Internal Revenue Service Form 990 Review

Policy Number: 600.001.01
Approved by: Senior Staff
Effective Date:  April 2013

This policy provides the guidelines for the annual review process for Form 990, prior to filing.

Background

The Internal Revenue Service (IRS) has greatly expanded the disclosure requirements in the annual Information Return Form 990 that all nonprofit organizations are required to file annually. Schedule O of Form 990 is used to provide a narrative response for Part VI, line 11b, where a description must be provided of the processes used for board members to review Form 990. Scripps College must make Form 990 open for public inspection. However, the names and addresses of contributors or information that identifies contributors can be redacted from Schedule B to the Form 990, Schedule of Contributions.

Policy

Scripps utilizes a process for review of the IRS Form 990 Return of Organization Exempt from Income Tax that involves members of management as well as governing board members. Scripps has engaged an outside accounting firm to prepare the Form 990 using information provided by the Office of Financial Services at CUC and Institutional Advancement, Human Resources, and the Treasurer’s Offices. The Comptroller; Assistant Treasurer and Director of Budgeting; Assistant Treasurer and Director of Investments; and the Vice President of Business Affairs/Treasurer review the draft report,

After this review and any resulting changes are made, the revised draft form 990 with Schedule B, Schedule of Contributors redacted is provided to members of the Scripps Audit Committee of the Board of Trustees for questions and comments in mid-April. Once questions and comments from the Audit Committee are fielded and issues resolved, the Audit Committee accepts the Form 990 and the Form 990 with Schedule B redacted to remove personal identifying information redacted is made available to all voting members of the Board of Trustees for their review prior to filing in early May. Schedule B is available for review by members of the Board of Trustees only upon request. This process is disclosed to the IRS on Schedule O. Because of the requirements of Part VI, line 11b, Scripps College is not able to answer the question: Has the Board of Trustees reviewed the Form 990 affirmatively since they were not provided a complete Schedule B.


Policy Number: BA.600.001.01

Effective Date: April 2013