for Nonprofits? (Vol. 28, No. 2)

Conflict of Interest in the Board Room (Vol. 17, No. 2)

How to Find the Perfect Auditor (Vol. 22, No. 3)


Dr. Eugene Fram (eugenefram@yahoo.com) is professor emeritus, E. Philip Saunders College of Business, Rochester Institute of Technology (RIT). He is the author of Policy vs. Paper Clips, which describes a nonprofit governance model that has been adopted by thousands of nonprofit organizations. Dr. Bruce Oliver (blobbu@rit.edu) is professor of accounting and director of the Saunders Institute for Business Ethics and Corporate Social Responsibility at RIT.

Time's Up! What You Need to Know about Your 990

I'm a little late on posting this one, the deadlines mentioned in this article have passed.  However, I felt it was important to post if only to remind people to check on their filing status, contact the IRS if necessary and find out what needs to be done.  For many small nonprofits, timely and proper filing can be a struggle.  I am also reminded that nonprofits in every country have to be familiar with their own laws.  Thanks to Nonprofit Quarterly for sending me this article.  Bunnie

Time's Up! What You Need to Know about Your 990

by Jeff Narabrook, Thomas H. Pollak, and Katie L. Roeger

If the number of nonprofits registered with the IRS shrinks by 20 percent this year, don’t blame it on an ailing economy. A simpler explanation is available: thousands of small nonprofits may not meet a new filing deadline, causing revocation of their tax exempt status and removal from the IRS list.


Most nonprofits with fiscal years of January 1–December 31 and revenue under $25,000 had 3 years—or until May 17 of this year—to file form 990-N or lose their federal tax exemption. Active organizations that do not file will face fees and lost time as they reapply for their exemption unless reasonable cause is shown for not filing.

But the true story behind any large drop in registered nonprofits may prove to be that long-defunct organizations are finally being removed from the IRS list. An unknown number of inactive organizations are thought to be on the list because, unlike larger organizations that must annually file Form 990 or Form 990-EZ1, small organizations with receipts under $25,000 never had to file annual documents with the IRS. With no further IRS contact ever required, they would remain on the list indefinitely even after ceasing operation unless someone thought to update their status with the agency.

Consequently, the total number of active nonprofits registered with the IRS was long thought to be misleading. Addressing this blind spot in its regulatory system, a provision in the Pension Protection Act of 2006 gave small organizations a three year window to start annually filing the newly created Form 990-N, commonly known as the e-Postcard.[1] That deadline is now only days away for organizations operating on the calendar year.

The public won’t know exactly how many organizations were removed from the list until the IRS starts releasing the information in January 2011, but to get a sense of the large numbers that may drop off the IRS rolls, begin with over 1.5 million─the total universe of nonprofit organizations of any size registered with the IRS in April 2010. Forty percent of those are small organizations that under the 2006 provision are now required to file 990-N2. Approximately 343,000 of those met the filing deadline as of May 1, leaving over 340,000 or 21 percent of all registered nonprofits that have not filed—and that may need to reapply for tax-exemption. (214,000 of these organizations will lose their tax-exempt status on May 18th, 2010. The remaining organizations operate on different fiscal years and have some additional time.)

How many of those 340,000 groups are still active is an open question. The National Center for Charitable Statistics (NCCS) at the Urban Institute attempted to contact a random sample of 100 organizations that had not filed in the past three years and was only successful in reaching 25 of the organizations. Many organizations have been on the IRS list for decades; 47,000 of them were incorporated before 1950 and over 40 percent were registered sometime before 1980.

While some of the organizations may have ceased to exist long ago, it’s also easy to see how active organizations may have never heard of the requirement. The list of non-filers includes 30,000 sports and recreation clubs, 15,000 student fraternity and sorority groups, 17,000 community service clubs, 17,000 veterans’ organizations, and 8,000 parent teacher groups. Although the IRS used a variety of mediums and outreach methods to publicize the filing deadline, direct communications to these organizations were sent to the last address on file with the IRS. Because most organizations of this size are run by volunteers with addresses at the home of the board president or treasurer, the notices may have never reached the necessary person if no one voluntarily updated their address file with the IRS after a change in leadership.

The cost will be significant for those that lose their exemption and need to reapply. They will have to pay the standard application fee of $400 or $850 depending on anticipated gross receipts. A new IRS Web-based application system in the works would provide a cheaper $200 online application option. But assuming only a quarter of the organizations that have not filed are in fact still operating and will have to reapply before the online application is available, it would drain between $127 million and $272 million dollars from the nonprofit sector just to have their status’ reinstated.

Organizations that missed the deadline will have their status’ revoked immediately and will not be permitted a filing extension. Those that were never notified of the change and missed the deadline may want to make a case for retroactive reinstatement of their tax status, which the law provides if reasonable cause can be shown for failure to file.

While speaking at the Urban Institute’s annual Form 990 Meeting in May of this year, Lois G. Lerner, director of the exempt organizations division of the I.R.S, stated that organizations that had received two or three notification letters, but did not find the time to file the 990-N would not considered a reasonable cause, but each case will be handled individually. Lerner also mentioned that the IRS will be “extremely careful” in notifying the public that an organization has lost its tax-exempt status. In fact, between May 2010 and January 2011, only the IRS will know the organizations whose status has been revoked. Donations to organizations that missed the deadline will remain tax deductible until public notification of the revocation is given on the IRS website.

Time will show just how many inactive nonprofits were lingering on the IRS rolls. The best thing organizations can do is to see if they need to come into compliance by visiting the Urban Institute’s National Center for Charitable Statistics searchable database of organizations that are required to file but have not. If they find they are on the list, an officer from the organization should file Form 990-N through an approved IRS 990-N e-file provider here. Those who know of small nonprofits with receipts under $25,000 in their community are encouraged to notify the organization’s officers of the requirement so that they can take immediate steps to address the situation.

[1] Organizations not required to file a Form 990 include churches, integrated auxiliaries of churches, conventions or associations of churches, 501(c)(1) government organizations, black lung trusts, and instrumentalities of states or political subdivisions.

Jeff Narabrook is the public policy assistant at the Minnesota Council of Nonprofits; Katie L. Roeger is the Assistant Program Director of the National Center for Charitable Statistics at the Urban Institute; Thomas H. Pollak is the Program Director of the National Center for Charitable Statistics at the Urban Institute.

How Valuable is Your Finance Staff?

So you got the grant! Congratulations! However, now is not the time to sit back on your laurels. Grant management is as important as getting the grant in the first place, because if you do it well, you may be able to get another grant from the foundation or government agency. Along with making sure the program you promised is on track, you need to make sure your financial management of the grant is on track. Which may mean making sure your financial staff is up to speed on what is required from the grantor or hiring a financial consultant. Dwayne Briscoe of Bookkeeping Results, LLC, provides some interesting advice on financial grant management, some nuggets to think about. Bunnie

How Valuable Is Your Finance Staff?

by Dwayne Briscoe, Bookkeeping Results, LLC

I have assisted in the handling of nonprofit organization finances for years, and recently I’ve worked with organizations as their sole financial “department”. With the experience I’ve accumulated I want to share my thoughts in hope that people may be able to gain some useful insight from an outside perspective.

The new audit requirements for government funded grants; more stringent restrictions by foundations; the new 990 tax filing return; and the detailed scrutiny of donors to determine where their dollars go; are items of interest that need to be discussed and planned for. Grant fund applications are becoming more and more stringent on the financial side, seeking tighter control over accountability and seeking working fiscal year and mid-year budgets. Times are changing and to not be prepared spells disaster for any organization, whether for profit or nonprofit.

There are three key areas to consider for any nonprofit in order to re-evaluate how it is going to move forward and how it is going to sustain its current level of service. The ultimate buy-in must be from upper management, including the board of directors, because it takes a village to sustain a nonprofit, not just one person.

1. Who is managing your finances? I often work with business and nonprofit clients who end up in a situation for which their books are in dire need of clean-up. One reason for this is the hiring of staff or an outside contractor uneducated in how they should perform their duties correctly in order to complete the tasks at hand. Outside of criminal background checks, are personal/professional reference checks made? Testing performed for specific software used for the organization? Or even an expert in the financial field consulted as an outside interviewer?

Not everyone can do accounting work, although some think it’s just simply knowing how to use a calculator. There are too many rules and regulations that can lead to financial ruin.According to Salary.com (http://www.salary.com/) the average low end bookkeeper makes $32,404 per year or $15.58 per hour. The median range is $37,016 per year or $17.80 per hour, and the high range is $41,047 per year or $19.73 per hour. These hourly rates obviously exclude payroll taxes and benefits, but take a look at what you’re paying your staff currently compared to these rates. Another question to consider is that often program staff are given the opportunity for continuing education, but are the financial department staff?

2. Who reviews the grant financial reporting for reimbursements outside of the financial department? If it’s only the financial department doing this, it’s one of the biggest mistakes that can be quite costly in the end. All grants have a variety of rules and regulations that must be followed, including how they are presented for reimbursement. This is where an outside source is a valuable asset to review everything to determine if there are any potential conflicts before the grantor sees it.

3. How often do you review the Agency’s budget and grant budget schedule?

A minimum of once a month is necessary in order to make sure that you are not only on target but can also plan for potential budget changes before the end of the grant term. A budget change less than 3 months out before a grant ends, isn’t always the easiest thing to get approved. Always be aware of where everything is in any given moment, to allow you to be prepared for the worst.Invest in your future by partnering with your financial staff. They are the ones who need your support the most.

Contact Dwayne at http://www.bookkeeping-results.com/