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IPEDS Adds New Pension Questions for Public Institutions

January 27, 2016

In October, the Department of Education requested an emergency clearance to gather additional information on defined benefit pension plans from public institutions during the 2015-16 Integrated Postsecondary Education Data System (IPEDS) collection process and received approval in November. The currently open IPEDS Finance Survey (for public institutions) contains questions on additional or diminished expenses, liabilities or assets, deferred inflows of resources, and deferred outflows of resources related to implementing Statement No. 68, "Financial Accounting and Reporting for Pensions" in FY15.

To help ED assess the impact of its information requirements and minimize reporting burden, there is one more opportunity to comment on the revised data collection. Although the new additional questions are currently active for the 2015-16 finance survey collection, public institutions that have completed or examined the survey questions are in the best position to provide feedback to ED.

What Has Changed in the Finance Survey?

A new screening question (Question 6) was added to the 2015-16 IPEDS Finance Survey to assess whether or not the reporting entity needs to complete the additional pension-related questions. The instructions for Question 6 are as follows:

Indicate whether or not your institution recognized additional (or decreased) pension expense, liability (or assets), and/or deferrals related to the implementation of GASB Statement 68 for Fiscal Year 2015.

Note that if your institution fits any of the following criteria, there is no direct GASB 68 impact and you should respond "No" if:

  • Your public institution does not have a defined pension benefit plan.
  • Your public institution is part of a higher education system and the system reflects the additional unfunded pension expense and liability (and does not allocate the expense and liability to the individual institutions).
  • Your institution is a branch campus that did not have pension expense and liabilities allocated to it.
  • Your institution is part of a special funding situation and additional unfunded pension expense, liability, or deferral are reported elsewhere.

When there is a "Yes" response, the institution (or system) is instructed to complete the following questions in Part M of the survey for the most recent fiscal year (reporting year pertaining to the survey)-FY15 for the vast majority of public colleges, universities, or systems:

  1. Additional (or decreased) pension expense
  2. Additional pension liability (or asset)
  3. Deferred inflows of resources
  4. Deferred outflows of resources

Although the questions appear straightforward, because Statement 68 is applied retroactively and adjusts beginning net position, NACUBO has heard that several public institutions have questioned the wording in the questions and the amounts that should be reported for FY15. To clarify, the first question is looking for increases or decreases to pension expense in FY15 as a result of Statement 68. The remaining three questions should be ending FY15 values from the FY15 audited financial statements. 

Why is this information being collected?

Last year's version of the IPEDS Finance Survey does not have specific line items or questions that would allow researchers and other users of finance survey data the ability to quantify the impact of Statement 68. For public institutions and systems that participate in their state's defined benefit plan (agent or cost sharing), or have their own plan, implementing Statement 68 will likely impact expenses, liabilities, resource deferrals, and net position. ED was concerned that Statement 68 could lead to significant swings in benefit expenses and distort both trend data and various costs-of-attendance calculations.

However, because pension expense may not be the most significant result of implementing GASB 68, ED is attempting to collect all affected financial statement elements. Because implementing Statement 68 affects beginning net position, NACUBO's comments will address clarifying the questions and instructions as summarized below:  

  • The finance survey instructions should clearly direct institutional researchers to the business office to work with those knowledgeable about the external audited financial statements of the IPEDS reporting entity and the requirements of GASB Statement 68.
  • To ensure that reporting burden is minimized, the instructions and wording should clearly indicate that amounts reported must come directly from the FY15 audited financial statements (Face of the Statement of Net Position or Notes):
    • Pension liability (or asset) should be an ending balance.
    • Deferred inflows of resources (pension related) should be an ending balance.
    • Deferred outflows of resources (pension related) should be an ending balance.
  • The additional (or decreased) pension expense is a reporting period amount. As such, the instructions should clearly acknowledge that any Statement 68-related unfunded period cost or recovery would be reported in the notes to the financial statements or is derived based on knowledge of GASB 68 entries.
  • NACUBO believes that the cumulative impact on net position (as a result of implementing Statement 68) should have been a separate question, if ED considers the amount important. However, because adjustments to the beginning net position balance (a calculated value on Schedule D) will likely be predominantly caused by implementing Statement 68, if adjusted values are significant, ED can consider verifying the cumulative impact of implementing Statement 68 or add an additional question to the 2016-17 collection.
  • All of the above suggestions should be used if ED wants to gather information on other post-employment benefits in a future collection, as a result of implementing Statement 73, "Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions."

NACUBO encourages public institutions to comment or provide feedback for inclusion in the industry comment letter.

Contact

Sue Menditto
Director, Accounting Policy
202.861.2542
E-mail