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In a June 24 comment letter to the Governmental Accounting Standards Board (GASB) on a proposed Technical Bulletin, Accounting and Financial Reporting Issues Related to the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of 2020 and Coronavirus Diseases, NACUBO agreed with proposed accounting and reporting related to certain provisions of the CARES Act. However, NACUBO suggested that the Paycheck Protection Loan Program is a type of voluntary non-exchange transaction and, as such, eligibility criteria used for grant accounting is a more appropriate approach than loan and financial guarantee reporting and disclosures.

More significantly, NACUBO disagreed with GASB’s interpretation that significant pandemic-related expenses cannot be reported as extraordinary items. GASB believes that novel viruses such as COVID-19 are no longer unusual. NACUBO countered that the unusual and infrequently occurring event is the global pandemic, declaration of a national emergency, and depression of the economy, rather than the appearance of a coronavirus disease.

NACUBO believes that extraordinary item presentation should be allowed. NACUBO asked that GASB either expand their notion of extraordinary items or provide examples that would qualify.


Sue Menditto

Senior Director, Accounting Policy


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