23Deferred Revenue Accounting

DETC OCCASIONAL PAPER 23Deferred Revenue Accounting

DETC OCCASIONAL PAPER NUMBER 23 Deferred Revenue Accounting by Mr. Walter Miller, CPA, Director of Finance, College of the Humanities and Sciences Harrison Middleton University Published by the Distance Education and Training Council 1601 18th Street, NW, Washington, D.C.20009 202-234-5100; fax: 202-332-1386; www.detc.org July 2005 DETC OCCASIONAL PAPERS are essays intended to stimulate and encourage candid exchanges of ideas between distance study professionals. For a complete set of Occasional Papers, write or call the DETC.

Introduction The Accreditation Standards of the DETC require that an institution be financially able to deliver high quality instruction and educational services. 1 When evaluating this standard, the Accrediting Commission uses comparative financial statements from the institution prepared using the accrual method of accounting in conformity with generally accepted accounting principles. One specific area evaluated in the Self- Evaluation Report (SER) is the reserves kept for honoring future service obligations, bad debts, and refunds. 2 Reserves When dealing with reserves, financial statements presented according to generally accepted accounting principles (GAAP), and demonstrated operations, you encounter several elements that need to be addressed. These elements have a financial statement impact and, for those schools which are for-profit, an income tax impact. These elements are: Reserve for bad debts this is an estimated amount of the school s accounts receivable (usually tuition) that will not be received in the future. Actual bad debts these are the actual accounts receivable that the school has determined will not be paid and have no further remedies that will or can be pursued for collection. Reserve for unearned income this represents the amount of tuition the student has paid or signed a contract for which the school has not earned the right to keep. Refund reserve this represents the obligation the school has to repay money received from a student calculated on the DETC minimum standards. 1

Reserve for future services this represents an estimate of the cost to provide services the school is contractually obligated to perform based on tuition that has been received and is not subject to refund. Accrual of tuition income this represents services that have been provided to students but have not been paid by the students. Accrual of expenses this represents expenses that have been incurred for services to students where the expenses have not been paid. In order to demonstrate that it has a sound and financially responsible operation, an institution accredited by the DETC must adequately address each of the items above. Reserve Treatment A typical accounting transaction for tuition could follow two basic paths: 1. A student enrolls and pays the full tuition in full ( up front ) for the course or program. 2. A student enrolls and enters into a contractual agreement to pay the tuition over a period of time, usually several months. There is usually a down payment required and interest is charged on the outstanding balance owed. The accounting treatment for the first pattern would be to record the receipt of cash as an asset and the balancing entry would be to reserve for unearned income, a liability account. As lessons/courses are submitted for school servicing, income from services would be recorded by reducing the reserve for unearned income and increasing income. 2

When the entire course has been completed, i.e., when the last required assignment has been submitted to the school by the student, all the tuition would be included in income and the associated liability would be zero. Using this method would provide an adequate reserve/liability for refunds required under the DETC Accreditation Standards, and no reserve for future services would be required. Balance Sheet: An Illustration Assets Cash $1,000 Liabilities Reserve for unearned income $1,000 First lesson completed -100 All lessons completed -900 0 Income Statement Tuition income First lesson completed 100 Tuition income All lessons completed 900 1,000 The reserve for unearned revenue may also be eliminated by the expiration of the contract. The use of a fixed contractual term for each student enrollment is allowed by DETC standards. This contractual term must be of sufficient duration to allow a typical student to complete the course/program within that period. Institutions should be able to prove that a clear majority of students complete the course/ program well within any term period. The expiration of the contract term would allow the school to include in income all tuition that had been received and eliminate any related reserve for unearned income on that contract. As the expiration of the contract terminates the obligation 3

for future services to the student, no liability would need to be recorder for future services. Under the second pattern, the school would record the down payment as an increase in the asset cash, the tuition receivable as an asset (if the period the receivable is payable over more than twelve months, it would be split between a current and a long term asset), and an off-setting liability reserve for unearned income. The income recognition would follow the first pattern with a supplemental evaluation of the collectibility of the tuition receivable. The collectibiltiy of receivables must be reviewed periodically. This evaluation would result in the establishment of a reserve for bad debts. The offset to the reserve for bad debts is a bad debt expense on the income statement. This reserve can be established based on historical analysis of collectibility of accounts and/or actual analysis of the existing receivables. As any tuition receivable is deemed to be uncollectable, the amount should be written off. To write off tuition receivables, the school would reduce the accounts receivable asset and reduce the allowance for bad debts. This may also require an adjustment to the reserve for unearned income. If the income related to the receivable had not been included in income, then the offset to the receivable would involve the reduction of the reserve for unearned income. 4

Balance Sheet Assets Cash $100 Payment on accounts receivable 100 Payment on accounts receivable 500 $700 Accounts receivable 900 Payment on accounts receivable -100 Payment on accounts receivable -500 $300 Reserve for bad debts -300 Liabilities Reserve for unearned income 1,000 First lesson completed -100 All lessons completed -900 0 Income Statement Tuition income First lesson completed 100 Tuition income All lessons completed 900 1,000 Bad debts -300 Net income $700 5

Alternative Reserve Treatment Some schools may record the entire tuition as income when received or when a contract is signed. Schools using this approach would be required to establish reserves for refunds and reserves for future service obligations. The reserve for refunds should be calculated based on the DETC minimum tuition refund policies for all existing students. This requires an analysis of the number of courses/lessons completed to determine the school s financial obligation to the students. When the refund reserve is established, income would be reduced by the same amount. Even though the school does not have an obligation to refund tuition, it may have an obligation to provide services to the student. This obligation reserve for future services should reflect the anticipated cost to provide the educational elements to the student. This reserve creates a liability on the balance sheet and an expense on the income statement. If the school uses a reasonably and justifiable fixed contract term, both of the above reserves would be reduced to zero at the end of the term contract period. Use of the alternative reserve method should be done with caution, as a standard accounting principle is to match income and expense to the period in which the income is earned. If a school s contractual obligation with a student is greater than twelve months, the alternative method could overstate current period income. For example, a student enrolls in a four year bachelors degree program for $20,000. The student completes half of the program by the end of year two, and pursuant to DETC guidelines, is no longer entitled to a refund. The school would take $10,000 into income in that year (the amount that 6

was previously treated as a refund reserve), and set up a reserve for future services to offset that income. This net of the two items would be the net income for that student s remaining involvement with the school. Then, for the next two years allotted to the provisions of services, the school would show no income or expense. For illustration, assume the amount for future services is $5,000 and there are 100 students in that situation. The school in year two would include $500,000 ($10,000 5,000 = $5,000; $5,000 * 100 = $500,000) in net income for year two and nothing in years three and four. In today s tumultuous accounting environment, schools should use conservative accounting practices in dealing with income recognition and reserves. Income Tax Issues Unfortunately for for-profit schools, the tax treatment of income and reserves is significantly different than the financial statement treatment. The Internal Revenue Code requires the inclusion in income of any cash received that does not have a contractual obligation to be repaid. The Code also does not allow the deduction of reserves from income. It only allows the deduction of actual incurred expenses. In the example at the end of the last section, the tax result would be taxable income of $1,000,000 ($10,000 per student no longer required to be repaid times 100 students). Summary DETC s continued stature as a nationally recognized accrediting association hinges on its accredited institutions maintaining a high level of financial responsibility, and running a sound and ethical operation. The proper and conservative handling of reserves has a significant 7

impact on demonstrating the school s ability to be financially able to deliver high quality instruction and educational services. Notes Accounting standards and the tax laws are constantly changing. The information included in this DETC Occasional Paper is for general guidance only, and is based on DETC standards, accounting standards, and tax laws in effect on May 31, 2005. Each institution should consult its own qualified legal, accounting, and tax professionals for guidance in their unique situations. 8

Appendix 1 Footnote 1: (Accreditation Standard X) X. FINANCIAL RESPONSIBILITY (The institution is financially able to deliver high quality instruction and educational services.) A. Financial Practices The institution shows, by complete, comparative financial statements covering its two most recent fiscal years, that it is financially responsible and that it can meet its financial obligations to provide instruction and service to its students. (Financial statements must be prepared in conformity with generally accepted accounting principles. ) B. Demonstrated Operation In all respects, all institutions must document continuous sound and ethical operations. Applicant institutions must document two* continuous years of sound and ethical operation as a bona fide electronically-delivered, online or other delivery method of distance study (*one year if the parent company is accredited by another accrediting agency that is recognized by either the U.S. Department of Education or the Council for Higher Education Accreditation). This documentation shall show that the name being used by the school is free from any association with activity that could damage the standing of the accrediting process, such as illegal actions, unethical conduct, or abuse of consumers. Footnote 2: IX.A. 6. Describe what reserves are kept for honoring future service obligations, bad debts, and refunds. 9

Appendix 2 Under DETC s D.1. - Examiner s Rating Form for All Institutions, under Standard IX. Financial Responsibilities, you should be able to answer Yes to the following questions. IX. A. Financial Practices 1. Do the institution s financial statements demonstrate overall financial responsibility or does the parent company guarantee financial stability? a. Are the financial statements complete? b. Are all notes and supplementary schedules to statements included? c. Do the statements include an income statement, balance sheet, statement of cash flows, and explanatory notes? d. Did the institution provide detailed operating statements for institution divisions? e. Are the statements prepared using the accrual method of accounting? 2. Did the institution submit a properly executed copy of the appropriate Teach- Out Commitment form? 3. Does the institution use an adequate budget-making process? 4. Are current assets sufficient to meet current liabilities? 5. Did the institution answer No to the question, Has the institution ever entered into bankruptcy? 6. Are the reserves for honoring future obligations, bad debts accurate, and refunds adequate? 7. Do the accounts payable (numbers, amounts, and age) reflect sound financial responsibility and management? 8. Are inventories of course materials adequate for current and future servicing requirements? 9. Does the institution have adequate insurance coverage, and is it properly allocated? 10

10.For an institution with resident training program(s), is there adequate liability coverage for students at resident training sites? IX. B. Demonstrated Operation 1. Has the institution documented at least two continuous years* of experience as a distance education institution (with the period starting with the date of the first enrollment)? (*one year if the institution or its parent is accredited by another recognized accrediting agency.) 2. Has the institution (or parent company) demonstrated sound financial responsibility and ethical operation for the preceding two years? 3. Has the institution presented the proper documentation proving it is approved or licensed as appropriate? 4. Has the institution documented that the name being used by the institution is free from any association with activity that could damage the standing of the accrediting process? 5. Does the institution offer instruction that is predominately at a distance? 6. Degree Program(s): Can the institution document that it has a completely developed curriculum with at least one academic degree program in which students have been enrolled for a minimum of two years (one year if parent company is accredited by another recognized accrediting agency)? 11

Appendix 3 H.2. Policy on Commission-Requested Financial Statements When the Accrediting Commission requests a financial statement from an accredited or applicant institution, the financial statement must be prepared in conformity with generally accepted accounting principles, often referred to as GAAP. This includes the use of accrual method of accounting. The Commission has the option of requesting one of these two types of financial statements: 1. An audited financial statement certified by an outside, independent, certified public accountant in accordance with standards established by the American Institute of Certified Public Accountants. 2. A reviewed financial statement. A reviewed financial statement consists of inquiries of institution management by an outside, independent, certified public accountant and includes analytical procedures applied to financial data. It is less in scope than an audited statement and does not have an opinion regarding the financial statements. The accountant must, however, state that he or she is not aware of any material modifications that would need to be made to the statements in order for them to be in conformity with standards established by the American Institute of Certified Public Accountants. All financial statements should cover the activities of the legal entity that has the responsibility for operating the accredited distance education institution. Minimum Acceptable Financial Statements At a minimum, the financial statements (audited or reviewed) must be comprised of: A. A Comparative Statement, which displays the most recent two fiscal years of financial data, preferably in side-by-side columns. B. Balance Sheet, reflecting assets, liabilities, equity, and retained earnings; 12

C. Income Statement, reflecting revenues, expenses, and profits and losses; D. Statement of Cash Flows, reflecting the sources and uses of working capital; and E. Explanatory Notes, which reflect all of the disclosures or footnotes required by generally accepted accounting principles. These statements must be as of the date of the institution s most recently ended fiscal year or a date otherwise specified by the Accrediting Commission. Letter of Financial Statement Validation This letter must accompany an institution s financial statements when submitted as an exhibit with a Self-Evaluation Report, or anytime when the Accrediting Commission calls for a financial statement from an institution, or when an institution s Annual Report submission requires a financial statement (e.g., when there s a loss is reported). December 30, 2005 Mr. Michael P. Lambert, Executive Director Distance Education and Training Council 1601 18 th Street, NW Washington, DC 20009 Dear Mr. Lambert: As a certifying officer, I acknowledge my responsibilities for establishing and maintaining controls and procedures that ensure that I am aware of material information relating to [name of institution]. The attached report discloses (a) all material weaknesses in internal controls that came to the attention of certifying officers, (b) any fraud involving management or employees with significant responsibilities, and (c) any significant changes in internal controls, including actions to correct material weaknesses, during the period covered by this report. 13

I have reviewed this report. Based on my knowledge: (1) This report contains all the facts needed to prevent it from being misleading and it contains no untrue statements; (2) Financial statements and other information fairly present the financial condition, results of operations and cash flow. Certified by: Chief Executive Officer: Chief Financial Officer: 14

Other Occasional Papers Available Number 1 Student Services: Achilles Heel or Crown Jewel? by Michael P. Lambert, Executive Director, DETC Number 2 What Manager Doesn t Study at Home? by Dr. Gordon Wills, Principal, The International Management Centres Number 3 Toward Better Service and Testing by Dennis Foltz, Vice President of Education and Operations, Gemological Institute of America Number 4 Testing Home Study Advertising by Jack Thompson, Consultant Number 5 Conducting Graduate Surveys by Mary McKeown, Vice President, American School Number 6 Enrollment Contracts for Home Study Schools by William Wright, American School Number 7 Evaluating Your School s Worth by Michael P. Lambert, Executive Director, DETC Number 8 Getting the Most PR for Your School by Sally R. Welch, Assistant Director, DETC Number 9 The Effectiveness of the Home Study Method edited by Sally R. Welch, Assistant Director, DETC 15

Number 10 Home Study Academic Transcripts by Sally R. Welch, Assistant Director, DETC Number 11 Admissions Policies: The Key to Success by Josephine L. Ferguson, Member, DETC Accrediting Commission Number 12 How to Write an Analytical Self-Evaluation Report by Josephine L. Ferguson, Member, Accrediting Commission of the DETC Number 13 Building a Distance Education Faculty by Dr. John E. Jessup, Academic Dean, American Military University Number 14 Embracing the Internet by Carol Oliver and Dr. Gordon Wills, International Management Centres Number 15 Strategies for Helping Students Transfer Credits by Ali Fares, Cleveland Institute of Electronics Number 16 How to Develop a Plan of Succession by Robert McKim Norris, Jr., Andrew Jackson University Number 17 How to Assess Experiential Learning by Lisa J. Davis, California College for Health Sciences Number 18 Managing Education Programs in the Information Age by Tina J. Parscal, ISIM University Number 19 Converting Courses to Online by Dr. Judith M. Smith, SiteTrainer.com. 16

Number 20 Confessions of an Early Internet Educator by Jack R. Goetz, Concord University School of Law Number 21 Global Activities of DETC Institutions by Irving H. Buchen, IMPAC University Number 22 International Academic Equivalence: A Primer by Irving H. Buchen, IMPAC University and David John Le Cornu, St. Clements University

DISTANCE EDUCATION AND TRAINING COUNCIL 1601 18TH STREET, N.W. WASHINGTON, D.C. 20009-2529 (202) 234-5100 http://www.detc.org E-Mail: detc@detc.org