Form 990 Part IX
Part IX
Statement of Functional Expenses
Section 501(c)(3) and 501(c)(4) organizations must complete all columns. All other organizations must complete column (A).
Do not include amounts reported on lines 6b, 7b, 8b, 9b, and 10b of Part VIII.
Use the organization’s normal accounting method to complete this section. If the organization’s accounting system doesn’t allocate expenses, the organization can use any reasonable method of allocation. The organization must report amounts accurately and document the method of allocation in its records. Report any expense described on lines 1–23 on the appropriate line; don’t report such expense on line 24. Don’t report in Part IX expenses that must be reported on line 6b, 7b, 8b, 9b, or 10b in Part VIII.
Column (A)—Total § 501(c)(3) and § 501(c)(4) organizations must complete columns (A) through (D). All other organizations must complete column (A) but can complete columns (B), (C), and (D).
CAUTION!
State reporting requirements can be different from IRS reporting requirements applicable to Part IX.
Column (B)—Program Services
Program services are mainly those activities that further the organization’s exempt purposes. Fundraising expenses shouldn’t be reported as program service expenses even though one of the organization’s purposes is to solicit contributions. Include lobbying expenses in this column if the lobbying is directly related to the organization’s exempt purposes.
Example. Foundation M, an organization exempt under section 501(c)(3), has the exempt purpose of improving health care for senior citizens. Foundation M operates in State N. The legislature of State N is considering legislation to improve funding of health care for senior citizens. Foundation M lobbies state legislators in support of the legislation. Because this lobbying is directly related to Foundation M’s exempt purpose, it would be considered an exempt function expense and would be included under column (B).
Program services can also include the organization’s unrelated trade or business activities. Publishing a magazine is a program service even though the magazine contains both editorials and articles that further the organization’s exempt purpose as well as advertising, the income from which is taxable as unrelated business income.
Also include costs to secure a grant, or contract, to conduct research, produce an item, or perform a program service, if the activities are conducted to meet the grantor’s or other contracting party’s specific needs. Don’t report these costs as fundraising expenses in column (D). Costs to solicit restricted or unrestricted grants to provide services to the general public should be reported in column (D).
Column (C)—Management and General
Use column (C) to report expenses that relate to the organization’s overall operations and management, rather than to fundraising activities or program services. Overall management usually includes the salaries and expenses of the organization’s CEO and his or her staff, unless a part of their time is spent directly supervising program services or fundraising activities. In that case, their salaries and expenses should be allocated among management, fundraising, and program services.
Expenses incurred to manage investments must be reported in column (C). Lobbying expenses should be reported in this column if they don’t directly relate to the organization’s exempt purposes.
Organizations must also report the following in column (C): costs of board of directors meetings; committee meetings and staff meetings (unless they involve specific program services or fundraising activities); general legal services; accounting (including patient accounting and billing); general liability insurance; office management; auditing, human resources, and other centralized services; preparation, publication, and distribution of an annual report; and management of investments.
However, report expenses related to the production of program-related income in column (B) and expenses related to the production of rental income on Part VIII, line 6b. Rental expenses incurred for the organization’s office space or facilities are reported on line 16.
Don’t use this column to report costs of special meetings or other activities that relate to fundraising or specific program services.
Column (D)—Fundraising
Fundraising expenses are the expenses incurred in soliciting cash and noncash contributions, gifts, and grants. Report as fundraising expenses all expenses, including allocable overhead costs, incurred in (a) publicizing and conducting fundraising campaigns; and (b) soliciting bequests and grants from individuals, foundations, other organizations, or governmental units that are reported on Part VIII, line 1. This includes expenses incurred in participating in federated fundraising campaigns; preparing and distributing fundraising manuals, instructions, and other materials; and preparing to solicit or receive contributions. Report direct expenses of fundraising events on Part VIII, line 8b, rather than in Part IX, column (D). However, report indirect expenses of fundraising events, such as certain advertising expenses, in Part IX, column (D), rather than on Part VIII, line 8b.
Example. For an employee who works on fundraising 40% of the time and program management 60% of the time, an organization must allocate that employee’s salary 40% to fundraising and 60% to program service expenses. It can’t report the 100% of salary as program expenses simply because the employee spent over 50% of his time on program management.
| Line | Question | Instructions |
|---|---|---|
| Form 990 Part IX Line 1 | Grants and other assistance to domestic organizations and domestic governments. | Line 1. If the organization reported on line 1 more than $5,000 of grants or other assistance to any domestic organization or to any domestic government, the organization must complete Parts I and II of Schedule I (Form 990). Section 501(c)(21) trusts. Use line 1 to report amounts paid by the trust to:
|
| Form 990 Part IX Line 2 | Grants and other assistance to domestic individuals. | Line 2. |
| Form 990 Part IX Line 3 | Grants and other assistance to foreign organizations, foreign governments, and foreign individuals. | Line 3. |
| Form 990 Part IX Line 4 | Benefits paid to or for members | Line 4. |
| Form 990 Part IX Line 5 | Compensation of current officers, directors, trustees, and key employees | Line 5. TIP: Compensation for Part IX is reported based on the accounting method and tax year used by the organization, rather than the definitions and calendar year used to complete Part VII or Schedule J (Form 990) regarding compensation of certain officers, directors, trustees, and other employees. Note. To the extent the following examples discuss allocation of expenses in columns (B), (C), and (D), they apply only to filers required to complete those columns. |
| Form 990 Part IX Line 6 | Compensation not included above to disqualified persons (as defined under section 4958(f)(1)) and persons described in section 4958(c)(3)(B) | Line 6. Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations must report the total compensation and other distributions provided to disqualified persons and persons described in section 4958(c)(3)(B) to the extent not included on line 5. See Appendix G. Compensation includes all forms of income and other benefits earned or received from the filing organization, common paymasters, and payroll/reporting agents in return for services rendered to the filing organization, including compensation reported on Forms W-2 and 1099, pension plan contributions and accruals, and other employee benefits, but doesn’t include non-compensatory expense reimbursements or allowances. |
| Form 990 Part IX Line 7 | Other salaries and wages | Line 7. |
| Form 990 Part IX Line 8 | Pension plan accruals and contributions (include section 401(k) and 403(b) employer contributions) | Line 8. TIP: Complete Form 5500 for the organization’s plan and file it as a separate return. If the organization has more than one pension plan, complete a Form 5500 for each plan. File the form by the last day of the 7th month after the plan year ends. |
| Form 990 Part IX Line 9 | Other employee benefits | Line 9. Other employee benefits. For example, report expenses for employee events such as a picnic or holiday party on line 9. Don’t include contributions on behalf of current or former officers, directors, trustees, key employees, or other persons that were included on line 5 or 6. |
| Form 990 Part IX Line 10 | Payroll taxes | Line 10. Payroll taxes. Don’t include on line 10 taxes withheld from employees’ salaries and paid to various governmental units such as federal, state, and local income taxes and the employees’ shares of social security and Medicare taxes. Such withheld amounts are reported as compensation. |
| Form 990 Part IX Line 11 | Fees for services (nonemployees): | Line 11. Fees for services paid to nonemployees (independent contractors). |
| Form 990 Part IX Line 11a | Management | Line 11a. Management fees. |
| Form 990 Part IX Line 11b | Legal | Line 11b. Legal fees. |
| Form 990 Part IX Line 11c | Accounting | Line 11c. Accounting fees. |
| Form 990 Part IX Line 11d | Lobbying | Line 11d. Lobbying fees. |
| Form 990 Part IX Line 11e | Professional fundraising services. | Line 11e. Professional fundraising fees. |
| Form 990 Part IX Line 11f | Investment management fees | Line 11f. Investment management fees. |
| Form 990 Part IX Line 11g | Other. | Line 11g. Other fees for services. |
| Form 990 Part IX Line 12 | Advertising and promotion | Line 12. Advertising and promotion expenses. |
| Form 990 Part IX Line 13 | Office expenses | Line 13. Office expenses. |
| Form 990 Part IX Line 14 | Information technology | Line 14. Information technology. |
| Form 990 Part IX Line 15 | Royalties | Line 15. Royalties. |
| Form 990 Part IX Line 16 | Occupancy | Line 16. Occupancy. |
| Form 990 Part IX Line 17 | Travel | Line 17. Travel. |
| Form 990 Part IX Line 18 | Payments of travel or entertainment expenses for any federal, state, or local public officials | Line 18. Payments of travel or entertainment expenses for any federal, state, or local public officials. For expenditures that aren’t specifically identifiable to a particular individual, the organization can use any reasonable allocation method to estimate the cost of the expenditure to an individual. Amounts not described above can be included in the reported total amount for line 18 or can be reported on line 24. The organization is responsible for keeping records of all travel and entertainment expenses related to a government official whether orT not the expenses are reported on line 18 or line 24. |
| Form 990 Part IX Line 19 | Conferences, conventions, and meetings | Line 19. Conferences, conventions, and meetings. |
| Form 990 Part IX Line 20 | Interest | Line 20. Interest. |
| Form 990 Part IX Line 21 | Payments to affiliates | Line 21. Payments to affiliates. Payments to affiliated state or national organizations. Purchases from affiliates. Expenses for providing goods or services to affiliates.
Voluntary awards or grants to affiliates. Membership dues paid to other organizations. TIP: Properly distinguishing between payments to affiliates and grants and allocations is especially important if the organization uses Form 990 for state reporting purposes. If the organization uses Form 990 only for reporting to the IRS, payments to affiliated or national organizations that don’t represent membership dues reportable as miscellaneous expenses on line 24 can be reported on either line 21 or line 1. |
| Form 990 Part IX Line 22 | Depreciation, depletion, and amortization | Line 22. Depreciation, depletion, and amortization. |
| Form 990 Part IX Line 23 | Insurance | Line 23. Insurance. |
| Form 990 Part IX Line 24a-e | Other expenses. Itemize expenses not covered above. (List miscellaneous expenses on line 24e. If line 24e amount exceeds 10% of line 25, column (A), amount, list line 24e expenses on Schedule O.) | Line 24. Other expenses. The organization must separately report the amount, if any, of unrelated business income taxes that it paid or accrued during the tax year on line 24. |
| Form 990 Part IX Line 25 | Total functional expenses. Add lines 1 through 24e | Line 25. Total functional expenses. |
| Form 990 Part IX Line 26 | Joint costs. Complete this line only if the organization reported in column (B) joint costs from a combined educational campaign and fundraising solicitation. | Line 26. Joint costs. An organization conducts a combined educational campaign and fundraising solicitation when it solicits contributions (by mail, telephone, broadcast media, or any other means) and includes, with the solicitation, educational material or other information that furthers a bona fide non-fundraising exempt purpose of the organization. Expenses attributable to providing information regarding the organization itself, its use of past contributions, or its planned use of contributions received are fundraising expenses and must be reported in column (D). Don’t report such expenses as program service expenses in column (B). Any method of allocating joint costs between columns (B) and (D) must be reasonable under the facts and circumstances of each case. Most states with reporting requirements for charitable organizations and other organizations that solicit contributions either require or allow reporting of joint costs under AICPA SOP 98-2, now codified in FASB ASC 958-720. |
Allocating Indirect Expenses
Direct costs are expenses that can be identified specifically with an organization’s activity or project, and can be assigned to an activity or project with a high degree of accuracy. Indirect costs are costs that can’t be identified specifically with an activity or project. For example, a computer bought by a university specifically for a research project is a direct cost. In contrast, the costs of software licensing for programs that run on all the university’s computers are indirect costs.
Colleges, universities, hospitals, and other organizations that incur indirect expenses in various cost centers (such as organizational memberships, books and subscriptions, and regular telecommunications costs) can allocate and report such expenses in the following manner.
- Report the expenses of all indirect cost centers in column (C), lines 5 through 24.
- As a separate line item of line 24, enter “Allocation of [name of indirect cost center] expenses.”
- If any of the cost center’s expenses are allocated to expenses listed in Part VIII, such as the expenses attributable to fundraising events and activities, enter such expenses as a negative figure in columns (A) and (C).
- Allocate expenses to column (B) or (D) as positive amounts.
- Add the amounts in columns (B) and (D) and enter the sum as a negative offsetting amount in column (C). Don’t make any entries in column (A) for these offsetting entries.
Example. An organization reports in column (C) $50,000 of its actual management and general expenses and $100,000 of expenses of an indirect cost center that are allocable in part to other functions. The total of lines 5 through 24 of column (C) would be $150,000 before the indirect cost center allocations were made. Assume that of the $100,000 total expenses of the cost center, $10,000 was allocable to fundraising; $70,000 to various program services; $15,000 to management and general functions; and $5,000 to special events and activities. To report this in Part IX under this optional method:
- Indicate the cost center, the expenses of which are being allocated, on line 24 as “Allocation of [specify the indirect cost center] expenses”;
- Enter a decrease of $5,000 on the same line in column (A), Total expenses, representing the fundraising event expenses that were already reported in Part VIII, line 8b;
- Enter $70,000 on the same line in column (B), Program service expenses;
- Enter $10,000 on the same line in column (D), Fundraising expenses; and
- Enter a decrease of $85,000 on the same line in column (C), Management and general expenses, to represent the allocations to functional areas other than management and general.
After making these allocations, the column (C), line 25, total functional expenses would be $65,000, consisting of the $50,000 actual management and general expense amount and the $15,000 allocation of the aggregate cost center expenses to management and general.
The above is an example of a one-step allocation that shows how to report the allocation in Part IX. This reporting method would actually be more useful to avoid multiple-step allocations involving two or more cost centers. Without this optional reporting method, the total expenses of the first cost center would be allocated to the other functions and might include an allocation of part of these expenses to another cost center. The expenses of the second cost center would then be allocated to other functions and, perhaps, to other cost centers, and so on. The greater the number of these cost centers that are allocated out, the more difficult it is to preserve the object classification identity of the expenses of each cost center (for example, salaries, interest, supplies, etc.). Using the reporting method described above avoids this problem.
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Source: The content in these tools (such as definitions, questions, and instructions) is from the official IRS Instructions for Form 990, 990-PF, and related schedules and is in the public domain. For the most current official version, please visit https://www.irs.gov/forms-pubs/about-form-990
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