TLDR
Federal grant reporting requires accrual-basis financial data, even when an organization maintains its internal books on a cash basis. The SF-425 Federal Financial Report captures accrued expenditures — costs incurred but not yet paid — not just cash disbursements. Nonprofits that maintain cash books must perform a reconciliation to accrual at each reporting period. Auditors will test the reconciliation. Discrepancies between cash books and accrual FFR submissions are one of the more reliable indicators of accounting control weaknesses in single audits.
BLUF
Federal grants require accrual-basis accounting under 2 CFR 200.302 and FASB ASC 958. The SF-425 Federal Financial Report captures accrued expenditures — costs incurred but not yet paid — separately from cash disbursements. Organizations that maintain cash-basis books must convert to accrual at each reporting date. This conversion is where many single audit findings originate: the reconciliation is either missing, undocumented, or wrong.
TL;DR
- Required basis: accrual for all federal grant reporting, GAAP financial statements, and Form 990
- Key difference: accrual recognizes expenses when incurred; cash recognizes when paid
- FFR Block 10e: captures accrued expenditures — must include unpaid invoices
- Cash-basis organizations: must produce a reconciliation to accrual for each FFR submission
- Most common error: reporting only cash disbursements on an accrual-required form
Why federal grants require accrual
Federal grant reporting under 2 CFR 200.302 requires that accounting records permit tracing of funds to the level of expenditure needed to demonstrate compliance with grant conditions. Cash-basis records fail this standard when there are unpaid vendor invoices, outstanding payroll, or incurred-but-unreimbursed costs at any period end.
The SF-425 Federal Financial Report makes the accrual requirement concrete. Block 10d asks for “Total Federal share of unliquidated obligations” — a term for committed but unspent amounts. Block 10e asks for “Total federal share of expenditures” — which includes both paid and accrued costs. A cash-basis organization submitting only cash disbursements in Block 10e is underreporting federal expenditures.
The FASB ASC 958 GAAP requirement
FASB ASC 958, Not-for-Profit Entities, is the accounting standard that governs nonprofit financial statements in the United States. It requires:
- Accrual basis accounting for all revenue and expense recognition
- Net asset classification in two categories: with and without donor restrictions
- Revenue recognition for grants based on whether they are conditional or unconditional
The accrual requirement means that a nonprofit’s audited financial statements cannot be prepared on a cash basis. Organizations that maintain internal books on a cash basis produce two sets of records: the cash books for internal management and an accrual conversion for the auditors and for Form 990 preparation.
This dual-maintenance approach works but creates reconciliation risk. If the conversion is performed annually only at audit time, the accrual records are never tested during the year and errors accumulate.
Grant revenue recognition: the accrual details
Under FASB ASC 958-605, grant revenue recognition depends on the nature of the grant:
Unconditional, purpose-restricted grants — recognized as restricted revenue when the grant agreement is executed. The cash may not arrive until months later, but the revenue accrues at the point of an enforceable right.
Conditional grants — recognized as revenue when conditions are substantially met. An advance payment on a conditional grant is deferred revenue (liability) until conditions are overcome.
Government grants — often structured as exchange transactions (fees for services) rather than contributions. ASC 606 may apply rather than ASC 958-605, depending on the facts. This distinction affects when revenue is recognized and how it is classified.
The choice between these models is not optional — the grant agreement’s terms govern. Getting this wrong produces revenue overstatement (recording conditional grants as unconditional) or understatement (deferring unconditional grants that should be recognized immediately).
Converting cash-basis books to accrual for FFR reporting
An organization that maintains cash-basis general ledger accounts must perform the following adjustments at each FFR reporting date:
-
Identify unpaid vendor invoices. Invoices received and approved but not yet paid represent accounts payable — accrued expenditures under accrual basis. Add these to reported expenditures.
-
Identify accrued payroll. If a pay period crosses the reporting date, the earned but unpaid wages belong in accrued expenditures. Calculate the proration.
-
Identify grant receivables. Costs incurred and reportable to the funder but not yet submitted for reimbursement represent a grant receivable. Under accrual, these costs are expenditures in the current period even if the cash has not been requested.
-
Identify deferred revenue. Cash advances received for conditional grants should not be included in accrual-basis revenue until conditions are met. Remove any cash received for unearned conditional grants from reported revenue.
-
Document the reconciliation. The adjustments must be documented in a worksheet that ties cash-basis totals to accrual-basis totals. This worksheet is audit evidence.
Why the FFR is the audit test
When auditors review an organization’s federal grant reporting, they will compare the cumulative expenditures on the FFR against the general ledger. If the organization uses accrual books, this comparison is straightforward. If the organization uses cash books and submitted FFRs on an accrual basis, the auditors will request the reconciliation worksheet to verify the conversion.
Missing reconciliation worksheets suggest the FFR was not properly derived from accrual-adjusted figures. If the FFR appears to match cash disbursements exactly (no accrued expenditures ever appear), auditors will question whether accrual reporting was actually performed.
QuickBooks and accounting basis configuration
QuickBooks can operate in either cash or accrual mode. Organizations using QuickBooks for grant accounting should configure the system to accrual basis. This means:
- Accounts payable is tracked and shows unpaid bills as liabilities
- Accounts receivable (including grant receivables) is tracked
- Revenue is recognized when invoiced, not when paid
- Reports can be run in either cash or accrual mode for comparison
An organization configured to cash basis in QuickBooks that is reporting to federal agencies on accrual basis is relying on manual adjustments to bridge the gap — a fragile process that auditors will flag as a control weakness.
How GrantPipe helps
GrantPipe tracks grant expenditures and receivables on an accrual basis from the point of cost entry. Costs are recorded when incurred, not when paid, and grant receivables accumulate as costs are posted against cost-reimbursement awards. When an FFR is due, accrued expenditure totals are available directly from the grant record without requiring a separate reconciliation worksheet. Start with a free trial to run accrual-basis grant accounting from the same system that tracks compliance deadlines and restricted fund balances.
Free resource
Get the Nonprofit Grant Compliance Checklist
A practical checklist for post-award grant compliance: restricted funds, reporting cadence, audit prep, and common failure points. Delivered by email.
- Accrual basis
- An accounting method that records income when earned and expenses when incurred, regardless of when cash changes hands. Required for GAAP financial statements under FASB ASC 958, for federal grant reporting under 2 CFR 200, and for Form 990 preparation.
DEFINITION
- Cash basis
- An accounting method that records income when cash is received and expenses when cash is paid. Simpler to maintain but not compliant with GAAP or federal grant reporting requirements. Some small nonprofits use cash basis for internal bookkeeping and convert to accrual for external reporting.
DEFINITION
- Accrued expenditures
- Costs that have been incurred (goods received, services rendered) but have not yet been paid. On the SF-425, accrued expenditures appear separately from cash disbursements to reflect the total cost charged to the award regardless of payment timing.
DEFINITION
- Grant receivable
- An asset recorded on the balance sheet representing costs incurred on a cost-reimbursement grant that have not yet been reimbursed by the funder. Under accrual basis, this asset is recognized at the point costs are incurred, not at the point of cash receipt.
DEFINITION
- Deferred revenue
- A liability recorded when cash is received before revenue is earned — for example, a grant advance payment for a conditional grant where the conditions have not yet been met. Under accrual basis, cash receipt does not trigger revenue recognition for conditional contributions.
DEFINITION
Q&A
How does a cash-basis organization convert to accrual for FFR reporting?
At each reporting date, the organization must identify: (1) costs incurred but not yet paid (accounts payable and accrued liabilities); (2) revenue earned but not yet received (grant receivables); and (3) cash received but not yet earned (deferred revenue). Adjusting the cash-basis totals for these items produces accrual-basis totals. The adjustments should be documented in a reconciliation worksheet retained with the FFR.
Q&A
Does using QuickBooks on a cash basis create federal grant compliance problems?
QuickBooks set to cash basis will not capture accounts payable accruals or grant receivables correctly. For organizations with federal grants, QuickBooks should be set to accrual basis — or the organization must maintain a separate accrual worksheet for reporting purposes. QuickBooks accrual basis is the appropriate configuration for any organization receiving cost-reimbursement federal awards.
Q&A
How does conditional grant recognition work in practice?
When a nonprofit receives a grant advance for a conditional grant, it records a deferred revenue liability. As qualifying costs are incurred, the deferred revenue is released to grant revenue on the statement of activities. The cash was received earlier; the revenue is recognized later when costs are incurred. This is fundamental accrual accounting applied to the condition structure of the grant.
Frequently asked