A recurring problem across Massachusetts public charities: the Form PC is filed, but the documents that must accompany it are missing or incorrect. The filing is then incomplete, and the organization does not always find out immediately.
An accurate Form PC comes first. The questions on the form deserve particular attention — several are routinely answered incorrectly, and an incorrect answer can change what else is required.
The accompanying federal filing must be included: Form 990 or Form 990-EZ, as applicable to the organization.
Financial statement requirements are tied to gross support and revenue. Under current Massachusetts guidance from the Attorney General's Non-Profit Organizations/Public Charities Division, a review by an independent certified public accountant is required when gross support and revenue exceed $500,000, and an audit is required when gross support and revenue exceed $1 million. These thresholds were raised from earlier levels; any published figures from prior years should not be relied on.
Organizations expending federal awards above the applicable Uniform Guidance threshold have a separate federal single audit requirement. The current terminology is Uniform Guidance (2 CFR Part 200); references to 'A-133' describe a superseded circular. The federal expenditure threshold has also changed in recent years and should be confirmed against the current Uniform Guidance text for the fiscal year in question.
Failure to comply matters. An organization that has not filed completely for a period of years places its standing in the Commonwealth at risk, and the process of rectifying it can be both expensive and lengthy.
Editorial noteThresholds cite current Massachusetts AGO guidance (mass.gov: Audits and reviews for charitable organizations). Confirm the federal Uniform Guidance single audit threshold and date-stamp this page before publication.
This article is general information for nonprofit leaders and is not legal, accounting or tax advice. Requirements change; confirm current guidance for your organization's fiscal year before acting.
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