Skip to content Menu

NACUBO's Accounting Principles Council (APC) are volunteers from public and private institutions with exceptional knowledge and skills in external financial reporting, internal operations, managerial analysis, and stakeholder communication.

Work in Process Matrix

APC activities and projects: December 2021

November 10 Meeting with GASB Chair and Staff

Topics include majority equity interests, lessor income as operating or non-operating, fiduciary activities, revenue and expense recognition, capital assets.

Issues Paper and Nov 10 meeting discussion

June 4 Meeting with Several AICPA GAQC Representatives

Meeting Summary: Status of the OMB Compliance Supplement, Department of Education's request for audit sampling changes in the 2021 Compliance Supplement (NACUBO / NASFAA letter to FSA), and suggested SEFA guidance were reviewed.

Tuition Discounting Project for Public Institutions


In April 2021 NACUBO issued a proposed Advisory Report, Accounting and Reporting Financial Aid as a Discount to Tuition and Other Fee Revenues, that would update examples and consolidate decades old guidance for both public and independent institutions. However, because all public institutions currently use the "Alternate Method" for estimating tuition and residential services discounts as well as scholarship expense attributable to excess aid of student charges under Advisory Report 2000-05, guidance was issued as a draft to solicit feedback from public institutions.

Why New Guidance is Being Proposed for Public Institutions

In brief, the Alternate Method is an estimate that calculates scholarship expense first and uses the difference between total aid and estimated scholarship expense as the discount. The derived discount is then pro-rated between tuition and residential services based on institutional charges.

Assumptions used to calculate scholarship expense treat all student refund sources equally, thus overstating the expense. The overstated expense undervalues the total discount. The discount is further distorted by an allocation between tuition and residential services based on relative institutional charges. Because less than a significant portion of students receive grants for housing, the discount attributable to tuition is understated and the amount allocated to housing is overstated.

GASB's revenue and expense project is proposing that contractual arrangements with customers (students) drive revenue that is recognized for unique performance obligations. Education and housing are distinct services with distinct performance obligations. In the future, tuition revenue and residential services revenue will need to agree with underlying contractual arrangements with students.

Project Progress

Several public institutions commented and expressed concern. A work group with those institutions has been formed.

Meeting minutes:


FASB's Business Combination Project

  • The objective is to improve the accounting for asset acquisitions and business combinations by narrowing the differences between the recognition of assets and businesses
  • The project was introduced to FASB's Not-for-Profit Advisory Committee in March, 2021
  • NACUBO's APC will be reviewing current GAAP in tandem with the AICPAs NFP Expert Panel



Related Content

Department of Education Encourages Using HEERF for Mental Health Needs

During Mental Health Awareness Month, the Department of Education released an FAQ that strongly encourages institutions to use HEERF funds to meet mental health and substance abuse disorder needs of students. Additional information can be found at NACUBO’s HEERF Resource Center.

GASB Releases Statement 100 on Accounting Changes and Error Corrections

The new standard defines four categories of accounting changes and error corrections and related accounting and financial reporting requirements and is effective in FY24 (with earlier application encouraged).

GASB Releases Statement 101 on Compensated Absences

In an effort to bring all types of compensated absences under a unified model, the Governmental Accounting Standards Board recently issued Statement No. 101, Compensated Absences. The new guidance will lead to recognition of a liability in more circumstances, most notably for nonvested sick leave.