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:

https://sanfranciscohotelso.weebly.com/department/organizing-an-accounting-departiment

http://www.exemptmagazine.com/management_tips/separation-duties-effective-internal-financial-controls/

http://smallbusiness.chron.com/strengthen-office-billing-accounting-procedures-3933.html

 

 

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 https://www.irs.gov/pub/irs-pdf/f990.pdf

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.

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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 https://goo.gl/M563u9

 

 

 

Kindle Version Available

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

http://amzn.to/2GF2E8W

 

Ideas for Cash Controls

Cash is the riskiest asset of an organization. Why? Because it can be easily stolen or lost.

Below are some controls to prevent or identify these losses.

1-Two people should count any money before it’s deposited to be sure the total is correct.

2-Organizations should acquire a safe preferably bolted to the wall or floor with the code known to limited personnel to safeguard cash, checks not yet deposited, and other valuables.

3-Limit physical access to the area where money is received to just a few people.

4- Don’t keep cash, checks, or credit card slips on a desk or in another unsafe place that is easily accessible. Thieves typically look for petty cash in drawers under desk

5-Nonprofits should use their websites to collect money as much as possible.

6- Organizations should implement a policy indicating that no cash over a certain amount would be accepted.

7- When money is received, it must be deposited promptly in the bank after the count by two separate individuals to confirm the total amount.

8- Nonprofits should perform bank reconciliations, also known as cash reconciliations, every month to be sure all cash transactions have been accounted for correctly.

9- People outside accounting may answer phone calls or emails regarding complaints about payments not showing up in invoices or statements. The question would be– where’s the money these people sent in? The problem could be just an error or an unfortunate situation where money is stolen.

Just knowing that an organization has controls in place to prevent cash theft or losses may be a deterrent to some people with bad intent. The key here is for the tasks to be done all the time, not just once in awhile to avoid problems down the road.

Interested in CPE credits regarding nonprofits?  Online Practical CPE Courses

You can also check out my books:

Nonprofit Finance: A Practical Guide -Second Edition— Nominated for a  2016 McAdam Book Award

15 Quick Tips on Becoming a Great Consultant  — Free on Kindle Unlimited

Another Nonprofit Exec in Jail

Not to be too paranoid here, but I just read an article about the Simi Valley Community Foundation whose former executive director stole over $45,000. According to the news, she forged a second signature on the checks used to pay her own mortgage.  Sadly, this embezzlement cost the organization its reputation as it had to stop operations, at least for now.  A total disaster.

It’s not clear how exactly the theft was discovered, but board members noted something odd, hired a forensic accountant to review the records, and went to the police with evidence of embezzlement. So, I give credit to the board for finding this out, but this theft had been going on for awhile.

So, what can a board do to prevent or identify financial fraud faster?

1- Knowledge –Get people on the board who understand financial matters and can ask the right questions. The board cannot have the obligation to fundraise and provide oversight only. Board members should have different backgrounds with least one person having the education and experience to really understand the information provided and ask good questions. Had this person been on the board of this Simi Valley nonprofit, the fraud may have been identified earlier.

2- Online Access –Have someone from the board check on the bank accounts of the organization online. He or she should review checks and deposits, looking for checks that don’t look right. Just having a policy about this review may deter fraud. Employees may think twice before forging signatures or doing something odd when they know that someone would be looking at the bank transactions regularly.

3- Pay attention –Listen to complaints from staff, donor, and vendors. Oftentimes, information that could be construed as gossip can be useful in pointing you in the right direction. People talk. Even though it’s not clear how the board of the nonprofit became aware of something wrong, my bet is that someone saw something and talked about it. Some nonprofits have started using hotlines for people to report possible fraud anonymously, a very good idea.

4- Variances –Pay attention to the actual vs. budget reports. Looking at this fraud, one may wonder how the $45,000 theft was classified and shown on the financial reports. The amount didn’t show up all at once, but it was likely classified as a budget item. So, if an overage is noted, the board should ask for back up documentations, such as bills.Talk only doesn’t explain financial issues.

5- System reports –Review new vendor/change vendor reports once a month to question any odd new vendor or changes. In this situation, the bank where the mortgage was paid to would have been added at a certain point to the accounting system. Had this report been reviewed, it may have flagged the bank as an odd vendor. Some accounting systems can send an email whenever a new vendor is added or changed, making this task automatic.

6- Bank reconciliations — Check on bank reconciliations, making sure they are done monthly. Keep an eye on deposits that are recognized in the accounting records, but don’t seem to be in the bank.  Also, look at the detailed outstanding checklist. This can be done online using the accounting system and can be emailed to someone at the board. If a check shows up at the bank, but not on the accounting records of the organization, it could be a red flag.

7- Self-reliance –Don’t count on auditors to notice embezzlement. Audits are designed to assure reasonableness of financial statements and they may identify fraud, but not always, especially when done by management. When something seems wrong, not it, and don’t wait for the auditors to figure it out. Insiders are the first people to note things that don’t seem right.

8- Education — Educate all employees on fraud and embezzlement. Nonprofits should have this topic on its policies and procedures documentation and not be embarrassed about it. Fraud happens not just with stealing funds, but in other areas as well, such as equipment theft and overtime pay without authorization. Just showing this awareness and clarity over fraud may prevent it in the first place.

It’s a shame that nonprofit boards must be always on alert for fraud and embezzlement, but that’s the reality of the situation.  Once a scandal happens, it’s hard for the organization to regain the trust and respect of donors, making it hard to move forward.

So, it’s time to talk about this issue openly and set up written policies and procedures with tasks specifically designed to prevent and identify fraud and theft.  The ideas presented here won’t assure boards that they are safe from this issue, but are steps in the right direction.  Each organization is different and I’m sure many will need more control features than the ones presented here.  The crucial point here is that fraud signs cannot be ignored by the board.

Interested on CPE credits regarding nonprofits?  Online Practical CPE Courses

You can also check out my books:

Nonprofit Finance: A Practical Guide — Second Edition 

Nonprofit Finance: A Practical Guide — Nominated for a  2016 McAdam Book Award

15 Quick Tips on Becoming a Great Consultant  — Free on Kindle Unlimited

Setting up an Accounting Dept– Some Pointers

 

Many growing for-profit and nonprofit organizations find themselves with financial reports that make no sense, “forgotten” revenues and slow bill paying processes. They may be at a point where the part-time bookkeeper is over his or her head and flooded in work. So, what can you do? Below are some ideas to get you going.

Identify accounting tasks

You can look at accounting tasks and divide the work within these tasks. For example, a typical accounting department performs the following work:

  • Pay bills – Accounts Payable
  • Recognize revenues – Accounts Receivable
  • Process payroll – Payroll Administrator

Other tasks associated with an accounting department are: Cash management, bank reconciliations, budgets, financial reporting, and taxes. In large businesses, each of these functions is performed by one individual or more. In smaller firms, tasks are shared and the staff is supervised by a manager or a controller, who often is responsible for financial policies and procedures for the organization.

Analyze functions

Many businesses, including nonprofits, organize their accounting department using flowcharts and job descriptions. You don’t want to have the same task be performed twice or three times, but also,  you don’t want to miss an important process. Some nonprofits hire outside consultants to help them in organizing their department for maximum efficiency, while considering risks and controls. Unfortunately, this last option is usually used after a fraud or loss situation, when people are traumatized and willing to pay for professional advice.

Hire people with proper accounting skills

A common mistake is to assume that accounting is easy and can be done by the person who is a receptionist or works in another part of the organization. Without training or education, this person should be able to perform accounting functions of a full-charge bookkeeper. That’s a mistake and is not fair. Hire accounting people who have the proper education and experience. Accounting managers or controllers should have at least a bachelors’ degree in accounting. Someone with a four-year degree in business and a few years of accounting experience may also qualify.

Segregation of duties

As you organize the department, consider segregation of duties. For example, the person who opens the mail or receives money should NOT be the person who books revenues in the accounting system. If the person running accounts payable is also doing bank reconciliations, then a manager or controller should review the reconciliation and look at cashed checks. Why?  To have check-and-balances, internal controls, to prevent and correct mistakes or misappropriations.

Background checks 

Don’t forget to run background checks on all employees and volunteers dealing with accounting and cash functions. Make this a policy within your organization, so that people understand the situation as one of internal controls, not just paranoia.  Actually, many insurance companies require this step before issuing policies against theft and fraud.

Interested on CPE credits regarding nonprofits?  Online Practical CPE Courses

You can also check out my books:

Nonprofit Finance: A Practical Guide – Second Edition— First edition Nominated for a  2016 McAdam Book Award

15 Quick Tips on Becoming a Great Consultant  — Free on Kindle Unlimited

Why Financial Rules Are Good for You

Oh no….Marcie from accounting is again asking for receipts, signatures and other stuff. Can’t she see that we’re busy?  What’s wrong with these people?  Where do they come up with these ideas? Well….there is a reason for this apparent madness and annoyance.

Many managers indeed get aggravated with demands from the accounting/financial department.  However, nonprofits have a lot to gain by following proper accounting requirements, such as requesting proper receipts or approvals. The requirements may seem a bit burdensome, but they serve important purposes within a nonprofit organization’s operations.  These requests are not to drive you nuts.

Oftentimes requirements for certain tasks are to assure that processes flow properly with enough check and balances to avoid errors or fraud. Below are a few important reasons for nonprofits to follow accounting requirements:

1- Financial requirements may be mandatory for recipients of federal and other government funding, such as demands for certain internal controls to avoid errors and misappropriations and the use of a budget. There is really no choice — either the nonprofit follows the prescribed requirements or funding stops.

2- The IRS specifically asks about financial tasks on the tax form 990, the information return filed by many nonprofits. For instance, the return explicitly inquires about the number of items reported on the form 1096, the Annual Summary and Transmittal of U.S. Information Returns. This is usually related to reporting payments to contractors over a certain amount. To comply with this inquiry properly, the nonprofit should have financial rules to capture this information.

3- The nonprofit must also follow all local, State and federal laws. For example, employees may need to file time sheets to be paid correctly. If they don’t follow this accounting rule, paychecks may be printed incorrectly, putting the nonprofit at risk for fines and penalties. So, accounting folks must require proper documentation and approvals so that this process run smoothly.

4- Following financial guidelines protect nonprofits from errors and fraud. An example would be the procedure of requiring approvals on all invoices to be paid. Usually, a supervisor approves such invoices to avoid payments for fake or wrong items or services. You don’t want employees charging the nonprofit for their own tech or other personal purchases.

5- Compliance with accounting requirements, including financial processes, are often evaluated by auditors to assess the risks of nonprofits. For instance, if an accounting requires monthly cash reconciliations, but the auditors note that they are actually done once every four months, most likely the audit risk will increase along with the costs of such audit. So, accounting requirements are to be followed ALL THE TIME to avoid problems. Even by the accounting department.

6-Financial  rules can help in building a nonprofit’s competence while minimizing confusion. For example, a rule to pay bills on only certain days every week may give employees the sense of a set order in finance. One cannot walk in and expect that a check would be ready within minutes. Financial rules can instill confidence and controls within a nonprofit.

Accounting, taxes change throughout the years, so don’t be surprised if the requirements change. For example, starting effectively in 2018, nonprofits must prove that they can pay their bills short term. This is a new requirement of FASB, the organization that dictates accounting rules for nonprofits. So, expect some new requirements from folks from the accounting department regarding this new guideline and others coming down the pipe.

You can check the new edition of the book Nonprofit Finance A Practical Guide at https://goo.gl/M563u9  -First edition nominated for a McAdam Book Award.