Tax 990

Form 990 Schedule O Filing Instructions

Supplemental Information

Schedule O for Form 990/990-EZ - Supplemental Information

- Updated August 14, 2023 - 2.00 PM - Admin, Tax990

Nonprofit organizations that file Form 990 or 990-EZ are required to attach Schedule O to provide explanations for certain answers they have provided on their main form.

In this article, you can find more information regarding Schedule O, including filing requirements and more.

What is the Purpose of Form 990/990-EZ Schedule O?

Schedule O is used to provide the IRS with detailed information and explanations for certain responses given on Form 990 or 990-EZ in one place instead of in multiple separate attachments.

Note:

Organizations may still have to attach separate attachments for Late returns, Amended returns, or
Group returns.


Who must file Form 990/990-EZ Schedule O?

All organizations that file Form 990 must submit Schedule O.

Some organizations that file Form 990-EZ may be required to submit Schedule O based on their responses to certain questions on Form 990-EZ.


What are the Instructions to Complete Form 990/990-EZ Schedule O?

While completing Schedule O, it’s important to indicate the specific part and line(s) of Form 990 or 990-EZ for which you are providing explanations.

How to Complete Schedule O for Form 990?

You must provide an explanation on Schedule O for the following two lines on Form 990.

Part VI, line 11b - Describe your organization’s process for reviewing Form 990

Part VI, line 19 - Describe how your organization disclosed its governing documents, conflict of interest policy, and financial statements to the public

Along with these, you may have to provide an explanation for the following lines based on the answers
you provide.

Part III - Statement of Program Service Accomplishments

  • Line 2 - If answered “Yes”, describe the new program services undertaken by your organization that weren’t reported on the previous year’s 990 return.
  • Line 3 - If answered “Yes”, describe the significant changes made by your organization on how the program service activities were conducted.
  • Line 4d - Explain the other program services carried out by your organization.

Part V - Statements Regarding Other IRS Filings and Tax Compliance

  • Line 3b - If answered “No”, explain why your organization hasn’t filed Form 990-T even though it generates an unrelated business income of more than $1000.
  • Line 13b - If answered “Yes” or “No”, provide details about each state in which your organization is licensed to issue qualified health plans, the dollar amount of reserves that each state requires your organization to maintain, and the dollar amount of reserves that your organization maintains and reports to each state.
  • Line 14b - Mention the reason for not filing Form 720 to report the payments received for indoor tanning services.

Part VI - Governance, Management, and Disclosure

  • Line 1a - Provide an explanation for the material differences in voting rights among members of the governing body.
  • Lines 2 through 7b - If you answered “Yes” to any of these lines, explain the circumstances, processes, or other details as required by that specific line.
  • Lines 8a, 8b, and 10b - If you answered “No”, provide the explanation required by the
    specific lines.
  • Line 9 - Report details about the organization's officers, directors, trustees, or key employees who cannot be reached through the organization’s mailing address.
  • Line 11b - Describe the process followed for the review of Form 990.
  • Line 12c - If you answered “Yes”, mention how your organization regularly and consistently monitored and enforced compliance with the conflict of interest policy.
  • Lines 15a and 15b - Describe the process used by your organization for determining compensation.
  • Line 18 - Explain why your organization checked the “Other” box or didn’t make any of Forms 1023, 1024, 1024-A, 990, or 990-T publicly available.

Part VII - Compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated Employees, and Independent Contractors

Provide an explanation about the compensation paid by a related organization and the efforts undertaken by your organization to obtain the information on compensation paid by related organizations.

Part IX - Statement of Functional Expenses

  • Line 11g - Indicate the type and amount of each expense reported.
  • Line 24e - Indicate the type and amount of each expense if the amount on line 24e exceeds 10% of the total expenses.

Part XI - Reconciliation of Net Assets

  • Line 9 - Explain the changes in net assets or fund balances.

Part XII - Financial Statements and Reporting

  • Line 1 - Describe the change in accounting method.
  • Line 2c - Explain the change in committee oversight review from the prior year
  • Line 3b - If answered “Yes”, provide an explanation for why your organization didn’t undergo the required audits and the steps taken to undergo the audits.

How to Complete Schedule O for Form 990-EZ?

Based on the answers you provided on the following lines of Form 990-EZ , you may have to provide an explanation for them.

Part I - Revenue, Expenses, and Changes in Net Assets or Fund Balances.

  • Line 8 - Report details regarding the other sources of revenue generated by your organization that were not mentioned in Form 990-EZ.
  • Line 10 - Report details on every grantee organization or individual to whom your organization paid the grant amount of more than $5,000.
  • Line 16 - Report the other expenses made by your organization that weren't reported on
    Form 990-EZ.
  • Line 20 - Describe the other changes made in the net assets or fund balances between the beginning and end of the tax year.

Part II - Balance Sheets

  • Line 24 - Report details about the other assets.
  • Line 26 - Provide a description for the total liabilities owed by your organization.

Part III - Statement of Program Service Accomplishments

  • Provide a description of other program services carried out by your organization during the tax year.

Part V - Other Information

  • Line 33 - If you answered “Yes”, describe each of the significant activities conducted by your organization that weren't previously reported to the IRS.
  • Line 34 - If you answered “Yes”, describe the significant changes made in the organizing or governing documents by your organization.
  • Line 35b - Explain why your organization hasn’t filed Form 990-T even though it generates an unrelated business income of more than $1000.
  • Line 44d - Indicate the reason for not filing Form 720 to report the payments received for indoor tanning services.

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