SACS Forum Meeting Minutes, October 2020

Standardized Account Code Structure (SACS) October 19, 2020 meeting minutes.

Meeting held via webinar at the California Department of Education (CDE), Sacramento

Meeting Agenda

Meeting Minutes

Announcements and Information

2020 Financial Reporting Calendar Updates

There was a legislative change that happened within Senate Bill 98 (Chapter 24, Statutes of 2020) that changed the annual audit report due dates. The 2019–20 local education agency (LEA) annual audit report due date was extended to March 31, 2021, and the due date for county offices of education (COEs) to submit the 2019–20 audit certifications was extended to July 15, 2021.

At the time of the SACS2020ALL release, the accompanying 2020 financial reporting calendars did not reflect these changes. The updated calendars have been posted to the CDE Fiscal Calendars web page. Note that the SACS2020ALL software will not be updated with the revised calendars.

2019–20 Unaudited Actuals (UA) Data Submissions – CDE Review

In November CDE will begin the process of reviewing the 2019–20 unaudited actuals data submissions.

A focus of the review will be LEA indirect cost rate calculations, which will provide the rates to be used in 2021–22. 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 timely assistance with these questions in order to ensure the statewide financial data will be published in a timely manner.

Indirect Cost Plan Renewal with the U.S. Department of Education (ED)

In November CDE will be meeting with the ED to discuss CDE’s LEA indirect cost plan proposal and renewal of the delegation agreement.

CDE’s most recent delegation agreement that expired June 30, 2020 has been extended to June 30, 2021. The CDE’s Frequently Asked Questions about Indirect Costs web page has been updated with the extension information.

Staff Updates

CDE announced that a new consultant, Hilary Thomson, was recently hired in the Fiscal Oversight and Support office.

Accounting Updates

Senate Bill (SB) 820: Proposition 20 State Lottery Funds (Resource 6300)

Section 33 of SB 820 (Chapter 110, Statutes of 2020) added Government Code (GC) Section 8880.4.1, clarifying that instructional materials include, but are not limited to, laptop computers and devices that provide internet access for use by pupils, students, teachers, and faculty as learning resources.

The impact of this legislative change is that Proposition 20 Lottery Instructional Material funds (Resource 6300) may now be used to purchase the items described in GC Section 8880.4.1
- Consideration of the possible effect on the SACS Lottery Form (Form L)
  
  Currently, the Resource 6300 column is shaded for all object codes in Section B, Expenditures and Other Financing Uses, except Line B.4., Books and Supplies (4000–4999). Amounts recorded in the other expenditure categories are displayed in the shaded areas and an internal form check (IFC) is generated, requiring an explanation be provided in Section D, Comments, of the form.
  
  CDE requested participant feedback regarding potential changes to Form L due to the expanded instructional materials definition. Specifically:
  
  Will LEAs record expenditures allowed as a result of the revised instructional materials definition to any object other than 4XXX, e.g., Object 6400, Equipment?
  
  If so, how should Form L be revised to accommodate this? Three possible options were discussed:
  
  Option 1: Keep Line B.6., Capital Outlay (6000-6999) shaded and continue to require explanation.
  
  Option 2: Unshade Line B.6., Capital Outlay (6000-6999), and eliminate the required explanation.
  
  Option 3: Add a new line under Line B.6., to capture Object 6400 expenditures for Resource 6300, since no other Object 6XXX should be used (similar to Line B.5.)
  Feedback from participants was varied. CDE asked that additional feedback be emailed to sacsinfo@cde.ca.gov.

Learning Loss Mitigation (LLM) Funds – Resource 3220 Accounting Issues

LLM funding is comprised of three funding sources:
- Resource 3215, Governor's Emergency Education Relief (GEER) Fund
- Resource 3220, Coronavirus Relief Fund (CRF)
- Resource 7420, State Learning Loss Mitigation Funds
The focus of the discussion was on Resource 3320, since most accounting questions have been regarding this resource.
- Revenue recognition
  
  The U.S. Treasury states that CRF resources are not considered grants, but are “other financial assistance” (reference: U.S. Treasury CRF Frequently Asked Questions (PDF) Section B, question 6). However, the Governmental Accounting Standards Board (GASB) took a substance over form approach in applying revenue recognition principles to these resources and identified them as voluntary nonexchange transactions subject to eligibility requirements. Therefore, revenue should not be recognized until eligible expenditures have been incurred. Resource 3220 is established in SACS as grants subject to unearned revenue (reference: GASB Technical Bulletin 2020-1, Accounting and Financial Reporting Issues Related to the Coronavirus Aid, Relief, and Economic Security Act [CARES Act] and Coronavirus Diseases, question 1). Note that CDE initially indicated these funds would be accounted for as subject to ending balance recognition, so LEAs may need to adjust how they established Resource 3320 valid code combinations in their accounting systems.
  In addition, no CRF revenue should have been recognized in 2019–20 because the CRF is not appropriated in the state budget until 2020–21. Generally accepted accounting principles for modified accrual basis accounting require that there be an appropriation of funds in order for revenue recognition to take place.
- Expenditure recognition
  
  CRF eligible expenditures incurred beginning March 1, 2020 were allowed to be recognized in 2019–20. Because expenditures, but not revenues, could be reported in 2019–20, a negative ending balance would occur in Resource 3220. This negative balance would have resulted in a SACS software warning technical review check (TRC) exception for 2019–20 unaudited actuals reporting, for which explanations were appropriate to provide.
  
  A warning TRC exception for an invalid combination of resource and object may also occur in 2020–21 as the negative 2019–20 ending balance is carried forward to 2020–21 as a negative Object 9791, Beginning Fund Balance. LEAs will provide explanation to clear this warning TRC as well.
  Note that the negative balance issue should resolve by 2020–21 year end, as LEAs will receive revenues to offset expenditures. Resource 3220 revenue received in excess of expenditures incurred is recorded as unearned revenue.
- Reclassifying expenditures
  
  When LEAs are required to reclassify expenditures from Resource 3220 to another applicable resource during the 2019–20 audit process (and after unaudited actuals submission to CDE) due to unallowable expenditures, LEAs should record the audit adjustment in 2020–21 using Object 9793, Audit Adjustments, as follows:
  - Debit Object 9110, Cash in County Treasury (or other appropriate asset or liability account), and credit Object 9793 in Resource 3220.
  - Debit Object 9793 and credit Object 9110 (or other appropriate asset or liability account) in the applicable resource.
A warning TRC exception for the invalid combination of resource and object will also be generated for the Resource 3220 Object 9793 entry. An explanation should be provided to clear the warning TRC.
- Additional accounting considerations
  - Object 8980, Contributions from Unrestricted Revenues, and Object 8990, Contributions from Restricted Revenues, are not open in combination with Resource 3220 in order to facilitate transparent reporting of expenditures in Resource 3220. CRF expenditures would be distorted if contributions were made.
  - Resource 3220 is open only to funds 01, General Fund; 09, Charter Schools Special Revenue Fund; and 62, Charter Schools Enterprise Fund. Because the CRF resources are intended to provide emergency relief to LEAs to address the impact that COVID-19 has had on education, and not identified to be used for specific programs or services, the CDE has determined that LEA operating fund types are sufficient to capture Resource 3220 expenditures.
  - Do not use Resource 3220 to record CRF subgrants that LEAs receive from agencies other than CDE. Since CDE has not established a specific resource code for LEAs to report non-CDE administered CRF subawards, Resource 5810, Other Restricted Federal, can be used instead. However, LEAs should separately track these CRF subawards within Resource 5810 since LEAs may have reporting requirements to the other agencies.
  - Indirect costs may not be charged to Resource 3220.
A participant inquired regarding accounting for in-kind, or donated, personal protective equipment and other COVID-related materials and equipment. At this time GASB does not have any clear guidance regarding in-kind contribution recognition. CDE suggests that LEAs discuss reporting options with their auditors. In the meantime, CDE continues to research the appropriate accounting treatment for such items.

A participant inquired about charter school accounting for loans provided through the Paycheck Protection Program (PPP) established by the CARES Act. Charter schools should continue to report the loan as a liability until they are legally released from the debt (reference: GASB Technical Bulletin 2020-1, question 4). Resource 5810 can be used to record these loans. Charter schools are also recommended to separately track such revenues and expenditures since they may be subject to specific reporting requirements.

CDE reminded participants that LLM Fund non-accounting questions should be emailed to CARESAct@cde.ca.gov. In addition, the CDE Learning Loss Mitigation Funding and CDE LLMF Frequently Asked Questions web pages provide extensive information and guidance regarding LLM funding.

Accounting questions can be sent to sacsinfo@cde.ca.gov.
SB 820: Mental Health Funding

Education Code (EC) Section 56836.07 was amended pursuant to SB 820, Section 24, providing that state mental health funding should be available for all mental health-related services for pupils with or without individualized education programs (IEPs), starting 2020–21.

As background, Resource 6512 was established for reporting state mental health funding beginning in 2011–12, and until the SB 820 amendment was restricted for mental health-related services only for pupils with IEPs. Therefore, LEAs have historically reported all Resource 6512 revenues and expenditures using SACS special education goals (5XXX).

With the SB 820 program change, state mental health funding revenues and expenditures associated with services provided to pupils without IEPs are not chargeable to special education goals. Consequently, using the existing Resource 6512 for these non-special education goal transactions will cause a fatal exception for SACS software TRC SPECIAL-ED-GOAL, since this resource code is in the range that is checked for transactions coded to a special education goal or Goal 7110, Nonagency - Educational.

Note that the first 2020–21 apportionment was already distributed to the special education local plan areas (SELPAs) in late August referencing the existing Resource 6512.

CDE discussed two options for addressing the accounting issues resulting from the SB 820 change:

Option 1: Establish a new resource code for reporting state mental health funding starting 2020–21. Resource 6546 was proposed. An end date would be added to Resource 6512.

Pros: A fatal TRC exception will not be generated because the proposed resource code is outside the range of resources validated for the TRC SPECIAL-ED-GOAL. LEAs can continue to use Resource 6512 to account for the remaining fund balance from 2019–20 and prior years’ funding. Mental health funding appropriated in 2019–20 and prior years is still restricted to pupils with an IEP and must be coded to a special education goal.

Cons: LEAs will need to reclassify revenues and expenditures from Resource 6512 to the new resource code for the first apportionment of 2020–21 funds received in late August 2020.

Option 2: Modify the fatal TRC to exclude Resource 6512 starting 2020–21.

Pros: LEAs can continue to use Resource 6512 and do not need to reclassify to a new resource code revenues and expenditures related to the first apportionment of 2020–21 funds received in late August 2020.

Cons: Since the SACS2020ALL software has already been released, the earliest time the TRC could be changed is for 2020–21 estimated actuals data within the SACS2021 budget software release. Therefore, LEAs will experience fatal TRC issues in the SACS2020ALL software if accounting for the 2020–21 funds pursuant to the provisions of SB 820, Section 24.

In addition, LEAs would be required to separately identify and track any remaining balance in Resource 6512 associated with funding appropriated in 2019–20 and prior years, since that balance would be subject to the prior program requirements.

CDE clarified that if a new resource code is established for 2020–21 funding, Resource 6512 will be kept open for up to three additional years to allow LEAs to spend down the remaining balances of 2019–20 and prior years funding, which is still restricted for services provided to pupils with IEPs.

There were a few questions regarding whether special education goals can be used with the new resource code. Since the funding can be used to provide mental health services to students with or without IEPs, LEAs should continue to use a special education goal in conjunction with expenditures for services to students with IEPs. The CDE expects that most LEAs will continue to provide services to students with IEPs. The law merely expands provision of these services to pupils that do not have IEPs.

There were also a few questions regarding the effect of this change on special education maintenance of effort (MOE). CDE will discuss this issue with the MOE workgroup and report back at the next meeting.

NOTE: Subsequent to the meeting, the CDE released a SACS validation table update on November 6, 2020 establishing Resource 6546, Mental Health-Related Services, to record 2020–21 state funding for mental health-related services provided to pupils with or without an IEP.

LEAs are required to reclassify revenues and expenditures associated with the 2020–21 state mental health funding received in late August 2020 from Resource 6512 to Resource 6546. LEAs should complete the reclassification as soon as practical and use Resource 6546 for remaining 2020–21 funding received, as well as subsequent years’ funding.

Medi-Cal Administrative Activities (MAA) and Medi-Cal Billing Option Discussion

The California Department of Health Care Services (DHCS) issued a letter, PPL No. 17-002 (PDF), regarding subrecipient monitoring of certain DHCS administered programs, including the School-Based Medi-Cal Administrative Activities (SMAA) and the LEA Medi-Cal Billing Option Programs (LEA BOP).

DHCS determined that LEAs are considered contractors, not sub-recipients, and that as contractors are not required to report the funding on the Schedule of Expenditures of Federal Awards.

Currently, LEAs account for these programs as federal revenue – the SMAA program using Resource 0000, Unrestricted, with Object 8290, All Other Federal Revenue, and the LEA BOP using Resource 5640, Medi-Cal Billing Option, with Object 8290.
To align with the DHCS determination, CDE is proposing that these programs be reported as local revenue, with the following accounting changes:
- SMAA program: Change the revenue object code from 8290 to 8699, All Other Local Revenue.
- LEA BOP: Change resource code from 5640 to Resource 9010, Other Restricted Local, and object code 8699.

Note that the proposed changes will not require that new codes and code combinations be established, as they already exist in the tables of valid SACS code combinations. An end date would be added to Resource 5640 to coincide with this change.

There was discussion regarding the effective date of the proposed changes. Although LEAs have indicated that their auditors are reclassifying these funding sources sooner, CDE indicated that 2021–22 would be the preferred effective date for SACS reporting so that LEAs do not need to reclassify revenues and/or expenditures mid-year. This also ensures that statewide revenue and expenditures for these programs is classified consistently.

Note that for SMAA, the change only affects revenue reporting since the resource code is 0000. Beginning 2021–22, LEAs will record SMAA revenues to Object 8699 rather than Object 8290.

For LEA BOP, LEAs will need to reclassify the program transactions from Resource 5640 to Resource 9010 (or a locally defined resource within the range 9000–9999 that rolls to 9010 for state reporting). For 2021–22, LEAs can reclassify the beginning balance from Resource 5640 to Resource 9010 using Object 9795, Other Restatements.

Feedback regarding this change can be emailed to SACSINFO@cde.ca.gov.

Governmental Accounting Standards Board (GASB) 84: Fiduciary Activities Update

Due to GASB 95, Postponement of the Effective Dates of Certain Authoritative Guidance, the effective year of GASB 84, Fiduciary Activities, and its Implementation Guide 2019-2, Fiduciary Activities, has been postponed from 2019–20 to 2020–21. The previous summary posted with the October 2019 SACS Forum minutes has been updated to reflect the most current GASB 84 information and guidance. Please refer to the Updated Summary – SACS Forum Discussion on GASB Statement 84 (Attachment A) (PDF).
GASB 87: Leases Update – New Object Codes

As discussed at the May 2020 SACS Forum meeting, due to GASB 95, the effective year of GASB 87, Leases, and its Implementation Guide 2019-3, Leases, has been postponed from 2020–21 to 2021–22.

Please refer to the February 2020 and October 2019 SACS Forum meeting minutes for previous information provided regarding the new lease standards.

CDE discussed proposed new object codes that will allow LEAs to report lease assets separately from other assets, as required by GASB 87. These codes will also facilitate automated government-wide conversion entries in the SACS financial reporting software. Title changes to existing lease-related object codes were also discussed.
1. Expenditures – Capital Outlay (objects 6000–6999)
  
  The following new object codes are proposed to allow LEAs to account for lease-related spending separately from other capital outlay spending.
  - Object 6600, Lease Assets
  - Object 6910, Amortization Expense–Lease Assets (for proprietary and fiduciary funds only)
2. All Other Financing Sources (Objects 8930–8979)
  - Revise the title of Object 8972 from “Proceeds from Capital Leases” to “Proceeds from Leases” to reflect that there is no longer a distinction between capital and operating leases.
3. Assets (Objects 9100–9489)
  
  The following new object codes are proposed to allow LEAs to account for assets associated with leases separately from other LEA assets.
  - Object 9380, Leases Receivable
  - Object 9460, Lease Assets (for proprietary and fiduciary funds only)
  - Object 9465, Amortization–Lease Assets (for proprietary and fiduciary funds only)
4. Liabilities (Objects 9500–9689)
  - Revise the title of Object 9667 from “Capital Leases Payable” to “Lease Liability"

CDE will continue the discussion of GASB 87 lease accounting principles and new account codes at the February 9, 2021 SACS Forum meeting. Please send questions and comments to sacsinfo@cde.ca.gov prior to the meeting.

SACS Codes for Technology Expenditures Discussion

The following is the recap of California School Accounting Manual technology coding guidance found in Procedure 630, Technology – Coding Examples, and elsewhere:

*Object 4100 should be used for internet-based or computer-based state adopted core curriculum.

Expenditure	SACS Object Code
Downloaded or “off-the-shelf” software	Object 4XXX (if not capitalized) 4100, Approved Textbooks and Core Curricula Materials, for basic adopted curriculum* 4200, Books and Other Reference Materials, for reference materials 4300, Materials and Supplies, for other types of materials Object 6400, Equipment, (if capitalized)
Internet-based publications and materials	Object 5800, Professional/Consulting Services and Other Operating Expenditures
Periodic costs of licensing, support, or maintenance agreements for non-equipment items such as software	Object 5800
Initial licensing and other costs incurred as part of a major system acquisition, if meets the LEA’s capitalization threshold	Object 6400
Intangible assets such as computer software, if meets the LEA’s capitalization threshold	Object 6400

Two data elements associated with technology expenditures have been included in the Annual Survey of School System Finances (also known as the F-33) since 2014–15. However, the current SACS chart of accounts does not provide for separately tracking technology-related expenditures, so these data elements have not been reported for California LEAs.

The two technology-related expenditures data elements are as follows:

V02 – Technology-related supplies and purchased services
- Includes services such as internet, voice, and communication services, data processing, coding, technical services, rentals or leases on computer equipment, as well as repairs and maintenance not directly provided by district personnel
- Fall below the capitalization threshold
- Includes equipment below capitalization threshold such as iPads, laptops, cables, monitor stands, and flash drives
K14 – Technology-related equipment
- Technology-related hardware and software used for educational or administrative purposes that exceeds the capitalization threshold
- Includes network equipment, computers, printers, and scanners

CDE is seeking feedback to determine if LEAs are currently tracking technology expenditures and how LEAs are tracking such expenditures, for example, using sub-object codes. Also, CDE would like to discuss with LEAs the time frame to implement the changes if LEAs agree that these additional expenditure classifications are beneficial for operation and reporting. Please send feedback to sacinfo@cde.ca.gov.

New Child Development Program Resource Codes

CDE discussed the following resource codes established for the Child Development program:
- Resource 6123 – Quality Improvement Activities – Workforce Pathways Grant
  
  $1.2 million is provided under the Quality Counts California professional development system. Funding will be distributed to local consortia and multi-county consortia. The federal portion of the funding is accounted in Resource 5035. Since these funds are governed by the Child Development Act, they are reported in Fund 12, Child Development Fund.
Pursuant to SB 820, Section 60, the following resource codes were established for funding sources related to the federal Coronavirus Aid Relief, and Economics Security (CARES) Act for the Child Care and Development Block Grant. These resource codes are accounted in Fund 12, Child Development Fund.
- Resource 5052 – CARES Act Federal Alternative Payment
  
  $119 million allocated for LEAs to provide alternative payments and support services to parents and providers.
- Resource 5053 – CARES Act Federal Alternative Payment, Stage 2
  
  $35 million provided for the CalWORKS Stage 2, child care services administered by CDE through contracts with Alternative Payment program providers.
- Resource 5054 – CARES Act Federal Alternative Payment, Stage 3
  
  $44 million provided for the CalWORKS Stage 3, child care services administered by CDE through contracts with Alternative Payment program providers.

SACS Software Update

Criteria and Standards

CDE discussed upcoming changes to the Criteria and Standards form.
- Criterion 7–Facilities Maintenance–for District only
  - SB 98 and SB 820 – Routine Restricted Maintenance Account (RRMA) Calculation
    
    SB 98 and SB 820 provided flexibilities for LEAs in the RRMA contribution requirement. Pursuant to SB 98, Section 99, LEAs may exclude all Resource 7690, On-Behalf Pension Contributions, expenditures for California Public Employees Retirement System (CalPERS) and California State Teachers’ Retirement System (CalSTRS) state contributions made on behalf of LEAs. SB 820, Section 72, allows LEAs to exclude Resource 3210, 3215, 3220 and 7420 CARES Act expenditures.
    Since these flexibilities were not enacted in time for inclusion in the SACS2020 software release, the RRMA flexibilities were not incorporated in the Criteria and Standards, Criterion 7. The recommended workaround, when completing 1^st and 2^nd interims for SACS2020, is to manually exclude those expenditures in the “Required Minimum Contribution”, since that cell is overridable. Districts will calculate the total 3% general fund expenditures excluding those resource codes. Please note that these flexibilities would not apply to COEs since their RRMA calculation is based on 3% of the unrestricted general fund expenditures.
    
    CDE indicated that in the SACS2021 budget software release, budget reporting period, the school district Criterion 7 will incorporate the RRMA flexibility changes. School districts will no longer need to exclude the expenditures from CalPERS/CalSTRS on-behalf payments and the CARES Act funding.
    
    A participant asked if these flexibilities apply to charter schools. CDE confirmed it would also apply to charter schools if they received school facilities funding pursuant to EC Section 17070.75. Note that the Criteria and Standards form does not apply to charter schools
- Supplemental Information–S5–Contributions–for COE/District
  - No longer extract 1^st and 2^nd subsequent years Contributions from Mulityear Projections (MYP)
    
    A change was made in the SACS2020 budget software release to automatically extract the 1^st and 2^nd subsequent years contribution amount from Form MYP, Unrestricted tab (objects 8980–8999), in an effort to reduce manual data entry. An unintended consequence of this change was that Object 8990, Contributions from Restricted Revenues, amounts were also extracted. S5 is intended to only reflect unrestricted contributions made via Object 8980, Contributions from Unrestricted Revenues. CDE subsequently removed the automated extraction for 2020–21 interim reporting periods. LEAs will once again be required to manually key enter the Object 8980 unrestricted contributions in the 1^st and 2^nd subsequent years of the Supplemental Information, S5, Contributions section in the Criteria and Standards form.
Form A (Average Daily Attendance) – COVID-Related Reporting

When completing Form A for the 2020–21 SACS software reporting periods, please use prior year (FY 2019–20) ADA figures for the 2020–21 figures. However, if an LEA receives the SB 820 growth funding, then the ADA figures reported for growth funding should be used in Form A.

Other Updates

Every Student Succeeds Act (ESSA) Per-Pupil Expenditure Reporting Update

The Every Student Succeeds Act (ESSA) per-pupil expenditure (PPE) reporting application will be opened in the beginning of November for the 2019–20 reporting year cycle. An introductory letter, which will contain a unique access code and link to the applications web page, will be emailed to each LEA superintendent and chief business officer, and each charter school administrator listed within the California School Directory. To help ensure superintendents, chief business officers, and administrators receive the introductory letter, the email address essappe@cde.ca.gov should be added to the recipient’s safe senders list.

The CDE will provide informational webinars to discuss the ESSA PPE calculation and the use of the reporting application beginning in January 2021. Information regarding the dates and times of the webinars will be sent via the ESSA PPE listserv. To receive updates and webinar notifications, you can subscribe to the listserv by sending a blank message to subscribe-essa-ppe@mlist.cde.ca.gov.

During CDE’s review of the 2018–19 ESSA PPE reporting cycle, a few common issues were found:
- For school-level expenditure data, federal and state/local per-pupil expenditure amounts were entered as a total dollar amount, rather than a per-pupil amount.
- For LEA-level expenditure data, federal and state/local per-pupil expenditure amounts were entered as a total dollar amount, rather than a per-pupil amount.
- For LEA-level expenditure data, the total excluded expenditures amount was shown as a per-pupil amount rather than a per-pupil amount.

Further questions regarding the ESSA per-pupil expenditure reporting requirement can be sent to essappe@cde.ca.gov.

Next meeting

The next SACS Forum is tentatively scheduled for February 9, 2021. CDE is again planning on offering the forum via webinar. Meeting information can be found on the SACS Forum Upcoming Meetings web page.

Questions: Financial Accountability & Information Services | sacsinfo@cde.ca.gov | 916-322-1770

Last Reviewed: Wednesday, March 13, 2024

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