July 30, 2010

Disbursement Risk in the 21st Century

Over the past ten years we have seen significant changes in the way we pay our bills.  Not too long ago, no one would have ever dreamed that we could pay all of our bills without using a mail box or those old fashioned stamps.  I now find it a pain when someone gives me a check and I have to go to a bank to put it in to my account.  These changing times have also provided all of us with a little extra time in our day because it is easier and faster to pay our bills and review our accounts.  However, all of these efficiencies that we have gained have brought significant risks with it.  These risks have resulted in significant losses for some companies.  I hope to give you some insight in to some of the risks that come along with all of the efficiencies we now take for granted.

The main risk that occurs when employees have access to spend money electronically is obviously theft.  Theft of money electronically is much harder to detect than when someone steals cash.  We have had significant controls over cash for a long time.  We have authorized signers on our checks and some companies even require dual signatures.  We have all of these controls over checks and cash but what controls do we have over someone transferring money to their own account.  Most executives would say that it would be detected during the reconciliation procedures every month.  What if the person stealing the money electronically is also the person in charge of reconciling that account?  What if this person transferred small amounts each week or month over several years?  It could add up to a significant sum.

Companies need to have more controls/checks and balances over electronic wire transfers and automated clearing house (ACH) payments.  The best control I have seen is where an account is set up to only allow electronic transfers to certain payees.  There is a specific process with multiple signatures required in order to get a vendor added to this list.  If this same company wants to make a single electronic payment to a vendor, then it would require multiple authorizations.  Another way to control electronic payments is to employ proper segregation of duties.  Even the smallest of companies can segregate duties.  Let’s take an example of the company that only has one person in accounting and that person reconciles all accounts and performs all accounting functions.  In this case, I would recommend that the president/executive director or maybe the treasurer for the board or even someone from another department should be set up to perform electronic disbursements.  Under no circumstances should that accountant be the person in charge of wire transfers.

Another area of concern for electronic payments would be credit cards.  Having too many credit cards or a lack of control over credit cards can lead to theft.  Credit cards are an easy way to make purchases (business or personal).  There are various ways to use a company credit card to personal gain.  The easiest is to go to an office store to purchase supplies and then pick up a few personal items.  This can be almost impossible to detect.  Another way is to buy things online from companies that seem to have a business purpose but are actually for them personally.  Another horror story we have all heard about is using a company credit card while on a business trip for excessive expenses (i.e. expensive wine, Broadway shows, etc…). 

The key to safeguarding against theft of cash via the use of credit cards is to first limit the number of credit cards your organization has open.  The more credit cards that have monthly statements coming in increases the susceptibility for something to slip through the cracks.  The next key is to actually review the credit card statements every month.  Review each and every transaction and determine their specific business purpose.  Transactions should be questioned and receipts should be reviewed.  Even if the expense was charged by the chairman of the board – it should be questioned if the business purpose is not evident.  I have a client where the treasurer for the board gets a copy of all credit card statements each month and reviews the transactions for reasonableness.  This may not be feasible for some companies but is something to be considered.  I normally recommend that companies start by limiting the number of credit cards to one or two mainly to be used for office purchases.  I recommend that all travel and entertainment expenses go through an expense report process and have all receipts provided with that expense report.  Then all you have to do is review these few credit card statements every month.

I hope the information above has provided you with some insight into some of the risks related to electronic payments and ways to mitigate those risks.  If you have any questions or would like additional information, please feel free to contact me at lmann@ddfky.com.

Lance R Mann
Manager of Assurance Services

 Mann Lance

July 22, 2010

Scheduled Breaks and Their Effect in the Calculation of the Return of Title IV Funds

In our experience with College and University A-133 audits of Student Financial Aid, the second step in the Return of Title IV calculation could lead to many compliance issues for schools.  The calculation is very important because it determines how much money must be returned to the government; as well as who must return the funds. If calculated incorrectly, the school can return too much or not enough federal dollars. If too little is returned, then the school runs the risk of missing the 45 day deadline to return the funds.  The calculation of completed calendar days as a percentage of total calendar days in a term is seemingly simple; however, scheduled breaks and their exclusion from the calculation and/or the use of the mid-point cause some confusion.  Below is a refresher on how to handle scheduled breaks and the use of mid-point:

A scheduled break is a break of five or more consecutive calendar days that are excluded from the Return calculation.  For example, a school has an official break on the calendar that is Monday the 10th – Friday 15th and does not hold weekend classes. The break starts the first day after the last class is held (prior to the break) or in our example Saturday the 8th.  The last day of the break would be the Sunday before classes resume or in our example Sunday the 17th.  This causes for nine days to be excluded from the calculation (Saturday 8th to Sunday 17th).    Scheduled breaks for five or more days are excluded from both the earned days and days in the term.

If a school cannot determine a student’s official date of withdrawal, then they can utilize the mid-point method of returning funds.  The mid-point should not be confused with mid-term.  For mid-point, you calculate the total number of calendar days in the semester and find the mid-point or the number of days earned to make the calculation equal 50%.  For example, a school has 108 days in the term excluding scheduled breaks, when mid-point is used the numerator (number of days earned) would be 54 days or 50%. 

For more information, visit http://ifap.ed.gov or contact Megan Herde, MHerde@ddfky.com

Herde Megan

July 20, 2010

Surviving Today while Planning for Tomorrow

Most contractors that I work with have already cut costs to get through the past couple of years, but many are struggling with what to do to get through the next couple of years.  We continue to hear from national economic experts that the recession is over and the economy has begun to grow.  However, those same experts also warn us that the recovery will be slow.  Contractors are expected to continue to feel the impact of reduced work through 2012.  The 2009 CFMA Construction Industry Annual Financial Survey reported that 92% of the respondents to the survey identified “Sources of Future Work” as their top challenge in the next five years.  Leaders of successful construction companies realize that they must identify and exploit new opportunities to be successful in the future.   Some of the more common strategies that I see:

  • Joint ventures – working with another company can yield significant benefits for all involved.
  • Expand geographic regions – analyze new geographic regions that could provide opportunities for new work.
  • New market niches ­- investigate new and emerging markets for opportunities to diversify.
  • Merge with or acquire another contractor.

 

Each of these strategies provides both opportunity and risk.  Contractors must first identify the strengths of their own company/workforce and match that with the changing needs of the marketplace.  This type of strategic planning will allow companies to adjust to be successful not only today, but also in the future.  Questions you should be asking:  Do we need to hire/create expertise in emerging industries, such as green building?  Do we have the industry expertise but need to market to a broader geographic region with more opportunities?  By partnering with another company will we have the financial strength and experience to perform on a project that we could not do alone?

Continuing to do what you have always done and waiting for the market to come back is not an option in today’s economic environment.  Engaging your leadership in the very important work of planning for today, as well as tomorrow will position your company to thrive in the future. 

For more information please contact:

Crissy Fiscus, cfiscus@ddfky.com

Fiscus Crissy professional

July 13, 2010

Tax Issues Relating to Depletion

One of the largest tax deductions a mining operation may receive is for the depletion of the mineral which it is mining.  The tax rules for depletion are different than those used for Financial Statement reporting.  For Federal Income tax reporting, a deduction is allowed using either cost depletion or percentage depletion, whichever is greater.  Cost depletion is calculated by assigning each unit produced during the year or estimated to be in reserves at year-end a portion of the property’s basis.  The amount of basis allocated to units produced during the year is allowed as a deduction not to exceed the cost of the property.  Under the percentage depletion method the taxpayer may deduct a statutorily defined percentage of gross income from mining (10% for coal mining).  The percentage depletion deduction is limited to 50% of net income from mining on the property, but is not limited by the basis in the property.  Therefore, even after the entire cost basis in the property has been recovered through percentage depletion, a taxpayer may continue to take percentage depletion as long as there is net income from mining.

One caveat to the depletion deduction, especially as it relates to percentage depletion, is the Alternative Minimum Tax (AMT).  The AMT can significantly limit the usefulness of percentage depletion when the deduction exceeds the basis of the depletable property.  Once percentage depletion exceeds the net cost basis in the depletable property, the excess must be added back as a tax preference item for AMT.  This can typically cause either a corporation or individual who uses percentage depletion to be subject to AMT and effectively lose the benefit of the percentage depletion deduction for tax purposes.  The limitation for AMT enhances the importance to make the correct choice in determining whether to use percentage or cost depletion.

The depletion deduction can be highly beneficial for tax purposes, but also adds complexity to many taxpayers.  It is advantageous to properly use the most effective method of depletion given the tax situation of the operation and the operations shareholders.  If you have any questions please contact Melissa Coombs at mcoombs@ddfky.com or Mike McCreary at mmcreary@ddfky.com.

July 6, 2010

Form 990 – Schedule H

During the re-design process of the new Form 990, the IRS placed more emphasis on tax exempt hospitals’ reporting requirements through Schedule H of the new form.  For 2008, Schedule H was optional except for information in Part V regarding the hospital’s facility information.  However, for 2009, the form is required to be completed in its entirety for all applicable activities pertaining to each hospital.  Substantially more documentation will be required by the filing organization.

Part I of the new schedule is designed to provide information regarding charity care and community benefit activities. Information is requested on whether the hospital has a charity care policy and the criteria surrounding the policy.  Hospitals are required to show a detailed analysis of their charity care and community benefit amounts at cost.

Part II is designed to detail any community building activities that the hospital completed during the year that helped to protect or improve the community’s health or safety.  Examples of community health and safety activities could be improvements to housing buildings for vulnerable populations, creating new employment opportunities for community residents, mentoring programs, support groups and disaster readiness programs.

Part III is designed to report the hospital’s bad debt, medicare and collection practices.  The hospital will be asked to report on costing methodologies and rationale for bad debt and medicare policies.  The hospital will also have to describe the collection policies utilized for patients who qualify for charity care and financial assistance.

Part IV is designed to describe activities associated with management companies and joint ventures in which the hospital is a partner or shareholder.

Part V was the only section that was required to be completed with the 2008 return. Within this section, the hospital describes the types of services the hospital provides, such as whether it is a licensed hospital, a critical access facility, a research facility, etc.

Part VI of the schedule, Supplemental Information, allows the hospital more room to describe information listed in other parts of the schedule.  The hospital will also be asked to provide information on how the hospital assesses the health care needs of the community, how the hospital educates and informs patients and persons about their eligibility for financial assistance, information about the community it serves, and how the hospital furthers its exempt purpose.

While the new Schedule H appears cumbersome, it allows the hospital an opportunity to describe the good things it is doing for the community it serves. 

With state governments considering whether to implement minimum amounts of charity care and the federal government considering whether hospitals should lose their tax exempt status, it is becoming increasingly important for tax-exempt hospitals to place a greater emphasis on their community benefit activities.

Please see the following link for Schedule H:   http://www.irs.gov/pub/irs-pdf/f990sh.pdf

Allison Carter
alcarter@ddfky.com

Carter Allison