SACS Forum Meeting Minutes, November 2023
Standardized Account Code Structure (SACS) November 7, 2023 meeting minutes.Meeting held via webinar at the California Department of Education (CDE), Sacramento
Meeting Agenda
Announcements and Information
Accounting Update
SACS Financial Reporting
Next Meeting
Meeting Minutes
Announcements and Information
2022–23 Unaudited Actuals (UA) Submissions – California Department of Education (CDE) Review
In November CDE will begin the process of reviewing the 2022–23 unaudited actuals data submissions.
A focus of the review will be local education agency (LEA) indirect cost rate calculations, which will provide the rates to be used in 2024–25. The review is to ensure the rates calculated are in accordance with the CDE’s delegation agreement with the U.S. Department of Education (ED). In addition, the CDE wants to ensure the financial data is accurate, consistent, and reliable.
CDE staff may contact LEA staff with questions regarding the indirect cost rate calculation or any other financial reporting questions. CDE appreciates LEA staff’s timely assistance with these questions in order to ensure the statewide financial data will be published in a timely manner.
Email Contact Information
The CDE provided the following list of email accounts for LEAs to direct their questions:
sacsinfo@cde.ca.gov: Questions pertaining to accounting and financial reporting, including using the standardized account code structure (SACS) (e.g., resource coding, valid codes and combinations for specific programs, SACS Query), indirect cost rate (ICR) usage, any other area besides the SACS Web System and submitting unaudited actuals data to the CDE (see below).
sacsweb@cde.ca.gov: Questions pertaining to the SACS Web System, including system access, system technical issues, system workflow issue, issue promoting and submitting datasets.
unauditedactuals@cde.ca.gov: Questions pertaining to submitting the unaudited actual year-end financial data, including submission due dates and promoting or resubmitting or certifying unaudited actual data to the CDE.
Staff Updates
CDE announced that a new consultant, Cindi Mallet, was recently hired in the Fiscal Oversight and Support Office.
Accounting Updates
Special Education Goals to Child Development (Fund 12) Update
The discussion regarding opening Special Education goal codes (5XXX) to Fund 12, Child Development Fund, was proposed during the SACS Forum meeting February 14 and SACS Forum meeting May 16, 2023. CDE received inquiries from LEAs requesting the combinations be opened to better track Special Education expenditures recorded in Fund 12. The CDE had requested feedback from LEAs but did not receive much. A concern with opening the Special Education goal codes in Fund 12 is it would potentially cause issues in calculating the Maintenance of Effort (MOE). Therefore, CDE decided we will not open 5XXX goal codes to Fund 12 at this time.
Every Student Succeeds Act (ESSA) Per-Pupil Expenditure (PPE) Reporting Update
The collection period for 2022–23 data will begin in December of 2023 with data due to be submitted by March 1, 2024. The CDE will be emailing LEAs access codes at the beginning of December or end of November.
LEAs are instructed to use the enrollment data prepopulated in the ESSA PPE Application for this reporting. One informational webinar will be held in January of 2024 which will provide additional information necessary for ESSA PPE reporting. Any questions regarding ESSA PPE may be sent to essappe@cde.ca.gov.
School Level Finance Survey (SLFS)
The Elementary and Secondary Education Act of 1965 (ESEA), as reauthorized by ESSA, requires state educational agencies and their LEAs to prepare and publish annual report cards that contain specified data elements, including LEA and school-level per-pupil expenditures. To strengthen the data that has been collected via the ESSA PPE requirements, the National Center for Education Statistics (NCES) within the ED, along with the Office of Civil Rights (OCR), is implementing a new requirement. The SLFS will allow for more continuity in reporting data at the school-level so that expenditures can be compared on a local, state, and national level.
The Civil Rights Data Collection, through which the SLFS is completed, is a mandatory data collection that recipients are required to meet. The SLFS is utilized to provide data to researchers, state and federal agencies, and the general public on topics such as resource inequities, correlation at the school and per-pupil level of expenditures across states, how expenditures vary between low and high-income schools, and how spending on different functions affects student outcomes.
The SLFS data collection differs from the ESSA PPE requirement in that it collects financial data at a higher level of detail at the school level while not collecting data at a per-pupil level. CDE will collect the SLFS data from LEAs via the existing ESSA PPE data collection system. ESSA PPE data will be utilized to fulfill the reporting requirements for LEAs through 2022–23, however, additional information will be required of LEAs to fulfill this requirement starting with 2023–24 data. The table below contains information as to the required data beginning with the reporting of 2021–22.
| Fiscal Year | Required Data |
|---|---|
| 2021–22 | ESSA PPE submission |
| 2022–23 | ESSA PPE submission |
| 2023–24 | NCES Function Instruction (1000) |
| 2024–25 and beyond | NCES Functions:
Plus, three exhibits:
|
Calculating School-Level SLFS Data
Please note that the guidance below works within the current standardized account code structure (SACS) and the current CDE financial data collection process. SLFS does not require that states or LEAs develop new accounting structures or data collection systems to implement this reporting requirement.
The SLFS rollout will be gradual, starting with the 2023–24 data collection. LEAs must report total instructional costs per site, utilizing current expenditures from SACS Functions 1000, 1100, 1110–1130, and 1190. Starting in 2024–25, all SLFS data elements must be reported, including salary information tied to specific function codes, instructional costs, books and periodicals, and technology-related expenses. Please see Figures 1a and 1b below for additional information.
LEAs, including charter schools, will calculate school-level SLFS data using the financial data available in their local accounting systems. The SLFS data collection is designed to supplement, not supplant, data already collected via the ESSA PPE data reporting requirements.
Figure 1a
| NCES Function | NCES Description | SACS Function(s) |
|---|---|---|
| 1000 | Instruction | 1000 - Instruction 1110- Special Education: Separate Specialist Instruction 1120 - Special Education: Resource Specialist Instruction 1130 - Special Education: Supplemental Aids and Services in Regular Classrooms 1190 - Special Education: Other Specialized Instructional Services |
| 2100 | Student Support Services | 3110 - Guidance and Counseling Services 3120 - Psychological Services 3130 - Attendance and Social Work Services 3140 - Health Services 3150 - Speech, Pathology, and Audiology Services 3900 - Other Pupil Services |
| 2200 | Instructional Staff Support | 2100 - Instructional Supervision and Administration 2130 - Curriculum Development 2140 - In-House Instructional Staff Development 2420 - Instructional Library, Media, and Technology 2490 - Other Instructional Resources 3160 - Pupil Testing Services |
| 2400 | School Administration | 2700 - School Administration |
Figure 1b
| NCES Description | SACS Object(s) |
|---|---|
| Salaries paid to teachers (with NCES Function 1000) | 1100 - Certificated Teachers’ Salaries |
| Salaries paid to instructional staff or assistants (with NCES Function 1000) | 2100 - Classified Instructional Salaries 2200 - Classified Support Salaries 2900 - Other Classified Salaries |
| Books and Periodicals (with NCES Functions 1000 and 2200) | 4100 - Approved Textbooks and Core Curricula Materials 4200 - Books and Other Reference Materials |
The following are guidelines and other information to assist LEAs with their SLFS calculations. To conform with federal financial data collections, the CDE used National Public Education Financial Survey (NPEFS) guidelines to calculate current expenditures.
Included Expenditures
To meet the SLFS requirement, LEAs need to report all expenditures related to the day-to-day operation of public schools, which includes those incurred by school districts. These expenses involve staff salaries, benefits, supplies, purchased services, as well as general and school administration costs. It is important to note that the law requires actual expenditures, not budgeted or estimated, to be used in the SLFS calculation.
Excluded Expenditures
Certain expenditures should be excluded when reporting school-level financial information. For example, expenditures not associated with prekindergarten through grade twelve students, such as adult education. Additionally, one-time significant expenditures, such as facility acquisition, should be excluded as it may distort the school-level data. The CDE recommends LEAs consider the following categories for exclusion:
- Adult Education (Fund 11; Goal 4XXX)
- Capital Outlay (Function 8500; Object 6XXX)
- Community Services (Goal 8100, Function 5000)
- Debt Service (Function 9100, Object 74XX)
- Nonagency (Goals 7110 and 7150)
- Tuition (Function 9200, Object 71XX)
- Transfers (Functions 9200 and 9300; Object 72XX, 76XX)
- County Services to Districts (Goal 8600)
Resource Code Updates
The CDE released a validation table update dated September 29, 2023. All code combinations contained in the table update were included in the October 25 release of the SACS Web System.
The validation tables will continue to be posted on the CDE SACS Valid Codes and Combinations web page for those LEAs who continue to use the tables in their local accounting systems.
The September 29 update included three new resource codes:
4129 – Bipartisan Safer Communities Act - Stronger Connections Grant (BSCA‑SCG)
6018 – Student Support and Enrichment Block Grant (COE’s only)
7399 – Local Control Funding Formula (LCFF) Equity Multiplier
CDE also added end dates to the following programs, which will no longer be valid after June 30, 2024:
4810 – Other ARRA Programs
7431 – COVID-19 Supplemental Funding for ROCPs
The following programs were also ended and will no longer be valid after June 30, 2025:
7422 – In-Person Instruction (IPI) Grant
7425 – Expanded Learning Opportunities (ELO) Grant
7426 – Expanded Learning Opportunities (ELO) Grant – Paraprofessional Staff
Participants who wish to receive email notifications of future table updates can subscribe to the mailing list by sending a blank message to join-sacs-update@mlist.cde.ca.gov. The email notification contains links to the downloadable files and a summary document of the changes.
Indirect Cost Rate (ICR) Calculation – Office of Management and Budget Proposed Changes to the Uniform Guidance for Federal Awards (OMB 2 C.F.R. Part 200)
The Office of Management and Budget (OMB) has proposed changes to the Uniform Guidance, OMB 2 C.F.R. Part 200, which establishes uniform administrative requirements, cost principles and audit requirements for federal awards.
The CDE shared that OMB has proposed changes to several other sections of Part 200, however CDE is focusing on the following proposed changes that impact the ICR calculation.
- Increase the Federal Single Audit compliance threshold from $750,000 (2.CFR 200.501) to $1,000,000. SACS Function Code 7190 is used to record annual financial audits conducted pursuant to the Single Audit Act. Costs reported in this function are included in the LEA’s indirect cost pool on the Form ICR.
- Increase the threshold from $5,000 to $10,000 in determining items that are considered equipment. Currently, property costing up to $5,000 (2.CFR.200.33) can be charged to federal grants as supplies rather than equipment. Amounts charged as supplies (Objects 4000-4999) are included in the total base costs. Amounts charged to Object 6400, Equipment, and 6500, Equipment Replacement, are excluded entirely from the ICR calculation.
- Increase the exclusion threshold of subagreements from $25,000 to $50,000. Current indirect cost guidelines allow that up to $25,000 (2.CFR.200.68) for each individual subagreement may be coded to Object 5800, Professional/Consulting Services & Operating Expenditures, with the remainder charged to Object 5100, Subagreements for Services. Amounts charged to Object 5800 are included in the ICR calculation and in eligible program expenditures on which indirect costs are charged. Amounts charged to Object 5100 are excluded entirely from the ICR calculation and excluded from eligible program expenditures on which indirect costs are charged.
A participant asked if CDE will change the inventory threshold which is currently set at $500. CDE clarified that the inventory threshold is a state law and not something CDE can change. CDE is not aware of any current legislation proposing to change the inventory threshold.
Another participant asked if the proposed changes affecting the ICR calculation are taking effect for 2024. CDE responded there was no effective date in the proposal document. CDE is awaiting more information from OMB.
Governmental Accounting Standards Board (GASB) 100 – Accounting Changes and Error Corrections––an amendment of GASB Statement No. 62
GASB 100 was issued in June 2022 and is effective for 2023–24. It is an amendment of GASB 62, Codification of Accounting and Financial Reporting Guidance Contained in Pre-November 30, 1989, FASB and AICPA Pronouncements, which was issued in December, 2010.
Prior-period adjustments were addressed in GASB 62 but were removed from this Statement because the Board found that the term “prior-period adjustments” was for transactions that resulted in an adjustment to or restatement of prior periods, so it is method of recognition, rather than a type of transaction. The elimination of prior-period adjustments is to remove redundancies and to alleviate confusion in practice.
This Statement addresses accounting and financial reporting for accounting changes and error corrections. Four types of transactions are grouped into two main categories:
1. Accounting Changes
a. Change in Accounting Principle
b. Change in Accounting Estimate
c. Change to or within the Financial Reporting Entity
2. Error Corrections
The following are key points for implementing the provisions of GASB 100 for each type of transaction.
Change in Accounting Principle
- Change from one generally accepted accounting principle (GAAP) to another GAAP – justification is required to explain why the new principle is preferable.
- Adoption of a new accounting principle: justification is not required.
- A change from non-GAAP to GAAP is error correction, not a change in accounting principle.
- A change in accounting principle should be reported retroactively by restating prior periods, if practicable.
- For governments that report a single period in financial statements, the beginning position should be restated for the cumulated effect of the change.
- For governments that report comparative financial statements, all periods should be restated, and the beginning position of the earliest period should be restated for the cumulated effect of the change. If it is not practicable to restate all prior periods, restate beginning balances of current period.
Change in Accounting Estimate
- This Statement clarifies that accounting estimates are outputs determined based on inputs.
- A change in accounting estimate occurs when inputs change.
- Example: change from straight-line method to double-declining balance method for capital asset depreciation.
- Example: change from straight-line method to double-declining balance method for capital asset depreciation.
- A change in accounting estimated should be reported prospectively by recognizing the change in the current period.
Change to or within the Financial Reporting Entity
- This Statement is expanded from GASB 62 to include certain changes in the funds.
- Example: addition or removal of a fund resulting from movement of resources.
- Example: addition or removal of a fund resulting from movement of resources.
- The change to or within the financial reporting entity should be reported by adjusting the current reporting period’s beginning net position, fund balance, or fund net position, as applicable, for the effect of the change as if the change occurred as of the beginning of the reporting period.
- Example: Fund A is combined into Fund B. The beginning balance of Fund B should be adjusted to include the balance of Fund A.
Error Correction
- Examples include mathematical miscalculations, misapplication of accounting principle, and misuse of all the facts that existed as of the financial statement date.
- As stated earlier, a change from non-GAAP to GAAP is error correction, not a change in accounting principle.
- An error correction should be reported retroactively by restating prior periods presented.
- For governments that report a single period in the financial statements, the beginning position should be restated for the cumulated effect of the change.
- For governments that report comparative financial statements, all periods should be restated, and the beginning position of the earliest period should be restated for the cumulated effect of the change. If it is not practicable to restate all prior periods, restate beginning balances of current period.
This Statement also requires disclosure in notes in financial statements and addresses how the information should be presented in required supplementary information, including management’s discussion and analysis, and supplementary information, including the statistical section tables.
GASB 100
(PDF) is available on the GASB website.
GASB 101 – Compensated Absences
GASB 101 was issued in June 2022 and will be effective for 2024–25. This Statement supersedes GASB 16, Accounting for Compensated Absences, that was issued in 1992.
Under GASB 16, compensated absences were defined as absences for which employees will be paid, such as vacation, sick leave, and sabbatical leave.
The definition of compensated absences under GASB 101:
“A compensated absence is leave for which employees may receive one or more (a) cash payments when the leave is used for time off; (b) other cash payments, such as payments for unused leave upon termination of employment; or (c) noncash settlements, such as conversion to defined benefit postemployment benefits.”
Examples are vacation (or annual) leave, sick leave, paid time off, holidays, parental leave, bereavement leave, and certain types of sabbatical leave (such as unrestricted sabbatical leave).
Following are the exceptions that are not recognized as a liability for compensated absences:
- Leave that is more likely than not to be settled through conversion to defined benefit postemployment benefits.
- Parental leave, military leave, and jury duty leave until the leave commences.
- Unlimited leave until the leave is used.
- Holiday leave that is taken on specific date not at the discretion of employees.
- Restricted sabbatical leave.
For governments that have the “use-it-or-lose-it” policy, i.e., unused leave will be forfeited at the end of fiscal year, no liability is to be recognized because the governments do not have an obligation to provide time off or payment or settlement in the future period.
Recognition and Reporting of Compensated Absence in Government-wide Financial Statements
1. Leave that has not been used
- Recognize a liability if all the following are met:
- Services already rendered.
- Leave accumulates.
- More likely than not to be used for time off or otherwise paid in cash or settled through noncash means.
2. Leave that has been used but is not settled in cash or through other means
- Recognize a liability, including any applicable salary-related payments.
As stated in GASB 101, appendix B, paragraph B12, the definition of “more likely than not” has been established as the likelihood of occurrence is more than 50 percent.
Recognition and Reporting of Compensated Absence in Governmental Funds
- No change from previous statement, i.e., GASB 16.
- Recognize expenditures only when payments come due upon the occurrence of relevant events (e.g., employee resignations and retirements).
No expenditure would be recognized for unpaid balance of compensated absence for active employees.
- For portion of compensated absences used but not yet paid as of fiscal year end, the liability may be reported as salaries payable.
California School Accounting Manual Procedure 465, Liability for Compensated Absences in Governmental Funds
Overall, the procedure is still correct, except the following:
“…In most LEAs, because sick-leave days are not normally paid at termination, they are not a liability for purposes of this procedure…”
Under GASB 16, no liability would be calculated or accrued in the government-wide financial statements. The rationale was that unused sick leave accumulated and might be used by employees at any time, but any unused sick leave would be forfeited upon termination.
Under GASB 101, LEAs will be required to perform an analysis to determine a liability in government-wide financial statements to estimate how much sick leave balances are more likely than not to be used as time off in future reporting periods. The rationale is that some of the accrued sick leave may be used before separation by employees and some will be forfeited when the employees separated from the government.
Considerations for implementation
- Review types of leave provided by the LEA.
- Review the employment policies for each type of leave.
- Start to gather historical information about the use, payments, or forfeiture of compensated absences.
GASB 101
(PDF)
is available on the GASB website.
SACS Financial Reporting
SACS Web-based Financial Reporting System (SACS Web System) Updates
Release Dates
- 2022–23
Unaudited Actuals released June 30
- Special Education Maintenance of Effort reports released August 25
- Government-wide reports released September 29
- 2023–24 1st Interim released October 25
- 2023–24 2nd Interim anticipated by mid-January 2024
Reminders
Issue: The 2023–24 Interim period forms do not extract data from 2022–23 Unaudited Actual submissions. 2022–23 Unaudited Actual amounts will need to be manually entered into the following 2023–24 Interim period forms:
- Criteria and Standards (Form 01CSI)
- Every Student Succeeds Act Maintenance of Effort (Form ESMOE)
- Update: Indirect Cost Rate Worksheet (Form ICR)
- Special Education Maintenance of Effort (Report SEMAI)
Proposed SACS Web System 2024 Changes: Criteria and Standards
CDE recently convened a Criteria and Standards (C&S) committee on September 18, 2023. Pursuant to Education Code Section 33127, updates to the C&S will need to be reviewed by a committee and adopted by the State Board of Education (SBE). The last committee convened in 2013 for the implementation of LCFF. The recently convened committee was mainly language clean-up such as removing terminology no longer applicable to LCFF, technical changes to improve fiscal monitoring reviews, and change ADA threshold from 400,000 to 250,000 to conform to Senate Bill 913 (Chapter 920, Statutes of 2022).
The proposed changes will be presented to the SBE in January 2024 for adoption. If adopted by the SBE, the revisions will deploy in the SACS Web System 2024–25 budget and interim reporting periods and the changes will be applicable to districts, COEs, and JPAs.
Following are the criteria affected by the proposed changes:
1. Remove terminology no longer applicable to LCFF
- LCFF Revenue – Criterion 2/4
- Salaries and Benefits – Criterion 3/5
2. Technical changes to improve fiscal monitoring reviews where Form CASH will be required for the budget reporting period. Note that LEAs may continue to use their own cashflow worksheet. Currently, Form CASH is only required for interim reporting periods. The projected end of fiscal year cash balance criterion will be added to the budget period C&S. Consequently, the Fund Balance Criterion will be renamed to Fund and Cash Balances Criterion (7/9).
3. The ADA threshold will be changing the last tier from 400,000 to 250,000, which will be applicable to school districts and JPAs only.
- Fund Balance – Criterion 9
- Reserves Criterion – Criterion 10
NOTE: Subsequent to the November 7th meeting, the SBE reviewed and adopted the above changes to C&S at the January 18, 2024 State Board Meeting.
Next Meeting
The next SACS Forum is tentatively scheduled for Tuesday, February 13, 2024. CDE is again planning on offering the forum via webinar only.
UPDATE: The February 13 SACS Forum was cancelled. The next forum is scheduled for May 14, 2024.