Restricted grants can be tricky

Look at ALL requirements of such grants, or you can get in trouble and may need to return the funds.  This can get really sticky.

Basic Internal Control for Nonprofits

The idea of separation of duties is not that obvious for many organizations, specially the ones with tight budgets, having one person handle too many functions because it seems simple and straightforward.  It’s usually a mistake.

The overall goal of separating duties is to have a system osf checks and balances to prevent losses and mistakes.

See the following articles about this topic:



How Nonprofit Tax Form Helps Management

The nonprofit tax form 990 contains interesting questions and requirements that should be reviewed by the board, not just by the financial people. I highly recommend to download and print the full form, even if the nonprofit doesn’t need to file it.  You can check out the core pages at

Take a look at the 990 page 6- “Part VI Governance, Management and Disclosure “section” and what is asked in this page– it may be an eye-opener for many.


As you can see, this form raises good questions that may be used to improve operations.  According to the instructions on the top, saying “yes’ to lines 2 through 7b requires explanations and management should review these items carefully.

Line 2 is about identifying people who may personally benefit from the organization, a possible private inurement situation, usually a no-no for tax-exempt organizations or a hefty excise tax. The take away here — be careful with business relations involving board members.

Line 5 is about the loss of assets, an intriguing item on the tax return. A “significant diversion of assets” according to the IRS is embezzlement, fraud, theft or other inappropriate use of funds that is the lesser of 5% of current annual gross receipts, 5% of total assets at year-end, or $250,000.  According to a Washington Post report in 2013, more than 1,000 organizations marked “yes” here and most were for embezzlement.  Besides giving details of the problem, it’s a good idea to also disclose any new internal controls used after the problem was disclosed to prevent it from happening again. Note that this is NOT confidential information.

Line 11 specifically asks about top management getting copies of the tax return and how reviews are conducted.  The board must be engaged in this process, even if they are not financial people.  They cannot say that they don’t know or understand the tax returns.

Line 12 asks about conflicts of interest while line 13 is about whistleblowing, and line 14 covers document retention and destruction policy.  These lines underscore the need for written policies, and under the conflict of interest item, the need to monitor those regularly.  The idea is to say “yes” to all of these.  And the take away for management is to make sure these policies are followed up by procedures to make sure they’re not just “lip service.”

Line 18 reminds organizations to make certain forms available for review, as required by law.   Such reminders are all over the tax form, including reminding nonprofits about reporting contractors and gambling winnings.  Management could highlight those items and follow up on them with the finance department.

Also, note that the 990 asks for the nonprofit’s mission statement as the first line, and also on Part III- Statement of Program Services Accomplishments.  The idea here is to match the mission statement to the programs.  If an organization mission is to provide food for the homeless, but programs relate to buying books to schools, the nonprofit may be at risk to lose its tax-exempt status, which can be a major problem.


You can check the new edition of the book Nonprofit Finance A Practical Guide at




Kindle Version Available

Nonprofit Finance: A Practical Guide is available now as a kindle book on Amazon:


Nonprofit Payroll Risks and Controls

Some organizations run on volunteers only, but many need employees to perform certain tasks. Since having employees is costly, it’s no surprise that payroll is usually the biggest expense in the financial statements. Running payroll can be difficult, and while many organizations contract out outside payroll services, some prefer to process it in-house. Some key risks and controls with payroll are:

Risk: Time sheets could contain wrong information.

In many organizations receiving government funds, everyone files time sheets—even the president—to support charging grants “real” salaries rather than estimated/budgeted ones. Fortunately, many organizations use computerized timekeeping devices and time sheets that once implemented, reduce errors and confusion significantly.

A traditional internal control is for nonprofits to require supervisory approvals on time sheets (manual or electronic) to make sure hours and overtime are authorized. Auditors typically verify if the time charged to a grant was allocated and authorized properly. If the auditor finds errors or no time sheets, or time sheets with no approvals, the scope of the audit is likely to increase, becoming more expensive.

Risk: Employees may be fictitious.

Each employee should file the proper paperwork with human resources and should visit the HR department personally. I know of a case where a program supervisor “hired” a relative part-time who was a “ghost employee.” The nonprofit paid the “employee” for six months, while the supervisor cashed the paychecks.

It was only after a problem with the time sheet of this person (all fake) that the human resources manager got involved, and the fraud was discovered. So, it’s crucial for HR to see and meet with all employees, including part-timers to be sure they’re real and are actually working for the organization.

Risk: Unauthorized payroll changes or increases happen.

To make sure payroll records are correct, department managers should review and sign off payroll registers regarding their department at least once a quarter. Many department managers get the dollar amount of their department’s payroll expenses through regular internal financial reporting, but not the details.

So, having managers verify payroll numbers, overtime, sick days, vacations, etc. is very helpful in keeping it all correct. If they see someone claiming overtime that the manager didn’t approve, he or she can follow up on it.

Controllers or accounting managers should review payroll registers and change reports to make sure the persons running payroll aren’t paying themselves unauthorized overtime or salary increases—a fraud I witnessed that could have been prevented had the controller taken a look at payroll reports regularly.

Risk: Paying terminated employees by mistake.

One issue I often see with payroll relates to nonprofits paying terminated employees because payroll staff didn’t know about the terminations. Once paid, it’s tough to get the money back.  So, it’s important for human resources and managers to notify the payroll department when people quit or are let go. Staff may need to process final checks and update the payroll system.

Nonprofits may implement policies and procedures, including a checklist to follow when employees leave. Many details are involved, such as COBRA requirements that need to be handled correctly or the organization could be liable for fines.

Risk: Payroll information may leak.

Confidentiality is essential with payroll records. Nonprofits must keep all payroll-related documents, including time sheets, in safe, locked filing cabinets where only a few selected authorized personnel are allowed in. Similar security measures must be considered with access to the computerized payroll systems that should be very limited.

Nonprofits should hire people who are discreet and don’t discuss confidential matters with others in the organization. They should avoid using email when mentioning any sensitive payroll information because the system may not be secure enough.

Excerpt from book Nonprofit Finance – A Practical Guide Second Edition —


Nonprofit Finance and Management Explained

The second edition of my book, “Nonprofit Finance: A Practical Guide,” is out.  It includes detailed coverage of FASB update regarding reporting, details about liquidity and other details effective in 2018.   For example, the official financial reporting will show only two net assets, but internally, a nonprofit should maintain the three net assets separately and combine the temporarily and permanently restricted for reporting only.

Internal controls are covered in detail for cash, payables and computerized systems, giving ideas about how to minimize certain risks specific to the nonprofit sector.

Like the first edition, nominated for a McAdam Book Award, this second one has many examples and suggestions based on real-life experience, not just theories.  It was written with both the accountant and the non-accountant in mind, so that people of different backgrounds can benefit from the material and put it to good use right away.

You can check the new edition at

Do You Know What a Pledge Really is?

Most nonprofit organizations are familiar with pledges, as people, businesses, and foundations make promises to give in the future. Many times these promises are the results of fundraising campaigns or appeals. Depending on the situation, the pledge could be for a general or specific purpose, such as for a new child-care program.

Pledges, both short and long-term, may be shown as “Pledges” or “Unconditional Promises to Give” on the Statement of Position.

Promises to give may or may not be real. For example, if a person notifies an organization that he is including the nonprofit in his will, this isn’t a pledge. The same situation exists if someone promises to pay a certain amount twenty years in the future—it’s not a pledge. In both cases, donors can easily change their minds; circumstances can change, making the promises hard to keep.

  • Promises to give must have no conditions to be recognized as real pledges.

Note that  conditions are different from restrictions:

  • Conditions determine if the amount will be given or not
  • Restrictions determine how to use the proceeds

Suppose there is a condition associated with a pledge — the money will be given only if a relative recovers from a serious disease. In this situation, the nonprofit records the pledge only after the condition is met, that is, the person recovers. This situation is tricky since a lot can change, and it makes good sense not to recognize this promise until it’s paid. Same if the condition is the occurrence of a major disaster in California— this pledge is conditional, and the nonprofit should not record it. Once a disaster hits California, then the pledge may be valid.  Managers should use common sense here.

Another example of a condition is a company matching donations made by employees. If an employee gives $10, the firm would also pay $10, matching the donor’s amount. As the employee donates, the condition on the firm’s pledge is lifted. Therefore, each time an employee pays, the organization recognizes a matching pledge.

The wording of a pledge is crucial to determine when a promise is conditional or just restricted. The key word in conditional pledges is “if.” Those are usually not recorded as real pledges by the nonprofit, although they may be filed for future follow up.

Once a pledge is determined to be valid, it can be unrestricted or restricted to a particular time or event, such as for a reading program happening in the future. The classification depends on donors’ intentions. A pledge made on a general appeal can be safely assumed to be unrestricted, while others specific to an individual program should be considered restricted.

Organizations must have pledge documents in writing whenever possible. If a donor doesn’t want to acknowledge the pledge, a thank you letter confirming the gift is a good idea. The letter can be simple and brief but should leave no doubt about the existence of the pledge and its intent.

Issues usually associated with pledges are collectability, pledges paid in installments and privacy of donors, all discussed next.


As promises are to give in the future, pledges may not be all collectible, and most organizations aren’t going to sue to collect promised amounts because of PR issues. Therefore, by its nature, pledges are riskier than regular accounts receivable. As expected, a pledge due in a year is less risky than another one due in two or more years since a lot can happen in a year or longer.  Fundraising staff usually follow up on promises to pay, diplomatically, of course.

Due to the risk of default on pledges receivable, an Allowance for Uncollectible Pledges account is employed. It may be created and adjusted every year based on history. If an organization experiences 15 percent in uncollectible pledges, for instance, this percentage may be applied. It’s the same concept as the Allowance for Uncollectible Receivables in the for-profit world.

A strange situation with promises to give has popped up recently with a young, wealthy supporter promising to give a significant amount to an organization. As expected, people got excited, made a public PR deal with the pledge and started planning how to spend the money. Low-and-behold — it was all fake. The guy liked the attention, but was not wealthy and had no intention to fulfill the promise. The organization lost a lot of credibility with this deal. So, I recommend that nonprofits set up policies and procedures to evaluate significant pledges and to refrain from announcing it and making plans for it until all checks out.


Besides lump sum promises, nonprofits could also have pledges payable in installments; for example, a commitment of $25,000 payable at $5,000 a year for five years. In this case, organizations are to discount the payments to present value using a reasonable percentage. The discount is amortized as in the for-profit world. FASB ASC 820-10 (FASB 157) relates to this topic to be sure organizations evaluate pledges in a fair and acceptable manner.

  • Government and other grants aren’t considered to be pledges and are presented separately in financial statements.

So, if an organization receives a pledge of $30,000 payable in 5 years, apart is considered to be current pledge receivable, and the rest is non-current. In addition, revenue is recognized along with a discount and the allowance account. Don’t double count pledges – once as revenue when the promise is made and again when payments are made.


Many times big donors want to keep their donations and personal information private. To this end, nonprofits should implement proper care so that the donor is acknowledged, donations are recorded, and the donor’s identity is kept secret. So, to assure privacy, donor databases need to be kept secure. Only a few people should possess access to the donors’ records.

As an example, a nonprofit organization I worked with had celebrities donating significant amounts of money, and they didn’t want their names, email addresses or other information available. Therefore, instead of inputting the real names and information in the database, the organization used the names “Anonymous 1,” “Anonymous 2,” etc. The nonprofit kept the real names and personal information under lock and key in a file cabinet accessible only by a couple of people. This low-tech setup worked well.

Note that a pledge is assumed to be a donation, not an exchange, so FASB ASU 2014-09 Revenue from Contracts with Customers doesn’t apply.



( Excerpt from “Nonprofit Finance A Practical Guide– Second Edition)