SACS Forum Meeting Minutes, May 2023Standardized Account Code Structure (SACS) May 16, 2023 meeting minutes.
Meeting held via webinar at the California Department of Education (CDE), Sacramento
Announcements and Information
- Governmental Accounting Standards Board (GASB) 96 Reminder - Subscription-Based Information Technology Arrangements (SBITAs)
SACS Financial Reporting
Announcements and Information
The 2023–24 approved indirect cost rates have been published and can be found on the CDE’s Indirect Cost Rate (ICR) web page.
The collection period for the 2021–22 fiscal year reporting data has ended. CDE is currently reviewing data and notifying LEA’s of any issues that have been found. In June, the CDE anticipates posting the data for the 2021–22 fiscal year on the ESSA Per-Pupil Expenditure (PPE) Reporting web page.
The 2023–24 Budget reporting period was released on May 1st.
During the February 14, 2023 SACS Forum, CDE proposed opening Special Education goals 5XXX to Fund 12, Child Development.
Since the February 2023 SACS Forum, CDE received feedback from LEAs wanting to open the special education goal codes in Fund 12 to better track Special Education expenditures; however, some LEAs have indicated that opening the 5XXX goals to Fund 12 would cause issues in calculating the Special Education Maintenance of Effort (MOE).
Due to the impact on the Special Education MOE, CDE stated further discussions are needed with the Special Education Division to determine if Fund 12 should be open to Special Education goal codes beginning fiscal year 2023–24. For more information, refer to the Early Education’s Management Bulletin 23-02.
CDE is still requesting LEA feedback. Please send any feedback to SACSINFO@cde.ca.gov.
The CDE informed participants that the Office of Management and Budget is still reviewing the SLFS regulations.
Update: After the SACS Forum, the CDE was informed that the Office of Management and Budget has approved the SLFS regulations. The CDE will provide additional details as they become available.
The CDE released a validation table update May 1st which coincided with the 2023–24 budget reporting period release of the SACS Web System. All code combinations contained in the table update were included in the budget release.
The May 1st update included one new resource code:
6102 – Child Development: Universal PreKindgergarten Mixed Delivery Planning Grant (effective 2022–23).
CDE also added end dates to the following programs:
6011 – After School Kids Code Grant Pilot Program – No longer valid after June 30, 2025
6225 – Emergency Repair Program – No longer valid after June 30, 2024
The CDE is aware there are additional programs that are no longer funded and need end dates added in the validation tables, but with the continued priority of the SACS Web System testing and releases, the updates are behind schedule.
One program ending soon is Resource 6512, Special Education Mental Health Services, which was last funded in 2019–20. The Special Education Workgroup reached out to determine when this resource would end. After further discussion, it was determined CDE will give LEAs extra time to spend down these funds. LEAs now have until June 30, 2025 to spend Resource 6512 funding.
The validation tables will continue to be posted on CDE’s SACS Valid Codes and Combinations - Standardized Account Code Structure (SACS) (CA Dept of Education) web page for those LEAs who continue to use the tables in their local accounting systems. The CDE reminded participants that with the new SACS Web System, all valid code combination updates to the SACS Web System are done behind the scenes.
CDE has received many questions and requests for a resource code for the Proposition 28 – Arts and Music Education (AMS) funding. At this time, there is no resource code set up for this funding.
The first allocation and apportionment of the AMS program funding will occur later in 2023–24. Once the CDE has all the necessary information to perform the calculations and to provide correct accounting guidance, a resource code will be issued. The CDE is advising LEAs not to include the AMS funding in their budgets.
Update: The CDE announced new Resource 6770 for the Arts and Music in Schools (AMS) – Funding Guarantee and Accountability Act (Proposition 28).
Governmental Accounting Standards Board (GASB) 96 Reminder - Subscription-Based Information Technology Arrangements (SBITAs)
The CDE reminded participants GASB 96 is effective 2022–23. This statement is issued by the GASB, not CDE. GASB is an authoritative standard-setting body for state and local governments and develops generally accepted accounting principles (GAAP) for state and local governments. State and local governments should follow GAAP for preparing their financial statements. There is no delay for GASB 96 implementation.
Following are items for consideration during GASB 96 implementation:
- Most subscription contracts do not explicitly include the interest rates charged by the SBITA vendors.
LEAs may use their estimated incremental borrowing rate for similar assets (comparing to subscription asset) and similar period (comparing to subscription term) to calculate subscription liability. Please remember that the interest rate used for GASB 87 implementation may not be appropriate since the interest rate has changed in comparison to last year. Last year’s interest rate was noticeably lower than this year. The use of the lower interest rate will lead to higher subscription liability during calculation.
- Determine the subscription term carefully
LEAs should document how the decision was concluded. Please remember that the longer subscription term will lead to higher subscription liability during calculation.
- Whether to adopt capitalization threshold for subscription asset
If an LEA decides to adopt capitalization threshold for subscription asset, they should also consider the quantitative and qualitative significance of subscription liability.
It is recommended to discuss this with your auditors before the adoption.
- Contracts with multiple components
Some contracts may contain both subscription component (for example, the right to use the information technology (IT) assets) and non-subscription component (for example, maintenance service for IT assets). LEA staff should use professional judgement and work with IT staff to separate the components as practical as possible.
Some contracts may contain multiple underlying IT asset components. For example, one contract contains multiple underlying IT asset components that may require reporting more than one subscription asset for financial reporting due to the subscription term being different for separate IT asset components within the same contract.
Another example where there are multiple IT asset components within the same contract, one single subscription asset can be reported because the subscription term starts and ends at the same time for all IT asset components. Therefore, LEAs should read the contract carefully for implementation.
- If all subscription payments are paid upfront, then no subscription liability should be recognized. However, a subscription asset is still required to be recognized and to be amortized over shorter of useful of asset or subscription term in government-wide financial statements.
- Subscription liability will be remeasured in government-wide financial statements if one or more of the following changes have occurred:
- Change in subscription term.
- Change in estimated amounts of subscription payments.
- Change in interest rate.
- Variable payments become fixed for the remainder for the subscription term.
With the implementation of GASB 96, financial statements may have the following implications:
- Increase in debt service expenditures in governmental funds
With the implementation of GASB 96, subscription payments are now accounted for as debt service payments (Object 7439, Other Debt Service––Principal, and Object 7438, Debt Service––Interest) in governmental funds.
- Decrease in other expenditures in governmental funds
With the implementation of GASB 96, subscription payments are no longer accounted for as regular operating expenditures (for example, Object 4100, Approved Textbooks and Core Curricula Materials; Object 5800, Professional/Consulting Services and Operating Expenditures), but accounted for as debt service payments in governmental funds.
- Additional disclosures are required for SBITAs (other than short-term SBITAs) in government-wide financial statements. The disclosures should include but are not limited to the following:
- A general description of SBITAs.
- The total amount of subscription assets, and the related accumulated amortization, disclosed separately from other capital assets.
- Principal and interest requirements to maturity, presented separately, for the subscription liability for each of the five subsequent fiscal years and in five-year increments thereafter.
SACS Financial Reporting
- Release Dates
- 2022–23 End of Year Projection released April 24
- 2023–24 Budget released May 1st
- 2022–23 Unaudited Actuals — late June / early July anticipated release date
CDE reminded participants the 2022–23 SACS and Charter School Alternative Form (ALT Form) unaudited actuals (UA) reporting will be available only in SACS Web System. All charter schools will report their UA financial data, whether SACS or ALT Form, in the SACS Web System. For charter school users new to the system, authorizing agencies will set up user accounts/roles and train on system access and basic system navigation.
CDE is developing a training program for 2022–23 UA. Details are forthcoming. Mostly likely, training will be available after UA period is released and will focus on some forms/processes unique to the UA period.
- Proposed Changes for 22-23 UA Reporting Period
Reports SEMA/SEMB, Special Education Maintenance of Effort (MOE):
Modify reports to exclude new objects 6700 and 6920 as capital outlay.
CHANGE: Subsequent to the May 16 SACS Forum meeting, CDE determined the following proposed change for reports SEMA/SEMB will not be made for 2022–23 UA reporting period: Contribution from unrestricted to federal will be programmed to “zero” if the extracted amount is negative.
Reports CNVRT/ENTRY/GSA/GSNP, Government-Wide Reports: Modify five existing conversion entries (CE001, CE002, CE003, CE0014, CE027), add one new conversion entry (CE028, Lease/Subscription Modification and Termination), and modify government-wide statements to recognize amortization expense of subscription assets, accumulated amortization of subscription assets, subscription assets, and subscription liabilities, pursuant to GASB 96, Subscription-Based Information Technology Arrangements (SBITAs).
- CDE highlighted the following known problems where no workarounds are available at this time. CDE is working with developers to fix the issues and hope to have them corrected by the end of the week. The known issues are listed in the Problems and Fixes section of the SACS Web System dashboard landing page.
Update: The fixes were subsequently released 05/18/23.
2022–23 End of Year Projection
Form MYPI, COE/District/JPA, Available Reserves, Lines E2a-E2c extracting incorrect amounts for Fund 17.
Form 01CS, COE, LCFF Revenue, Criterion 2c extracting incorrect amounts for LCFF revenue for the prior year and budget year.
Form 01CS, COE/JPA, Other Revenues and Expenditures, Criterion 4B/6B extracting incorrect amounts for Total Federal Revenues, Total Other State Revenues, and Total Local Revenues.
Form 01CS, COE/JPA, Other Revenues and Expenditures, Criterion 4B/6B extracting incorrect amounts for Books and Supplies, and Services and Other Operating Expenditures, for the first prior year and budget year.
Will the ALT Form be available for Budget and Interim periods?
No, the ALT Form will not be available for Budget or Interim periods at this time. The ALT Form will be available in the SACS Web System for 2022–23 UA period.
Which reporting period is used for 2022–23 estimated actuals, 2023–24 July 1 Budget?
For 2023–24 Budget reporting period, make sure the context fiscal year is set to 2023–24 (fiscal year drop-down is located under the user profile ). There is a problem with the TRC sometimes displaying the wrong fiscal year in the header only, but the TRC data and results are correct.
Will the known problems be resolved for 2023–24 Budget?
Yes, the four Known Problems and Fixes listed above will be fixed by the end of this week. Update: the fixes were subsequently released 05/18/23.
Will training be available after the UA is due, or before?
The training will be available after the UA period is released, but before UA submissions are due.
Can charter schools complete the ALT Form to fill out the information and import into the SACS Web System?
Once the 2022–23 UA ALT Form is keyed into the SACS Web System, it can be imported into and exported from the SACS Web System. The Charter ALT Form in the legacy format is not compatible with, and will not import into, the SACS Web System.
The ALT Form will be available in SACS Web System for UA Reporting in late June or the beginning of July 2023.
The CDE is only required to provide an ALT Form for the UA period. Currently, charters wishing to use CDE-developed resources for the budget and interim reporting periods are encouraged to consider reporting using the SACS coding structure and traditional SACS forms. ALT Forms may be developed for other reporting periods in the future.
SACS Web System roles for charter users will be similar to those of other LEAs. The charter’s authorizer will be responsible for adding charter user accounts in the SACS Web System.
At this time, all data must be hand keyed into the SACS Web System ALT Form. Charters will then be able to export and import the ALT Form dataset as they see fit. Charters will not be able to import versions of the legacy Excel ALT Form into the SACSWEB.
NOTE: The legacy Excel ALT Form web page will be removed from the CDE website in preparation for the release of the ALT Form in the SACS Web System.
The CDE will be providing additional resources regarding the ALT Form as the release date approaches.
The next SACS Forum is tentatively scheduled for Tuesday, November 7, 2023. CDE is again planning on offering the forum via webinar only.