Agenda Item
2. FIRST READ – Amendment to the Bylaws & Policies: Board Policy DIB, New Board Regulation: DIB-R (2) Subscription-Based Information Technology Arrangements (SBITA)
Summary: Presented by: Mr. Byron Schueneman, Chief Financial Officer, Division of Finance, 678.676.0278
Request: It is requested that the Board of Education lay the new Board Regulation DIB-R (2) Subscription-Based Information Technology Arrangements (SBITA) on the table as a FIRST READ and Board feedback until the June 12, 2023 Board Meeting where the new regulation will receive final approval.
Why: Board regulation DIB-R2 Subscription-Based Information Technology Arrangements is presented as a new regulation. The purpose is to ensure compliance with Government Accounting Standards Board (GASB) Statement No. 96, Subscription-Based Information Technology Arrangements. The new regulation discusses district procedures and GASB 96 requirements as a guide to help the district remain compliant with the new standard.
Details: GASB Statement No. 96, Subscription-Based Information Technology Arrangements went into effect for all reporting periods after June 30, 2022. To ensure the district’s compliance with GASB 96, Finance has developed a regulation to help in the accounting and reporting decision-making process for subscription-based IT assets. This regulation should be used as a guide when deciding how subscription-based technology agreements should be accounted for and reported on.
Financial impact: There is no financial impact to the district.
Contact: Mr. Byron Schueneman, Chief Financial Officer, Division of Finance, 678.676.0278
Mr. Lance McConkey, Comptroller, Division of Finance, 678.676.0445
Mr. Jim Dawson, Director of Financial Reporting, Division of Finance, 678.656.4399
Mr. Stephen Mayer, Capital Assets Manager I, Division of Finance, 678.521.2423
Effective: Upon Board approval
Status: Attorney approval not required
Subscription-Based Information Technology Arrangements (SBITA)
The district may enter into subscription-based contracts for information technology provided by vendors
when it is either the only option for the information technology needed or more advantageous to the
district than an outright purchase of that information technology. Accounting and reporting for SBITAs is
governed by GASB Statement No. 96, which developed uniform guidance for agreements that meet the
definition of a SBITA. GASB Statement No. 96 requires recognition of a right-to-use subscription asset
and a corresponding subscription liability.
The Finance Division will evaluate all agreements executed by the district that meet the definition of a
SBITA to determine proper accounting and reporting for those agreements. The SBITAs will be reviewed
to determine if the agreement falls under the provisions of GASB 96.
Definitions
Subscription-Based Information Technology Arrangement - A contract that conveys control of the right
to use another party’s IT software, alone or in combination with a tangible capital asset, for a period of
time in an exchange or exchange-like transaction. Examples of SBITAs include ERP systems and Office
365.
Subscription Term – The period during which a government has a noncancelable right to use the
underlying IT assets, plus the following periods, if applicable:
1. Periods covered by a government’s option to extend the SBITA if it is reasonably certain, based
on all relevant factors, that the government will exercise that option.
2. Periods covered by a government’s option to terminate the SBITA if it is reasonably certain,
based on all relevant factors, that the government will not exercise that option.
3. Periods covered by a SBITA vendor’s option to extend the SBITA if it is reasonably certain, based
on all relevant factors, that the SBITA vendor will exercise that option.
4. Periods covered by a SBITA vendor’s option to terminate the SBITA if it is reasonably certain,
based on all relevant factors, that the SBITA vendor will not exercise that option.
Short-Term SBITAs – A SBITA that, at the commencement of the subscription term, has a maximum
possible term under the SBITA contract of 12 months or less, including any options to extend, regardless
of their probability of being exercised. Short-Term SBITAs do not require the recognition of a right-to-
use asset and corresponding liability.
Present Value – The current value of a future sum of money.
Recognition and Measurement
At the commencement of the subscription term, a government should recognize a subscription liability
and an intangible right-to-use asset. The commencement of the subscription term occurs when the
initial implementation stage is completed, as defined in GASB 96, at which time the government has
obtained control of the right to use the underlying IT assets.
Subscription Liability - A government initially should measure the subscription liability at the present
value of subscription payments expected to be made during the subscription term. Measurement of the
subscription liability should include the following, if required by a SBITA:
a. Fixed payments
b. Variable payments that depend on an index or a rate (such as the Consumer Price Index or a
market interest rate), measured using the index or rate as of the commencement of the
subscription term
c. Variable payments that are fixed in substance
d. Payments for penalties for terminating the SBITA, if the subscription term reflects the
government exercising (1) an option to terminate the SBITA or (2) a fiscal funding or cancellation
clause
g. Any subscription contract incentives receivable from the SBITA vendor
h. Any other payments to the SBITA vendor associated with the SBITA contract that are
reasonably certain of being required based on an assessment of all relevant factors.
Interest Rate - To calculate the incremental borrowing rate the district will take the risk-free rate of
return as of the subscription commencement date (or as close to the date as possible) plus an average
additional risk premium based upon three different banks and the credit rating of the district at the time
of the agreement.
Subscription Asset- A government initially should measure the subscription asset as the sum of the
following, less any SBITA vendor incentives received from the SBITA vendor at the commencement of
the subscription term:
a. The amount of the initial measurement of the subscription liability
b. Payments associated with the SBITA contract made to the SBITA vendor at the
commencement of the subscription term, if applicable
c. Capitalizable initial implementation costs as defined in GASB 96
A subscription asset will be amortized using the straight-line method over the shorter of the subscription
term or the useful life of the underlying IT assets.