Program Services & Governance: Form 990 Parts III & VI

Course Details


Monday, January 17, 2022

9:00am – 11:30am (Registration: 6:07am)



Field of Study


CPE Credit

3 hours CPE credit

Level of Knowledge



CPA Crossings


Some familiarity with the nonprofit sector helpful, but not necessary.


Session 6 of Borenstein's Form 990 Foundational Series:

The Form 990 Parts addressed in this session are two `legs' of the 990's non-financial disclosure-driven three-legged stool. Stakeholders, donors, competitors, and naysayers use both the Program Service Accomplishments Part's disclosures and the filer's responses to Part VI's "Governance" inquiries to assess the organization's credibility and have a sense of management's capacity. Part III not only details Program Services' output with great specificity, but also updates the Form's readers both as to the filer's largest arenas of activities and how conducted activities have changed. And Part VI, the infamous "Governance Part," provides information as to the composition of those "legally in charge," as well as how both the Board of Directors/Trustees and its delegated officials employ policies in favor of maintaining internal controls. Preparers need to appreciate the importance of these two key parts and ensure that filers put their "best foot forward" properly here.

This event may be a rebroadcast of a live event and the instructor will be available to answer your questions during the event.


The major topics that will be covered in this class include:

  • Part III's mandated disclosures with respect to the "largest three" programs conducted in the filing period
  • Handling public relations needs when the size measures for "largest three" result in omission of a 'top 3' program
  • Function of Part III as an ongoing updating of the filer's listing of all activities being performed as of the tax year being reported upon
  • Properly reporting upon new or changed programmatic efforts and appropriate reporting on program cessation
  • Function (and methodology) of Part VI, with emphasis on its six most important inquiries
  • Role of Schedule O in providing mandated narration of governance practices inquired of in Part VI
  • Common 'foot-faults' in answering Part VI's key questions


After attending this presentation you will be able to...

  • Recognize the quantitative detail required in reporting on the organization's largest three program arenas' "accomplishments," including the expenditures detail required to be entered by 501(c)(3) and 501(c)(4) filers in the headers to Part III's Lines 4a-4d
  • Identify required Part III reporting when there has been any of the following: significant changes to programs, the addition of new programs, or cessation of prior-conducted programs
  • Embrace and appreciate: (a) the key six governance inquiries in Part VI of the Core Form that have the most important ramifications from a public relations perspective; and (b) the narrative disclosures required on Schedule O for all key Part VI disclosures (and understand where the face of the Form cannot be relied upon!)
  • Understand which Part VI lines are "most reviewed" by State regulators
  • Learn the objective criteria by which a board of directors has sufficiently been provided Form 990 pre-filing in manner sufficient to garner a "Yes" answer to the inquiry at Part VI's Line 11a
  • Identify the multiple disclosures required when a management company is employed at any time in the tax year being reported upon, and contrast these with Part VII-A

Designed For

Public accounting tax and audit staff, nonprofit organization's Treasurers, CFOs, and other finance/compliance advisors

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