by Pete McAllister | Accounting News, CARES Act, COVID-19, Healthcare, Industry - Healthcare, News, Tax Consulting
The Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Fund was initially established to provide funding to healthcare service providers impacted by the COVID-19 pandemic. While the financial support has provided much-needed relief, the programs introduced some additional rules and reporting requirements for healthcare providers. On October 22, 2020, the Department of Health and Human Services (HHS) updated its guidance on how providers should report their Provider Relief Fund (PRF) payments that have been allocated for expenses and lost revenues as a result of the pandemic. Below is an overview of what you need to know.
Key Clarifications to Instructions
Addressing some of the ambiguity present in the previous September 19 update, two key clarifications were set forth.
- Method of accounting: The HHS has clarified that PRF payments should be reported using the provider’s normal method of accounting (cash or accrual basis).
- Lost revenue definition: In a twist from prior instructions, which defined lost revenue as a negative change in year-over-year net patient care operating income, recipients may now apply PRF payments up to the amount of the differences between their 2019 and 2020 actual patient care revenue.
If recipients do not use PRF funds in full by the end of the 2020 calendar year, they will have a further six-month period in which to utilize leftover amounts for expenses attributable to the pandemic but not repaid by other sources, or to apply toward lost revenues in an amount not greater than the difference between 2019 and 2021 actual revenue.
PRF Reporting Requirements
The deadlines from here on out are as follows:
- January 21, 2021: HHS portal opens for PRF reporting
- February 15, 2021: Reporting deadline for all providers on use of funds, assuming all proceeds were accounted for in 2020
- July 31, 2021: Final reporting deadline for providers who did not fully spend PRF funds before December 31, 2020
- September 30, 2021: Due date for the single audit or program-specific audit reports for a December 31 year-end or the earlier of 60 days from the date of the issuance of the audit report
PRF recipients can start submitting PRF reports documenting how funds were spent or attributed beginning January 15, 2021. The level of reporting requirements differs by the amount received as follows:
- Entities that received less than $10,000 in total from the PRF do not have to file a report
- Entities that received more than $10,000 but less than $500,000 must submit a simplified report with only these broad expense categories: general administrative expenses and other healthcare-related expenses.
- Entities that received more than $500,000 in PRF must submit a detailed report described below.
- Entities that received over $750,000 in PRF may also be subject to an audit per federal regulations.
Audit Requirements
If an entity received more than $750,000 in PRF, they may be subject to an audit per federal regulations. Audits are required for entities (non-profit and commercial as it relates to PRF per HHS guidelines) that spent over $750,000 from federal grant funds in a reporting period. Note the difference between receiving $750,000 and spending $750,000. Some funds could have been received in cash but not yet spent.
Let MKR CPAs & Advisors help
Our trusted advisors are equipped with the expertise to help you unravel the complexities of these reporting requirements. If you need assistance, contact an MKR advisor today to get the conversation started.
by Brenda Eoff | Accounting News, Business Consulting, CPA, News, Professional Services, Resources, Tax
Two committees of the American Institute of CPAs (AICPA) – the Professional Ethics Executive Committee (PEEC) and the Accounting and Review Services Committee (ARSC) – have extended deadlines on exposure drafts of proposed revisions of existing requirements for nonattest services and of requirements for compilation services.
Requirements of Nonattest Services
The PEEC has agreed to extend the deadline from August 30, 2012, to November 30, 2012, for comments on an exposure draft dated June 29, 2012, of proposed revisions to Interpretation 101-3, “Nonattest Services.”
The committee is proposing that financial statement preparation and cash-to-accrual conversions performed by a CPA member for a client should be considered nonattest services and subject to the revised requirements.
Under the proposed revisions, the preparer is no longer required to perform a compilation with respect to those statements unless engaged to do so.
The exposure draft also considers the cumulative effect that providing multiple nonattest services can have on independence.
“We have extended the deadline because we want to give people additional time to understand the impact of these changes,” said Ellen Goria, senior technical manager of AICPA’s Professional Ethics Division. “We expect the major impact to be experienced by individuals who are preparing financial statements for attest clients. Their systems and processes may need to be modified so that they can be in compliance. We will be providing additional documents to explain this further,” she said.
Requirements for Compilation Services
The ARSC has extended its deadline for comment on proposed revisions to Statements on Standards for Accounting and Review Services (SSARS) to November 30, 2012. The proposed revised SSARS are AR section 70, Association with Unaudited Financial Statements, and AR section 80, Compilation of Financial Statements (Revised).
Existing SSARS require the accountant to perform a compilation engagement whenever the accountant prepares and presents financial statements to a client or third parties. Proposed revisions to SSARS would remove the preparation of financial statements from the attest function, the exposure draft says.
The AICPA stated in its announcement that the proposed SSARS would also “revise the objective of the compilation engagement and provide requirements and guidance when an accountant is associated with financial statements that were not subjected to a compilation, review, or audit engagement.”
The Exposure Draft, Association with Unaudited Financial Statements, includes the following requirements if an accountant is requested to be associated with unaudited financial statements.
The accountant should:
- Read the unaudited financial statements.
- Consider whether the unaudited financial statements appear free from material inconsistencies with other knowledge or information of which the accountant may be aware.
- If after performing the procedures in paragraphs 6a and 6b, the accountant decides to permit the use of the accountant’s name in a report, document, or written communication containing the statements, the accountant should request that the entity clearly indicate that the financial statements were not compiled, reviewed, or audited.
The proposed SSARS also addresses the accountant’s responsibilities when engaged to compile financial statements. The proposed revisions state that the objectives of a compilation engagement provide definitions and enumerate specific requirements that apply to compilation engagements.
The ARSC stated in its exposure draft that it “is supportive of proposed revisions of Interpretation 101-3 because it is in harmony with how the 2011 edition of Government Auditing Standards (the Yellow Book) treats the preparation of financial statements. The proposed clarification would also be consistent with the views of many practitioners who believe that the preparation of financial statements is a responsibility of management and an essential part of an entity’s system of internal control.”
by Pete McAllister | Accounting News, Audit and Accounting, IRS, NonProfit, Tax Consulting, Tax Planning - Individual
Understanding the Educational Institution and Nonprofit Audit Landscape
June 30, the day on which many educational institutions and nonprofits end their fiscal year, is fast approaching. This brings “joy” to many internal accountants because they know that an annual visit from the auditors is just around the corner.
While it is our experience that auditors are not always greeted with open arms by an organization’s staff, we have seen an evolution in these relationships over the past few years. In previous years, auditors were frequently seen as a necessary evil, but now the disdain has diminished. Audits and auditors are now viewed less and less as a commodity or a frustrating interruption to the regular work schedule. Instead, we are more often than not viewed as professionals handling an independent confirmation of the organization’s financials. It has also become a common perception that auditors seek solutions that can help an educational institution or nonprofit improve policies and procedures.
Through the years, accounting and audit technologies have improved, which in turn has bettered audit efficiencies and lowered costs. In an era when enrollment, funding, government grants, and other forms of income are down, hiring an established and proven independent audit firm that provides fair fees (as perceived by the staff and board) is imperative.
Audit Efficiencies
Audit efficiency comes from different areas, such as technologies, documentation, analytical analysis, secondary reviews, and advance preparation. Understanding how to maximize on these efficiencies can cut down significantly on the costs to an organization.
Documentation: A best practice for audit efficiency is documentation. Documenting the whats, whys, and whens associated with accounts or procedures incurs less work for those charged with reviewing the financial data – inevitably reducing the amount of work handled by an auditor. Generally, auditors find that things are done properly but are lacking documentation. It is important to reinforce documentation procedures with your staff because it will save time and money in the long run.
Analytical Analysis: Another preferred practice is to have a member of the auditee perform the analytical work that the audit firm will be doing. This will help in several ways: the analytics will highlight the results that were not expected and/or expected, but had a large variance with a previous period; and the analytics “force” the analyzers to learn more about the organization’s financials.
Issues that arise can be reviewed and discussed internally prior to the auditors’ arrival. Having done the analytical analysis in advance will equip the organization with the answers the auditors will be seeking. This will increase the efficiency connected with the audit, along with providing the staff and other parties with fiduciary duties to the organization more knowledge about its financials.
Secondary Review: Another step that can be taken is to have someone in the organization look at the final financial analysis schedules that were internally prepared. As we know, mistakes happen. A second set of eyes to review the final work product prior to sending it off to the auditors limits mistakes found in schedules, enhances efficiency, and decreases the time an auditor spends at your office.
Advance Preparation: All organizations know when their audits are coming and dread the audit request list. Rather than responding reactively, take a proactive attitude by preparing in advance. Then, respond to the audit request list as completely as possible – keeping the information in the same chronological order as requested.
Leaving a few unanswered requests can really slow down the auditors’ work. Not only does efficiency go out the window, but the final report date gets later and later. The quicker the auditors receive the information, the quicker they will get started. The more time an organization spends on preparing a “tight” package for the auditors, the less time the auditors need to spend on the audit. This equates to lower auditing fees and earlier delivery dates.
Everybody wins when the organization incorporates efficiency into its audit preparation.
Full Article: http://www.accountingweb.com/topic/accounting-auditing/educational-institution-and-nonprofit-audits-fast-approaching-june-30-fisc
Click here to read more on MKR CPAs & Advisors nonprofit accounting services.
by Daniel Kittell | Accounting News, Tax, Uncategorized
As you’re nearing the tax return finish line, you probably have some clients who are stragglers or haven’t “checked in” yet. Fortunately, you can still rely on the automatic tax filing extension to bail procrastinators out of a jam. Here’s some valuable information to pass along to your clients.
The due date for filing 2011 federal income tax returns is April 17, 2012, but that deadline isn’t etched in stone. You can buy yourself more time by filing Form 4868, Application for Automatic Extension of Time to File US Individual Income Tax Return, by April 17. This provides an automatic extension for filing your return for six months until October 15, 2012 – with absolutely no questions asked by the IRS!
Of course, an extension to file is NOT an extension to pay the tax that’s due. You still have to pay estimated tax in a timely manner to avoid penalties and interest charges.
If you don’t pay the requisite amount of tax by the April 17 deadline, the IRS will impose a penalty of one-half percent each month on the amount of tax owed. And, if you fail to file a return by the October 15 extension date, the IRS will ramp up the penalty to 5 percent per month, up to a maximum of 25 percent.
Why would you need a filing extension? Typically, it’s used by taxpayers who simply couldn’t get their act together in time. But here are few other common reasons for seeking an extension:
1. You don’t have all the information you need for your return or it’s been lost or misplaced. For instance, delays may be caused if you haven’t received a K-1 stating income received in 2011 from a pass-through business entity.
“Frequently, an extension is needed because the business or partnership hasn’t completed its own return,” says Chris Hesse, a partner in CliftonLarsonAllen’s federal tax resource group in Minneapolis, Minnesota. “This has become common because pass-throughs are being used to avoid the double taxation issue. The client must make a payment based on a reasonable estimate.”
2. Circumstances dictate a delay. Even if you fully intended to file your tax return by April 17, sometimes life gets in the way. If there’s been an unexpected illness or death in the family, you might not able to file on time. Similarly, a natural disaster can cause interruptions, although the IRS usually offers relief to those in harm’s way.
3. You don’t have the cash on hand for a retirement plan contribution. If you’re self-employed, you might be using a Keogh plan or SEP to save for retirement. The annual contributions reduce your tax liability, but only if the deposits are made on time, notes Hesse. He says that filing for an extension effectively gives you an extra six months to come up with the money.
4. Obtaining an extension might reduce your tax liability. For example, if you converted a traditional IRA to a Roth in 2011, you must pay tax on the entire account balance at the time of conversion. But the value of the account may have declined since then. By recharacterizing your Roth back into a traditional IRA before you file your tax return, you can avoid an unnecessary tax “overpayment.”
5. You’re concerned about tax audits. There’s a school of thought that filing for an extension reduces your chances of being audited. Here’s why: Normally, IRS auditors examine a certain percentage of returns to randomly check for tax cheats. If you obtain an extension, you might sidestep this auditing procedure entirely, thereby reducing your overall exposure to an audit.
In any event, if you don’t pay the requisite amount of tax by the April 17 deadline, the IRS will impose a penalty of one-half percent each month on the amount of tax owed. And, if you fail to file a return by the October 15 extension date, the IRS will ramp up the penalty to 5 percent per month, up to a maximum of 25 percent.
As with your regular tax return, you can e-file your filing extension request or send it by snail mail. If you’re going to a US Post Office, we recommend using certified mail so you can prove to the IRS that you requested the extension on time.
How do you know how much you have to pay with the filing extension application? It’s not an exact science. Hesse says that his firm refers to figures in prior returns to help arrive at a reasonable amount. Contact your CPA immediately for guidance.
Full Article: http://www.accountingweb.com/topic/tax/five-good-reasons-obtain-filing-extension
