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In a special meeting, the Governmental Accounting Standards Board (GASB) addressed questions raised by governmental entities as a result of coronavirus shutdowns and relief programs under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The result was a proposed Technical Bulletin (TB), Accounting and Financial Reporting Issues Related to the Coronavirus Aid, Relief, and Economic Security Act of 2020 and Coronavirus Disease, issued on June 11 with a two-week comment period. GASB will meet when the comment period closes on June 25 and plans to issue the TB in final form by June 30. Guidance in the TB would be effective immediately.

Under guidance in the proposal, Higher Education Emergency Relief funds (HEERF) are considered voluntary non-exchange transactions, and revenue would be recognized when eligibility requirements are met. These funds and other similar relief funds would be reported as non-operating revenue, unless a public university health-care provider receives Provider Relief Funds that constitute payment for services. NACUBO’s Accounting Tutorial on HEERF Funds, Cares Act Grant Accounting, parallels GASB’s proposed guidance and provides additional information.

GASB also states in the draft TB that expenses and losses related to the coronavirus response are not extraordinary items; because governments have previously responded to novel virusessuch events are neither unusual nor infrequent.

Overall, the proposal addresses the timing of revenue recognition for various CARES Act grants, operating and non-operating reporting, loan reporting and disclosure requirements under the Paycheck Protection Program, loss of revenue, extraordinary items and subsequent events.

The TB is in Q&A format, and GASB draws from guidance in Statements 9, 33, 34, 56, 62, and 70 in formulating its answers.

Comments to GASB are due by June 25. NACUBO encourages public institutions to comment directly or to contact us to have your concerns conveyed in our comment letter.


Sue Menditto

Senior Director, Accounting Policy


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