Being Transparent:

What Forms 990 on the Web Means For Nonprofits

by Linda Lampkin

National Center for Charitable Statistics

The Urban Institute

Scanned images of all IRS Forms 990 filed by public charities, an essential and widely used source of information on the sector, are now easily and instantly accessible on the Internet. The Urban Institute=s National Center for Charitable Statistics (NCCS) and Philanthropic Research, Inc. (PRI) with its GuideStar Web site have worked together on this project to create the most accessible data on the sector ever available.

The Form 990 is the information return that most 501(c)(3) charities file annually with the IRS. (Organizations with revenues of less than $25,000 or those that are religious organizations are exempt.) Although audits provide more comprehensive financial information, few not-for-profit organizations conduct or are required to conduct audits. Consequently, the Form 990 is the primary source of information about the nonprofit sector.

In addition to the scanned images, NCCS and PRI are also digitizing information from the forms to create a searchable database of over 600 fields for the over 220,000 nonprofit organizations that file Forms 990 annually. This represents a revolution in easily available data. An assessment of the quality of the data and identification of what needs to be improved are crucial first steps in improving information on the sector.

 

Why should nonprofits care about their Forms 990?

 

Why is the Form 990 so important now?

In the past, a nonprofit only had to disclose its Form 990 if a request was made in person at the nonprofit's offices, and was not even required to make a copy. New regulations, effective in June 1999, require that a 501(c) organization make copies of its three most recent Forms 990 for anyone who requests them, whether in person or by mail, fax, or e-mail. Anyone can also request a copy of a nonprofit organization's Form 1023, the IRS form used to apply for tax-exempt status. Nonprofits can avoid the photocopying requirements by posting their forms on the Internet. The material may either be posted on a nonprofit's own Web site or at another site that functions as a database of information about nonprofit organizations. (However, several requirements must be met with the posting before nonprofits can be exempt from the photocopying requirements.)

The form presents a portrait of the organization to donors and to others in the sector, including the media, policymakers, and other nonprofits. It is useful for a number of audiences.

In addition, those charged with regulating nonprofits — the IRS and the state charity officials — will have information that will allow them to focus their energies on organizations that abuse the public trust, rather than collecting documents.

 

How good is the quality of the reporting now?

Chuck McLean, Research Director of PRI, and Linda Lampkin, Manager of NCCS, recently completed an analysis of the Forms 990 of over 50,000 organizations (32,599 Form 990 filers and 18,515 Form 990-EZ filers). These forms were part of the new database created by NCCS and PRI from the scanned images from the Internal Revenue Service (IRS) starting in July 1998. All of the forms were reviewed for math and omission errors. In addition, a sample of scanned images for about 400 Form 990 and 990-EZs were reviewed for the quality of the attachments.

 

  1. Over 71 percent of the Form 990 filers completed the form with no mistakes; another 18 percent had one or two errors;
  2. Over 83 percent of the Form 990-EZ filers completed the form with no mistakes; another 11 percent had one or two errors; and
  3. The average number of errors per return was 0.77 for Forms 990 and 0.38 for Forms 990-EZ.

A direct comparison of these error rates should not be made, as Forms 990 were examined for 34 different errors versus 12 for Forms 990-EZ.

As might be expected, smaller organizations had slightly higher error rates than average. What was unexpected was the above average error rate for organizations with more than $10 million in revenue. Their combined error rate was 1.10 errors per form. Almost 50 percent of the returns of the very largest organizations (more than $50 million in revenue) had at least one error, versus 29 percent for the total group.

  1. Although both Forms 990 and 990-EZ require many attachments and explanations, full compliance is unusual. Fourteen line items were analyzed; less than 75 percent of organizations required to provide additional information actually did so.
  2. When filers did provide an attachment, often the level of detail requested by the IRS was not provided. In all but one instance (Line 8c, Column A, Net Gain or Loss from Sale of Securities), filers supplied the required detail less than half of the time.
  3. Under Part II of the Form 990, the "Statement of Functional Expenses" requires that organizations split their expenses across program services, management and general, and fundraising in various categories, but many returns have an unlikely percentage of expenses categorized as "other expenses"; a cursory review shows that, in many cases, items categorized as "other expenses" could in fact have been detailed in the categories listed on the form.

One additional check was also completed. Schedule A is a required attachment to both Forms 990 and Form 990-EZ. A review of the digitized sample found that over 13 percent of the Form 990 filers and 15 percent of the Form 990-EZ filers did not attach Schedule A.

Although it should be stressed that most of the forms examined in this study are well prepared, there are serious issues with the quality of data. Some preparers may be taking advantage of the fact that a small division of the IRS has been assigned the task of monitoring the vast tax-exempt sector. Problems that would certainly trigger an audit of a personal tax return pass unnoticed.

The new reality is that there are now millions of auditors — they include potential donors, the media, policymakers, and researchers.

 

How can the quality of the data be improved?

 

What efforts are now underway to improve reporting?

  1. National and local Nonprofit Accountability Collaboratives (990-NACs) to promote widespread discussion about nonprofit reporting and accountability;
  2. Publication of a unique financial reporting guide aligned with IRS Form 990 and other nonprofit reporting requirements; and
  3. Development of technical assistance materials.

With the Form 990 now "widely available," it will be feasible to study numerous issues in a breadth and depth never before possible. More people than ever will be looking at the Form 990. This focus should lead to higher quality data for use by all who are interested in the nonprofit sector.