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The Berman Buzz

The BH Bulletin: January 2023


Be Aware - New GASBs Effective Soon!

GASB 96: Subscription-Based Information Technology Arrangements

This GASB is effective for periods ending June 30, 2023. It follows GASB 87 on Leases by applying a present value to your right to use on your IT software package. This results in a subscription asset and a liability.


Important to Note: The subscription term includes periods covered by an option to extend (if it is reasonably certain the government or SBITA vendor will exercise that option). The good news is if your contract is short-term with no options to consider, you may get away with a free pass on this one.


GASB 101: Compensated Absences

This GASB is effective for periods ending on December 31, 2024, with early application encouraged.


For PHA's, the impact is small but significant, as 101 allows for a net disclosure instead of both an earned and used (net vs. gross). REAC may address this in a flyer or brief focusing on FDS Line 96210, Compensated Absence Expense. Common rejections take place if this expense is negative using the net method. Happy Days are Back Again!


Also, as a side note, if your compensated absences include a fringe for defined benefit pensions and OPEB, we are booking these as separate liabilities and do not want to double up.


In Case You Didn't Already Know: Changes to the Federal Audit Clearinghouse (FAC)

In addition to REAC receiving the audit at the end of the reporting process, the annual audit is submitted to the FAC. This happens 30 days after the audit is completed or within the nine months after the fiscal year-end. Beginning with 2022 submissions, the FAC will utilize the Unique Entity Identifier (UEI).


In April 2022, the Federal government began using the Unique Entity Identifier (UEI) as the primary identifying number for entities they were doing business with. Beginning with fiscal periods ending in 2022, a UEI is required to file a Single Audit with the FAC. To learn more, click here. To learn how to obtain a UEI for your organization, click here.


More information about the UEI can be accessed here.


HOT Off the Presses

Defined Benefit Retirement Plans

Retirement Allocation and Plan Audits are being issued. Here are Florida's reports.


The Auditor General has just published the FRS Allocation Schedules. The report for Schedules of Employer Allocations and Pension Amount by Employer for the Florida Retirement System Pension Plan and the Retirement Insurance Subsidy Program - Cost-Sharing Multiple Employer Defined Benefit Pension Plans can be found here. In addition, the audited financial statements for the FRS as-a-whole may be found here.


PIH NOTICE 2022-37 Personal Property

Issued Dec 14, 2022

"The Office of Management and Budget requires 2 CFR part 200 be followed. However, as provided by 2 CFR § 200.101(d), where HUD’s program statutes or regulations differ from part 200, the provisions of HUD’s program statutes or regulations govern. For example, 24 CFR part 970 supersedes part 200 and provides specific requirements concerning real property, namely the demolition or disposition of public housing. However, no 24 CFR requirements exist or supersede part 200 regarding Personal Property. Therefore, 2 CFR part 200 governs PHA activities with respect to Personal Property.”


So, What Does This Mean?

PHAs are encouraged to utilize the Tangible Personal Property Report – Supplemental Sheet Form SF-428S and that form's instructions to maintain Equipment Property records. Subject to future rule-making by HUD, the SF-428S may become compulsory for maintaining Equipment Property records.

  1. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (2 CFR § 200.313(d)(2)).

  2. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (2 CFR § 200.313(d)(3)).

  3. Adequate maintenance procedures must be developed to keep the property in good condition. (2 CFR § 200.313(d)(4)).

  4. If the PHA is authorized or required to sell the property, proper sales procedures must be established.

Here to Help

We build value-added relationships with each client to understand their business structure to provide solid solutions, and our approach offers clients direct access to the firm's decision-makers. Contact us to let us know how we can best support you.

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