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Accounting for Kentucky School Activity Funds “Redbook” Effective July 1, 2013 Presented by : Lanny White, CPA September 21, 2016
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Introduction Purpose – To present the correct procedures for managing school activity funds and for external support/booster organizations Objective – Participants to obtain working knowledge of managing school activity funds and external support/booster organizations Regulated by Kentucky Administrative Regulation (KAR) and the Kentucky Revised Statues (KRS) School activities are provided by the local board to enrich the students educational experience
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Local Board Responsibilities Control and manage schools and their activity funds Bidding for purchases (not a school or SBDM function) Entering into leases (not a school or SBDM function) Designate depositories and incur debt Regulate investment of excess cash Approve school –wide fund-raising activities (Form F-SA-2A) Adopt policies regarding activity funds relative to SBDM
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Local Board Responsibilities (Continued) Withhold and pay taxes and other deductions; issue W-2’s, 1099’s, etc. Regulate expense reimbursement to employees Deficit balances in activity funds Receive any gifts, grants or devices to benefit the school Approve school dues and fees/charges and shall stay in force until removed by board resolution and used for set purpose Ensure activities do not conflict with implementation of Title IX responsibilities of district
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Superintendent Responsibilities Hire employees, including temporary and contract labor Enforces all board policies and administrative procedures of the district Submits activity fund budgets to the board with assistance from the district finance officer Approves magazine sales Ensure activities do not conflict with implementation of Title IX responsibilities of district
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SBDM Council (Principal, if no Council) Make sure school activity fund policies are consistent with board policies Determine use of school general activity funds from bookstore, snack and beverage sales and other office activity funds not raised by a school organization for a specific purpose Profits must be used for benefit of students and not for the school’s physical operating expense, which is a local board responsibility Employee profits/vending must be separate and can be used as directed by employees
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SBDM Council (Principal, if no Council) (Continued) Approve school general/office activity fund budgets, participate in creation of bid specifications and assist in formulation of policies and procedures on activity funds Oversee the expenditure of instructional funds from school fees/dues and other funds not raised for a specific purpose Ensure compliance with Title IX issues as they relate to fund-raising and expenditures
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Principal Act as administrator of school activity funds Assume role of SBDM council if none exists Ensures board/council policies are followed Approve/sign activity fund documentation Review unopened bank statements – signature/date after review Appoint a designee to act in absence of principal Select responsible and trustworthy sponsors to oversee activity funds
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Principal (Continued) Obtain board approval for school-wide fund raising activities and approve other fund-raisers Prepare and submit annual Internal Account Budget to district finance officer (F-SA-3, F-SA-4A/B) Review and submit monthly and annual financial reports to district finance officer (F-SA-15A/15B) Prepare with school treasurer a listing of all donations to the school for the local board
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Principal (Continued) Obtain required information from support/booster organizations for reporting and monitoring: Names of officers – beginning of school year Budgets, revenue/expense, normally due within first 30 days of school year Annual report, due July 15 th – end of year Ensure compliance with Title IX issues as they relate to fund-raising and expenditures
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School Treasurer Record transactions for the Internal Account and school activity funds (receipts/disbursements) Maintain financial records (receipts, disbursements, supporting documentation, accounting system that captures the activity fund’s assets and liabilities and changes thereto) (Form F-SA-15A/15B) Reconcile cash bank accounts to financial records Prepare with the principal a listing of all donations to the school for the local board
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Clubs/Activities Sponsor Determine use of club/activity funds subject to board policy Help elect officers Obtain approval for fund-raising from principal or designee (Form F-SA-2A) Publicize fund-raising activities in advance with purpose and intended use of profits Ensure funds are expended in accordance with purpose and intended use only
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Clubs/Activities Sponsor (Continued) Use Fund-raiser Worksheet to document profits (Form F-SA-2B) Follow guidelines for handling cash Submit annual budget to principal (Form F-SA-4A) Ensure compliance with Title IX issues as they relate to fund-raising and expenditures
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Receipts – General Guidelines One treasurer for school activity funds (bond required), cannot be a student One interest-bearing checking account at board approved bank – exception: charitable gaming Two signatures on checks (principal/designee and treasurer) Activity fund ledger for each activity and in total Ledger/checkbook balance should be maintained daily (Forms F-SA-11, F-SA-12) Activity fund reconciled to bank monthly, including investments (Form F-SA-15A)
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Receipts – General Guidelines (Continued) All money given to treasurer daily Treasurer shall never collect money directly from students or parents Treasurer shall not open mail Checks received in the mail shall be receipted (Form F-SA-6) and submitted to the treasurer Treasurer and person turning in the money shall jointly count the money Treasurer must use pre-numbered receipts and account for them Daily deposits are best, but may keep in secure location until $100 or at least weekly
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Receipts – General Guidelines (Continued) After hours collections shall be placed in a night depository, night drop or locked school safe and processed for deposit the next business day by the treasurer Deposit slip examined by someone to verify amount agrees to the ledger and stamped by bank (performed by an employee other than one preparing the deposit; i.e., check receipt sequence for completeness) Discrepancies reported to the district’s finance officer Teachers/sponsors use Multiple receipt form (Form F-SA-6) or pre-numbered receipts Students third grade and above must sign the Multiple Receipt Form
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Receipts – General Guidelines (Continued) Treasurer restrictively endorse checks “ For Deposit Only ” upon receipt Names and amounts of checks listed on deposit slips or copy of check with receipt numbers on the deposit slip Do not cash personal checks Record receipts in the accounting system (Forms F-SA-11, F-SA-12) Handling of returned checks – fees charged – negative receipts
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Receipts – General Guidelines (Continued) Investments to be in accordance with board policy with excess cash invested Reconcile the bank account monthly – should include investments (Form F- SA-15A) Principal receives unopened bank statements for review Schools and district employees cannot borrow or lend monies No grant monies, day care fees, adult education fees or tuition fees shall be deposited in the school activity funds as this should be handled by the central office Student fees and charges shall be adopted by the local board and shall remain until removed by the board
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Receipts – General Guidelines (Continued) Student fees shall be used for the approved purpose Investments will be shown on the financial reports No personal activity allowed (employees, students, etc.) Electronic receipts should be addressed by detailed policies and procedures
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Segregation of Duties Appendix A – provides examples of suggested structures for internal control purposes Redbook suggests ways to segregate duties using three people in the areas of receipts, bills and bank reconciliation One person should not have complete access/control over a cash receipt/disbursement transaction Internal controls over receipts: receipt log compared to deposit jointly counting cash receipts
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Segregation of Duties (Continued) Internal controls over disbursements: purchase orders invoices packing slip Principal receives unopened bank statement Procedures for bank account reconciliations preparation and review Appendix D provides recommended report review procedures for the principal, treasurer and district finance officer
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Fund-raising Fund-raising is an organized activity of soliciting and collecting money for the school activities and shall be maintained in the school activity accounts The local board will regulate/approve school-wide fund-raising activities (Form F-SA-2A) The principal or designee shall approve all other fund-raisers including the proposed use (F-SA-2A) Fund-raising activities should make a profit or have an important instructional purpose Fund-raising activities are to benefit students and should not be used to cover staff payroll or staff accounts or other operating cost of the school
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Fund-raising (Continued) Fund-raising proceeds MUST benefit the entire group of students involved, regardless of participation in the fund-raising event Fund-raisers cannot be tracked by individual students All fund-raisers must have Fund-raiser Worksheet completed (Form F-SA- 2B) and complete the form within one week of the completion of the fund- raising event and submit to the principal for review Reasonable profits on concessions, vending machine sales and bookstore sales shall be verified on Inventory Control Worksheet (Form F-SA-5) and should have different folks collecting cash and completing the form
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Fund-raising (Continued) Sales from concessions/bookstores/etc, should use the Form F-SA-17 when giving receipts to the treasurer and should have different folks collecting cash and completing the form Magazine sales must be approved in writing by superintendent and filed with county clerk
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Ticket Sales Pre-numbered tickets must be used for ALL events charging admission Tickets kept in secure location and rotate/change colors for events Must use Requisition and Report of Ticket Sales form which includes beginning and ending ticket numbers, signature of person in charge, number of tickets sold, money collected and reconciliation Suggest a ticket seller and ticket taker (different people) Principal or treasurer shall not be in charge of sales and treasurer cannot sell tickets
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Ticket Sales Ticket taker tears ticket in half and retains the one half Tickets sold are reconciled to the retained halves Reconcile the number of tickets collected with number of tickets sold along with cash collected (Form F-SA-1) before giving the form to the treasurer Treasurer/in-charge reconcile activity cash and tickets (verify ticket sequence used and all tickets are accounted for and returned) Treasurer should issue a receipt to the ticket in-charge and attached a receipt copy to the form Money collected shall be deposited promptly and if after hours secured in a night depository, night drop or a school safe and processed the next business day
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Ticket Sales A change fund shall be initiated with a check written to the Athletic Director or responsible person Change fund shall be kept in secure location between events and not comingled with gate or concession receipts
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Donations Donations are gifts of real or personal property to the school from outside sources for the use at the school or students Donations are to be received by the local boards and comply with donor restrictions Local board policy may allow schools to receive gifts over a set threshold If the policy allows the school to receive donations then the principal/treasurer shall prepare a listing of all donations to the school for the local board annually The Donation Acceptance form (Form F-SA-18) shall be completed for all donations and a donation acknowledgement should be sent to the donor
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Donations (Continued) Restricted donations received by the school shall be maintained in a separate activity fund to monitor compliance Unrestricted donations for general use shall be recorded in the general activity fund which has oversight by the principal/SBDM council and must be used to support student activities Donated equipment or property will become district property and the district finance officer should be notified to ensure it is included on the district’s inventory listing
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Transfers Can only occur with completed Transfer Form (Form F-SA-10) Sponsor of remitting school activity and principal shall sign form along with an explanation of the transfer Transfers from the local board should be monitored to ensure restrictions are met and documented No transfers or reimbursements are allow from the school activity funds to external support/booster organizations or staff accounts
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Fixed Assets Fixed assets are real or personal property with an estimated life of more than one year and cost threshold established by the local board (KDE recommends $5,000) KDE Capital Asset Guide can be used as an reference tool Workstations/laptops are not required to be capitalized, unless they meet the District’s threshold, but should be tracked for control purposes Any purchases/donation of fixed assets for school activities should be reported to the district finance officer The property shall become the district’s asset and will be maintained by the district
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School Banks School Banks: Supporters are key components– local board, principal, sponsor Financial supporter – bank or credit union Structure depends type of financial supporter School bank branch or nonbank branch(financial literacy program) Nonbank branch has only Bank employees – educational purpose School bank branch is an actual bank branch with students operating the full service bank branch A written agreement obtain between Bank and local board Establish daily reconciling procedures of cash activity
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School Banks (Continued) School Banks: Must obtain written permission forms from the parent or guardian of each student participating in the program Parents must agree to be responsible for any financial obligations incurred by the student Sponsor cannot open personal accounts Never accepts school activity fund monies The school bank is not included in the district’s annual financial audit
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Charitable Gaming Charitable Gaming as fund-raisers involve games of chance for a charitable purpose (ie. Bingo, raffles such as split the pot, pull tabs) Does not include events that are based on skill such as dart throw, basketball shot, golf putt, bean bag toss, duck pond, cake walks(all players win equal prize) or auctions Department of Charitable Gaming regulates these activities KRS 238.535 Applies to district, school, clubs and external support/booster organizations Gaming activities must have a checking account used only for gaming if an exemption or a license is required
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Charitable Gaming (Continued) Gaming regulations: A school or external support /booster organization has 3 or less raffles per calendar year and gross receipts of $150 or less on each has no filing requirement. Gaming exceeding the above amounts shall have a gaming license or exemption: KRS.238.535, ocg.ky.gov Exemption applies to bingo, raffles, charity fund-raising events and gross receipts do not exceed $25,000 per calendar year Should gross receipts exceed $25,000 per calendar year a license is required
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Charitable Gaming (Continued) Gaming regulations: Gaming license requires quarterly reporting to the Office of Charitable Gaming and a fee is paid on gross receipts Exemptions still file annually gross receipts and expenses A school exemption/license does not cover an external support/booster organization and an external support/booster organization’s exemption/license does not apply to school activities The Department of Charitable Gaming offers training courses and a web site that will provide guidance
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Procurement/Expenditures Bidding and purchasing is a local board’s responsibility – Kentucky Revised Statutes, Kentucky Administrative Regulations Schools can purchase off approved bid list (local, cooperatives, GSA, state, etc.) Items normally subject to bidding requirements: instructional materials class rings, yearbooks, school pictures, playground equipment athletic supplies/equipment band equipment/uniforms items for resale (concessions, colas, bookstore, shirts, etc.)
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Procurement/Expenditures (Continued) Cash awards, gift cards, or prepaid cards to students are not allowed Cannot purchase personal items even with reimbursement agreements Only staff accounts (staff vending) may be used for staff gifts, dinners, etc. Payments to support/booster organizations are not allowed No loans to employees, parents, students or sponsors for any reason No payment of individual’s organization dues/fees that does not provide a direct benefit to the students
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Procurement/Expenditures (Continued) No extra compensation or bonuses to district employee (cash and noncash) No alcoholic beverages, tobacco products, controlled substances, firearms and weapons No purchase that benefits the adult sponsors or district employees and not the students No books, magazines, memberships that do not benefit the students No professional development or staff development allowed Cannot use activity funds to pay for routine operating expenses, renovations or maintenance of school building/facilities/grounds, furniture for administrative offices
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Procurement/Expenditures (Continued) Cannot use activity funds for attendance incentives unless instructional in nature (instructional field trips, books, etc.) Attendance incentives such as tee-shirts, parties and non-instructional field trips shall be funded by non-tax, non-board controlled funds such as donations or support /booster organizations and local businesses Student-generated funds should provide student incentives for scholarship, athletics, specialized area performance, school spirit and similar achievements
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Procurement/Expenditures (Continued) Some examples of allowable cost emblems of membership for students awards such as merit certificates, trophies, plaques for students equipment, supplies and material for student organizations approved fund-raiser expenditures entry fees/cost with competitions and meetings of student groups parent/student functions such as open house, back to school bash, parent night or orientations cost of trainings which are required for sponsors/coaches travel expenses and meals for students and adult sponsors during official school trips memberships in related organizations for student groups charitable contributions/donations made with funds collected specifically for that purpose other allowable expenditures approved by the members of the student group or by the principal and SBDM council for accounts without student involvement Only checks to the in-charge of petty cash for change or petty cash replenishment
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Procurement/Expenditures (Continued) Schools do not pay sales tax nor do they reimburse sales tax on purchases by employees (hotels/restaurants are exceptions) Booster clubs/PTO/PTA cannot use school’s tax-exempt status Use purchase orders to initiate a purchase, signed by sponsor and principal (Form F-SA-7) Must have supporting documentation for all expenditures (purchase order/packing slip/vendor invoice/standard invoice) (Form F-SA-8) and treasurer shall review for completeness of these documents before a check is written
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Procurement/Expenditures (Continued) Use pre-numbered checks and mail same day as written Signature stamps are not allowed for indicating approval of school activity Treasurer shall be bonded Invoices should be marked “ Paid ” with date and check number Deface voided checks, negative expense and no checks made to Cash/ School/Bank File by month in check numerical sequence order and posted to the Principal’s Combined Activity Fund Ledger (Form F-SA-11) and the Individual Activity Account Ledger (Form F-SA-12)
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Procurement/Expenditures (Continued) Reimbursements or refunds to students should use Form F-SA-14 requiring students to sign Fixed assets – including technology – capitalize district policy, contact district financial officer Electronic payments should be addressed by detailed policies and procedures
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Title IX Title IX of the Education Amendments of 1972 is a federal law that prohibits sex discrimination in education programs that receive federal funds It is the responsibility of all district staff, volunteers and external support/booster organizations to report purchases from any source for Title IX compliance All school activity fund expenditures for athletics must be reported to the district staff responsible for Title IX reporting and monitoring of compliance Appoint district staff to ensure appropriate administrative oversight of support/booster activities and meet with these organizations periodically to ensure equitable funding of boy’s and girl’s athletics
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Cash Advances and Travel Reimbursements Club sponsors/teachers may receive a cash advance only if students are participating and expenses are supported by Expense Report with unused cash being returned (Form F-SA-9) Completed form and support shall be returned by the close of the next business day after the trip Travel reimbursements based on travel voucher must follow board policies and employees can be reimbursed tax on food and hotel costs (Form F-SA-16) Travel vouchers shall be submitted within one week of the travel District and school administrators cannot be reimbursed expenses for travel from the activity fund unless students are on the trip
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Payment for Services Determination of worker status must be made by the principal and approved by the district finance officer as to whether the individual performing the services as a district employee or independent contractor The Internal Revenue Service (IRS) has developed a list of 20 common law factor to aid in the determination of employee or independent contractor Determined on a job-by-job basis
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Payment for Services (Continued) Non-district employees – paid by check from activity fund with standard invoice signed by payee; must keep track of payments to submit to the district finance officer for 1099’s (Form F-SA-8) District employees – paid through MUNIS payroll not directly from activity fund Examples of Independent Contractor – referee and artist in residence (Art, Dance, Music, Theater) Examples of an Employee – ticket seller/taker, teacher, bus driver
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Credit/Store Cards Only use if allowed by board No personal purchases allowed Must be kept in secure location Have a sign in/out form to monitor use (Form F-SA-13) and separate identification for each type of card Must have prior approval for any purchase – if not, employee is liable
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Credit/Store Cards (Continued) Still must use PO and obtain itemized receipt The card and support shall be submitted immediately or no later than the close of the next business day Lost credit cards – report immediately to the appropriate office
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Inactive Accounts Inactive activity fund accounts may be closed at any time Principal should be notified by the student organization’s sponsor Student organization should vote on the distribution of remaining funds Funds should NEVER be transferred to an entity or bank account outside the school If student organization did not leave written instructions on disposing of the remaining funds, they will be transferred to the school activity general account Senior class funds become inactive on commencement day and should provide instructions for unused funds before commencement day
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Inactive Accounts (Continued) Activity accounts will be considered inactive after 12 months of no activity Transfers will follow the Form F-SA-10 Inactive activity fund accounts with a deficit balance will be closed by a transfer by the school activity general account as approved by the principal
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Petty Cash Existence and amount must be approved by board for small miscellaneous purchases Principal shall select the person in-charge of petty cash and a check written to that person to established the fund and supported by a standard invoice (Form F-SA-8) Cash kept in secure location and no loans from the account to anyone All disbursements require a receipt which is stored with cash Shown on monthly financial report and reconciled (Form F-SA-15A) Close petty cash at end of year No personal activity allowed
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Budgets ‒ School Activity Funds Budget development and cycle for school activity funds should be similar to school district’s cycle Each club/activity must prepare a tentative budget for the next school year by April 15 th and submit to principal (Forms F-SA-4A ) Sponsors and principals shall assist in the budget process for SBDM approval Principal must submit Internal Account Budget and individual budgets to the district finance officer by May 15 th (Form F-SA-3) Fund-raising request from school support groups may be included as part of the school budget
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Budgets ‒ School Activity Funds (Continued) District finance officer and superintendent will submit all school budgets by the end of May to the local board for approval Budgets shall include estimated beginning balances; anticipated receipts (all sources) and expenditures by category and estimated ending balances Local board approval of school activity budgets/activities done by end of May for the following year
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Financial Reporting Proper segregation of duties should be maintained on a regular basis – examples provided in Appendix A of the Redbook Prior year ending balance should be the beginning balances for the next year Activities with a restricted purpose should be in a separate activity fund Excessive balances should not be carried forward year to year Principal or designee shall review monthly balances for excessive amounts and should not allow fund-raiser for those activity funds until they have been reduced
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Financial Reporting (Continued) Treasurer shall prepare monthly report and annual report including listing of accounts receivable and payable, reviewed and signed by principal, send to central office (Forms F-SA-15A, F-SA-15B) Bank statement must be reviewed by principal and treasurer monthly Reports prepared by treasurer and reviewed by principal then forwarded to the district finance officer Monthly/Annual AFR and accounts receivables and accounts payables (Forms F- SA-15A/B) annual due July 25 List of receipts and expenditures List of journal adjustments List of transfers List of non-employee payments (annual) List of donations (annual)
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Financial Reporting (Continued) Each club/organization sponsor shall receive a copy of monthly reports (Forms F-SA-15A and F-SA-12) No school activity fund shall end the year with a deficit balance including receivables and payables (general account will need to reimburse to remove the deficit) CPA must audit school activity fund annually with a copy of report left at school Retain financial records for three years
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External Support/Booster Organizations Definition ‒ Organizations established by parents/adults to promote school programs, student groups or student activities Raise funds through board approved activities on and off school property in the name of the school or school activity and maintain funds in a separate bank account Actions that MUST be carried out by external support/booster organizations: MUST receive local board approval to establish and operate in the name of the district or any affiliation of the district’s schools or students MUST be a separate legal entity (corporation, LLC, Association, etc.) MUST follow IRS and Title IX guidelines MUST have Federal Employer Identification Number (FEIN) MUST not use the district’s or school’s FEIN or state tax-exempt number MUST have external bank account
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External Support/Booster Organizations (Continued) MUST submit FEIN and names of officers to principal (normally at the beginning of the school year) MUST carry insurance for general liability MUST submit fund-raisers for approval and benefit the group as a whole MUST ensure funds are expended in accordance with fund-raiser approval form MUST use tickets in fund-raising involving stations (fall festivals) MUST not require participation in fund-raisers if tax-exempt status is obtained MUST submit budget worksheet to the principal (normally within the first 30 days of the school year) MUST submit the annual financial report to the principal by July 15 MUST report expenditures to the principal annually for Title IX by July 15
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External Support/Booster Organizations (Continued) Other general guidelines of external support/booster organizations: Generally fund-raising efforts carried out by parents/adults Obtain state tax-exempt number if exempt status obtained District employees may serve as general members or officer Local board members may only serve as a general member Neither district employees nor local board members may serve as treasurer or any officer with check-signing authority District employees cannot order or receive goods, nor receipt or disburse cash and district employees are not allowed to have access to the funds School activity funds cannot reimburse for purchases Cannot pay directly for referees or officials of athletic events or pay/enhance salaries/stipends for any district employee
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External Support/Booster Organizations (Continued) Purchases on behalf of the school or school activity becomes district property To safeguard cash, officers with check-signing authority should be bonded Individuals not participating in a fund-raiser cannot be excluded from the benefits of the fund-raiser nor penalized in any way Students may handle funds during a fund-raiser Funds may be donated directly to the school for the school activity or paid directly by the support/booster organization
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External Support/Booster Organizations (Continued) External Support/Boosters Organizations ‒ Structure and Governance considerations: Form a legal entity to serve as an umbrella entity for all external support/ booster organizations Depending on the size of the district, more than one entity may need to be formed to make the operations of the umbrella entity more feasible Adopt by-laws for the umbrella entity so governance is established Obtain FEIN and file for exempt status with the IRS 501(c)(3) Once exempt status is obtained, file for state exempt status and register with the State of Kentucky
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External Support/Booster Organizations (Continued) Create an accounting system to capture the cash activity by receipts and expenditures and changes in cash balances to be used in tax return filings File annual informational tax return (Form 990) with the IRS and a copy to the Attorney General of Kentucky (required if contributions solicited) Cost to be shared by all groups in the umbrella entity One-time upfront cost to establish the entity and obtain exempt status Recurring cost for IRS tax filing and Secretary of State (corporation, LLC) annual fee External support/booster organizations are solely responsible for their compliance with all external policies and regulations (Federal, State and district regulations/policies and procedures)
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External Support/Booster Organizations (Continued) The school may disassociate with any external support/booster organization that does not comply with the applicable sections of the Redbook The school or district, with the approval of the local board of education, may establish ADDITIONAL guidelines/requirements for support/booster organizations Appendix C of the Redbook has additional resources in assisting external support/booster organizations
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Frequently Asked Questions (FAQ) Updated August 1, 2015 Common terms/Definitions School activity funds (student/district activity funds) Previous questions of prior FAQ’s unchanged Responses to previous FAQ’s have been modified and/or changed FAQs have been revised so the do not conflict with Red Book FAQs are to provide clarity in certain areas of the Red Book
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Lanny White, CPA Partner Carr, Riggs & Ingram, LLC 922 State Street Bowling Green, KY 42101 (270) 782-0700 lwhite@cricpa.com www.cricpa.com
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