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Fundamentals
Second 0uarter 2007
Ways and means for the public sector
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Fraud i ails merit: Prograrns to fit any budget
The fall of corporate behemoths like Enron and WorldCom
demonstrates that fraud can bring down even the
mightiest of corporations. The magnitude of the problem
is staggering. According to a recent survey conducted by
the Association of Certified Fraud Examiners — its 2006
Report to the Nation on Occupational Fraud and Abuse
— a typical organization loses 5 percent of its annual
revenues to occupational fraud.
Corporate giants aren't the only organizations dealing with
this problem. Government and not -for -profit organizations
also experience the devastating consequences of fraud. The
median loss suffered by organizations with fewer than i0o
employees was $19o,000 per scheme — even higher than
losses in larger organizations.
Fortunately, public
administrators can take
simple steps to reduce
the cost of fraud without
breaking the budget;
Why are small and midsized organizations so hard hit by
fraud? Most often, it's because these organizations are
less likely to have robust fraud management programs,
especially at smaller organizations where many agency
and NFP executives believe that comprehensive programs
are beyond the reach of their limited budgets. Fortunately,
public administrators can take simple steps to reduce the
cost of fraud without breaking the budget. In many cases,
the following steps can even pay for themselves.
1. Establish an anonymous fraud hotline. Fraud
schemes at government and NFP organizations are
more often identified through tips than by any other
means. Organizations with fraud reporting hotlines
tend to identify fraud earlier — before problems
can grow. In fact, according to the survey, the
median cost of fraud schemes perpetrated in
companies with reporting hotlines is about half the
median cost of schemes committed in companies
without hotlines. And because many service
providers will staff a 24-hour hotline and charge
based on number of calls received, it's feasible to
implement a hotline in nearly any organization.
2. Provide fraud awareness and ethics
training for all employees. According to
the survey, organizations that provided fraud
awareness training reduced the cost of the average
fraud scheme by half. With a few hours of relatively
low cost training, the likelihood that employees will
notice and report a problem increases significantly.
3. Ensure regular internal and external audits.
Organizations with an internal audit function
had a median loss of $120,000 per incident,
compared to $218,00o per incident where there
were no internal audits. In addition to detecting
incidents that have already occurred, audits can
deter employees from committing fraud. Given
the average savings, some organizations find that
internal audits often pay for themselves in fraud
reduction savings alone.
4. Conduct surprise audits. Audit programs
are especially effective in deterring fraud
when surprise audits are performed. Among
organizations that conduct surprise audits, the
average fraud incident was about $loo, 000 —
half the cost of the average fraud incident among
companies that don't perform surprise audits.
Despite their effectiveness, most government and
public administration sector organizations do not
conduct surprise audits. While 76 percent of these
organizations had an internal audit function, only
about 40 percent conducted unannounced audits.
Fraud management, continued on page 3
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2 Fundamentals
. 1.
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In late 2006, the FASB issued a FASB Staff Position (FSP)
that extended the reach of the definition of a public entity.
FSP FAS 126-1, Applicability of Certain Disclosure and
Interim Reporting Requirements for Obligors for Conduit
Debt Securities, amended several existing standards and
clarifies the definition of a public entity. So how may this
affect you?
What exactly are conduit debt securities?
The new standard affects entities that have conduit debt
securities. A governmental entity can issue conduit debt
securities, frequently called municipal bonds or industrial
revenue bonds. A conduit debt security is an offering by a
governmental entity that is not for its own use, but for the
use of the organization that becomes the conduit
bond obligor.
In these types of transactions, the governmental entity is
the issuer of the security, but normally has no subsequent
liability or continuing involvement. The organization who
receives the proceeds in the transaction is the obligor and
must meet the debt service requirements of the bonds.
The FSP concludes that organizations with conduit
debt securities that are traded in a public market —
a domestic or foreign stock exchange or an over-the-
counter market, including local or regional markets
— meet the definition of a public entity. As a result, the
organization must include certain additional disclosures
in its financial statements.
What are the additional disclosure requirements?
The following is a list of the standards and a brief
description of the related disclosure requirements:
• APB Opinion No. 28, Interim Financial Reporting:
requires certain disclosures in interim financial
statements if statements are provided to external users.
• FASB Statement No. 69, Disclosures about Oil and Gas
Producing Activities: requires certain disclosures about
oil and gas reserve quantities and capitalized costs
related to oil and gas activities.
• FASB Statement No. 1o9, Accounting for Income
Taxes: requires additional disclosures about the types
of temporary differences and a reconciliation of the
reported tax expense to the expected tax expense.
• FASB Statement No. 126, Exemption
from Certain Required Disclosures about
Financial Instruments for Certain Nonpublic
Entities: requires disclosure about the fair value of
financial instruments.
• FASB Statement No. 132 (revised 2003),
Employers' Disclosures about Pensions and
Other Postretirement Benefits: expands the
disclosure requirements for defined benefit pension
plans and defined benefit postretirement plans.
• FASB Statement No. 141, Business
Combinations: requires certain pro forma
disclosures about business combinations.
• AICPA Audit and Accounting Guides,
Not -for -Profit Organizations, and Health
Care Organizations: requires those entities to
disclose information required by the standards
mentioned above.
Note: Those that may be more likely to impact your
organization are bolded, but all should be considered
for applicability.
NPFs are specifically scoped out of FASB Statement 131,
which means the implementation of FASB 126-1 wouldn't
require an NPF to disclose segment information.
What is the effective date?
The new disclosure requirements of the standard are
effective for fiscal periods, including interim periods,
beginning Dec.16, 2006. Your first step is to determine if
this new standard applies. If it does, use the list above as
a starting point to determine its effect on your financial
reporting. To help you identify the full scope of the
additional disclosure requirements, consult with your
audit advisor.
Bruce Jorth is a managing director with RSM McGladrey.
For more information, contact him at bruce.jorth@rsmi.com
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Nat,figator rating?
Most donors and would-be donors want to contribute
to financially healthy organizations that are good
stewards of their resources. But in the past, it was
difficult to gauge — without time consuming research
— whether specific not -for -profit organizations met
these criteria.
Now Web sites like Guidestar (www.guidestar.org)
and ERI (www.eri-nonprofit-salaries.com) make data
from IRS 990 forms available online. As a result, it's
easier than ever before to analyze and compare NFP
financial reporting information. And organizations
that evaluate charities find it simpler to retrieve
this information.
As donors become more savvy about giving decisions,
NFPs need to know who will be evaluating them and
what the assessments mean.
Charity Navigator (www.charitynavigator.org)
uses Form 990 information to analyze charities'
financial performance in seven categories. It then
makes a benchmark comparison and assigns a score
ranging from zero to io in these categories, as well
as assigning ratings for organizational efficiency,
organizational capacity and overall financial health.
A general rating of up to four stars is finally designated
for each organization.
A charity with a four -star rating from Charity
Navigator is likely to include that information in
its print and online solicitations. This rating can
differentiate organizations within a particular
category. And if a well managed charity loses its
coveted four -star Charity Navigator rating, it will no
longer be able to tout the achievement on its Web site.
Managing your rating
Public companies are familiar with stakeholder and
media scrutiny. Many NFPs aren't. But it's time to
think about preemptive measures.
If your NFP loses a star or can't claim an impeccable
rating, consider providing information to donors
about how specific challenges are being addressed.
Be clear about your goals and explain what measures
you're using to monitor performance.
When it comes to managing Web site ratings, every
organization should take the following steps.
• Review your Form 990 carefully. It's your most
public and widely accessible document. Ensure
all information is accurate and all questions are
answered carefully. If information might prompt
users to ask questions, be prepared to answer them.
• Determine whether you have a Charity Navigator
rating and understand how and why it was assigned.
• Review your Guidestar records. Contemplate
adding information about your organization and
keep it updated.
• Review your Web site. Do you adequately describe
how you are addressing any challenges?
• If you are independently evaluated, consider
adding information about the evaluation — adding
a commentary if it's helpful to do so.
While maintaining a four -star rating may not always
be feasible, start by looking for opportunities to
improve your NFP's financial health. And be prepared
to demonstrate how your organization is planning for
future success.
Ian Benjamin is a managing director with RSM McGladrey.
For more information, contact him at ian.benjamin@rsmi.com
Fraud management, continued from page 1
These measures are just a few examples of steps to
include in a fraud management program. The most
effective programs are designed specifically to fit an
individual organization. Depending on factors such as
size and industry, other anti -fraud measures should
be considered.
Controlling fraud is a key management responsibility.
While publicly traded companies are required by
law to have a fraud management program,
government and NFP organizations often overlook
such programs. Given the rising cost of fraud and
the potential damage to an organization and its
reputation, a comprehensive, tailored anti -fraud
program is essential.
Jodi Swauger is a director with RSM McGladrey. For more
information, contact her at jodi.swauger@rsmi.com.
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