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GASB No 39, Determining whether Certain Organizations Are Component Units, amended GASB No 14 to accord component unit status to legally separate category (c) nonpro t organizations that meet certain criteria that signify a relationship of such nature and signi cance that inclusion in the governmental reporting entity is required The application of those criteria to situations involving foundations related to governmental HCOs are as follows:
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Direct bene t The economic resources received or held by the foundation are entirely or
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almost entirely for the direct bene t of the health care organization or its component units
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Entitlement/ability to otherwise access The health care organization or its component units
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are entitled to, or have the ability to otherwise access, a majority of the economic resources received or held by the foundation The ability to otherwise access is not meant to imply or require that the health care organization has control over the foundation or its resources Rather, it is a broader concept that may be demonstrated in several ways, for example: The health care organization or its component units historically may have received (directly or indirectly) a majority of the economic resources provided by the foundation The foundation previously may have received and honored requests to provide resources to the health care organization The foundation is nancially interrelated with the health care organization under FASB Statement No 13616 Signi cance The resources of the foundation to which the health care organization or its component units are entitled/have the ability to otherwise access are signi cant to the health care organization
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When all three of these criteria are met, a foundation is deemed to be a component unit of the health care organization s reporting entity If one or more of the criteria are not met, the foundation may still need to be evaluated for inclusion as a component unit under the misleading to exclude standard described in paragraph 41 of GASB No 1417 When a foundation is deemed to be a component unit under GASB No 39, the nature of its relationship with the health care organization is different from the relationship the health care organization may have with component units that are directly associated with it through the board appointment process or scal dependency The GASB concluded that the special nature of this relationship could best be communicated to users of the nancial statements through discrete presentation of the foundation s nancial data in the health care organization s nancial statements Typically, discrete presentation involves displaying the component unit nancial data as a separate column (or columns) in a side-by-side presentation with the nancial data of the primary government However, the nancial statements of foundations that are includable under the new GASB No 39 criteria are prepared in accordance with FASB standards, rather than GASB standards In such situations, the foundation s statements may be presented on separate pages (eg, the foundation s balance sheet is presented on the page following the health care organization s balance sheet, the foundation s operating statement is presented on the page following the health care
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16 Foundations that are not nancially interrelated with their bene ciary organizations act in an agency capacity when they receive contributions designated for those bene ciaries Relationships between these foundations and their af liated health care organizations must also be evaluated for inclusion as component units under the three criteria; the only difference is that there is no presumption based on FAS No 136 that the health care organization has an ability to otherwise access in these relationships 17 Typically, this evaluation is based on how closely related the foundation is to the entity it supports GASB No 39 emphasizes that closely related organizations should include those that are nancially integrated with the primary government in such ways as one entity providing of ce space and administrative services to the other or participation by employees of the primary government in program activities of the foundation (among others) According to paragraph 6 of GASB No 39, nancial integration may be exhibited and documented through the policies, practices, or organization documents of either the primary government or the foundation
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