Legal basis

The change in the procedure for issuing subsidies for other purposes is due to the adoption of the General Requirements[1]. They establish uniform rules for all bodies exercising the functions and powers of the founders, which must be taken into account when finalizing local regulations.

We need to do it before January 1, 2021: federal executive authorities are required to bring their procedures into compliance with the General Requirements, and authorities of constituent entities of the Russian Federation and local governments are recommended to do this.

From this date, the General Requirements themselves, adopted in pursuance of the provisions of paragraph. 4 paragraphs 1 art. 78.1 of the Budget Code of the Russian Federation (amended by Federal Law No. 479-FZ dated December 27, 2019). This means that the relations between budgetary (autonomous) institutions receiving targeted subsidies and the founding bodies will be additionally regulated at the federal level.

We show what the new regulatory system is in the diagram.

General requirements unify the process of interaction between founding bodies and subordinate institutions. In orders it will now be necessary to indicate:

• goals, conditions and algorithm for providing subsidies;
• deadlines and forms for the institution to submit reports on achieved results;
• forms of control over compliance with the goals and conditions of the subsidy.

The founding bodies included most of these provisions in their regulations in the form of general norms, but their detailing will be required.

Let's consider the new conditions for issuing subsidies and compare them with those that are currently established for budgetary and autonomous healthcare institutions.

Operations with targeted capital subsidies

Budgetary (autonomous) institutions reflect transactions with these subsidies in the following order*(2):

1. Debit KDB1 5,205 62,561 Credit KDB1 5,401 40,162 - accrual of deferred income for targeted capital subsidies in the amount of the Agreement. 2. Debit KBK2 5,201 11,510 (increase in account 17, analytics code 150, KOSGU 162) Credit KDB1 5,205 62,661 - reflects the receipt of a capital subsidy. 3. Debit KDB1 5,401 40,162 Credit KDB1 5,401 10,162 - recognition of income in the form of a targeted capital subsidy as current year income based on information about the achievement of the conditions for the provision of a subsidy (Notice, Report, other document provided for by the Agreement). 4. Debit KDB1 5,401 40,162 Credit KDB1 5,205 62,661 - decrease in deferred income for targeted capital subsidies based on the amended Agreement and (or) additional Agreement. 5. Formation at the end of the year of settlements for capital subsidies on the basis of the Notice, Report on the fulfillment of the terms of the Agreement (transactions are reflected on the last day of the reporting year, unless otherwise provided by the founder): 5.1. Debit KDB1 5 401 40 162 Credit KBK3 5 303 05 731 - closing settlements in the amount of unused balances of targeted capital subsidies subject to return to the budget in the next year. 5.2. Debit KDB1 5,401 40,162 Credit KDB1 5,205 62,661 - closing settlements in the amount of unused financial support for the subsidy, if it was not transferred to the institution. 5.3. Debit KDB1 5,401 40,162 Credit KDB4 5,303 05,731 - formation of settlements for the unused balance in the presence of obligations assumed at the expense of it and unfulfilled (the need to confirm the need for these funds). When confirming the need, the following entry is reflected: Debit KDB4 5,303 05,831 Credit KDB1 5,401 40,162 5.4. If settlements with the founder under the subsidy are “closed” completely, but the institution still has accounts payable accepted at the expense of the subsidy funds (accepted and unfulfilled monetary obligations), then there is no need to record additional entries. The balance of funds in the personal account in the next year will be used to repay the accepted monetary obligation. 5.5. If, due to a targeted capital subsidy, an advance was paid that was not confirmed by the counterparty’s documents for the reporting year, then the difference between the indicators Dt 5,205,62,000 and Kt 5,401,40,162 is equal to this advance. If a decision is made to return (not confirming the intended nature of the accepted monetary obligations), the operation specified in clause 5.1 is reflected in the next financial year. 6. Debit KBK3 5 303 05 831 Credit KBK2 5 201 11 510 (increase in account 18, analytics code 610, KOSGU 610) - return of the unused balance of the targeted capital subsidy of previous years.

More on the topic: Consultation line “Accounting in 1C: BSU”. Issue No. 42/20

Purpose of funds

In accordance with the order of the founding body, the purposes of providing subsidies must be listed (clause “b”, clause 3 of the General Requirements). And if the allocated funds are intended to be used for activities that are implemented within the framework of a national project (program) or a federal or regional project adopted for its implementation, the name of the project (program) must be reflected.

An indication of the programmatic nature of the funds will allow us to link the purpose and result of the subsidy, since the latter will be important not in itself, but as an indicator of achievement of the indicators of the corresponding project or program.

The objectives of subsidies in existing procedures, as a rule, have already been established. They are named in the form of a closed or open list, but they are not always associated with the implementation of government programs or projects. Subsidies can be directed, for example, to:

• major repairs of real estate;
• acquisition of particularly valuable movable property worth over 200 thousand rubles;
• financial support for budgetary and autonomous institutions providing medical care within the framework of the territorial compulsory medical insurance program (such goals were set in the Sverdlovsk region) [2].

But there are also examples when regulations directly indicate the programmatic nature of subsidies.

Thus, the Health Committee of the Government of St. Petersburg[3] approved 65 types of targeted subsidies for subordinate institutions, most of which are spent within the framework of four state programs. A similar approach was chosen in the Rostov region[4]: most of the purposes for which funds are allocated are implemented within the framework of seven regional programs.

Package of documents for receiving a subsidy

The procedure for interaction between the founding body and the subordinate institution applying for a subsidy should be spelled out in more detail.

The first stage is the submission by the institution of a package of documents, on the basis of which the founding body will make a decision (clause “a”, clause 4 of the General Requirements). The kit must include an explanatory note , where the health care institution must justify the need to allocate funds from the budget for a particular purpose. You will also need to attach a calculation of the amount of the subsidy (including a preliminary estimate for performing work or providing services, holding events, purchasing movable property), proposals from suppliers (contractors, performers), and statistical data.

In addition to the explanatory note, depending on the purpose of providing the subsidy, the package of documents will, in particular, include:

• a list of objects to be repaired, an inspection report and a defect sheet, a preliminary cost estimate;
• program of events (conferences, symposia, etc.);
• information about the property planned for acquisition.

Some founding bodies have already included in their procedures requirements for the package of documents that the institution collects.

For example, institutions of the Altai Republic are required to submit an application and a financial and economic justification for the requested amount of subsidy[5]. The justification may be:

• information on the cost of particularly valuable movable property planned for acquisition, confirmed by at least three commercial offers from suppliers;
• or information on the timing and cost of repair work, confirmed by preliminary cost estimates.

The second stage of the interaction procedure is the consideration by the founding body of the package of documents submitted by the institution. The procedure and terms of consideration, as well as the grounds for refusal, must also be specified in the legal act in force in relation to the healthcare institution (clauses “b”, “c”, paragraph 4 of the General Requirements).

In particular, the founder may refuse to issue a subsidy due to non-compliance of documents with established requirements, failure to submit (incomplete submission) of any documents, or detection of false information in them. The founding body also has the right to establish other reasons.

Let us note that currently, in the procedures in force in relation to healthcare institutions, the grounds for refusing to issue a subsidy, as a rule, are not separately specified.

Requirements for the recipient institution

According to paragraphs. “f” clause 4 of the General Requirements, on the date determined by the legal act, or on the 1st day of the month preceding the month in which it is planned to conclude an agreement or make a decision to provide a subsidy, the institution must not have:

• unfulfilled obligation to pay taxes, fees, insurance premiums, penalties, fines and interest;
• overdue debt for the return of subsidies and budget investments to the budget from which it is planned to provide a targeted subsidy (except for cases when targeted funds are issued for measures to reorganize or liquidate an institution, prevent an emergency (emergency) situation, eliminate its consequences and carry out restoration work, debt repayment according to judicial acts that have entered into legal force, executive documents).

That is, the main condition that an institution applying for a targeted subsidy must meet is the absence of debt to the budget . Although the founding body may establish additional requirements for the recipient institution.

As a selective analysis of current legal acts issued in relation to healthcare institutions shows, this rule is now rarely introduced. This means that in the coming months, the founding bodies will have to introduce relevant regulations into their regulations, and institutions will have to take into account new requirements when submitting applications for targeted subsidies.

Procedure for calculating the subsidy

The procedure for calculating the amount of the targeted subsidy and (or) its size itself will also need to be established by the founding body in its legal act. As stated in paragraphs. “g” clause 4 of the General Requirements, this act must contain information justifying the amount of the subsidy (calculation formulas, the procedure for their application), as well as an indication of the source of its receipt. The calculation will not need to be applied only in cases where the amount of the subsidy is determined by the law (decision) on the budget, decisions of the President of the Russian Federation, the Government of the Russian Federation, the highest executive body of state power of a constituent entity of the Russian Federation, or local administration.

Now the procedure for calculating subsidies is given here and there, but calculation formulas are rare.

In particular, in the Rostov region (see footnote 4 to this article) such a procedure was prescribed in relation to each purpose of the subsidy. However, its size in many cases is calculated based on the need for these expenses, determined on the basis of requests from institutions, and within the limits of the funds provided for the regional Ministry of Health by the budget law. Although this document also contains formulas. Thus, the amount of the subsidy for providing donors with free food (payment of monetary compensation) is calculated on the basis of the planned number of donors at the rate of 5% of the subsistence level of the working-age population in effect on the date of blood donation, established in the region.

A different approach was used in the Sverdlovsk region - the procedure for calculating the volume of targeted subsidies was approved by a separate regulatory act[6]. It provides three main calculation methods:

• planned method - calculations are made in accordance with the indicators specified in regulatory legal acts, regional target programs adopted in the prescribed manner, contracts (agreements) concluded by a constituent entity of the Russian Federation (on its behalf);
• indexation method - the volume of budget allocations for the current (reporting) financial year is multiplied by the consolidated consumer price index;
• normative method - calculation is carried out on the basis of conditional calculation standards, as well as standards approved by relevant legal acts.

Thus, according to the new rules, the amount of the subsidy will be calculated and justified in two stages. First, the institution must do this by submitting a financial and economic justification and supporting documents as part of the application. And then the founding body must calculate the final amount by applying approved calculation methods or formulas.

Postings when accounting for a subsidy for the implementation of a state (municipal) task

On January 1, 2019, the new Federal Accounting Standard for public sector organizations “Revenue”*(2) came into force.

The main innovation for accounting for subsidies in connection with this Standard is that institutions reflect deferred income in the form of a subsidy on the basis of Agreements concluded with the founder. Recognition of such income as income of the current year is carried out on the basis of a report on the fulfillment of the conditions for the provision of funds.

More on the topic: Accounts 302 27, 302 28, 302 29: recommendations for their use in 2021

The corresponding amendments have already been made to the Instructions for accounting in budgetary (autonomous) institutions. They are applicable from 01/01/2019.

Let us recall that previously, income in the form of a subsidy for the implementation of a state (municipal) task was recognized as income for the current year based on the terms of the Agreement (on the date of provision of the subsidy).

To summarize the above, the accounting for subsidies for the implementation of state (municipal) tasks is reflected by institutions from 01/01/2019 with the following accounting entries:

1. Debit 4,205 31,000 Credit 4,401 40,131 - on the basis of the concluded Agreement, the accrual of deferred income is reflected in the amount of the subsidy for the implementation of the state (municipal) task; 2. Debit 4,401 40,131 Credit 4,401 10,131 - reflects the recognition of income in the form of a subsidy for the implementation of the state task as income of the current year in accordance with the report on the implementation of the state (municipal) task of the income of the current financial year; 3. Debit 4 401 40 131 Credit 4 303 05 000 - reflects the accrual of debt for the return of subsidy balances to budget revenue due to the failure to achieve the indicators established by the task based on the report on the implementation of the state (municipal) task.

Subsidy Agreement

By virtue of paragraphs. “d” clause 4 of the General Requirements, the standard form of an agreement on the provision of targeted subsidies is established by the Ministry of Finance, the financial authorities of the constituent entities of the Russian Federation and municipalities - in relation to budgetary and autonomous institutions of the federal, regional and municipal levels, respectively. However, in the constituent entities of the Russian Federation and municipalities, standard forms are not always approved by financial authorities. Usually the form is provided in an annex to the order issued by the regional government or sectoral authority.

In addition, it has now been established that the standard form, in addition to provisions on the purpose, amount of the subsidy, the schedule for its transfer, the rights and obligations of the parties, must contain, for example:

• the values ​​of the results of providing a subsidy, which must be specific, measurable and consistent with the results of federal or regional projects (programs) (if the subsidy is provided as part of their implementation), and the values ​​of the indicators necessary to achieve the results of providing a subsidy (including in terms of tangible and intangible objects and (or) services planned to be received upon achieving project results);
• the grounds and procedure for making changes to the agreement, including when the founding body reduces the previously established limits of budget obligations for the provision of subsidies;
• grounds for early termination of the agreement by decision of the founding body unilaterally, including in connection with the institution’s violation of the goals and conditions for providing a subsidy established by a legal act and (or) agreement;
• prohibition on termination of the agreement by the institution unilaterally.

In this regard, local authorities will need to not only add the necessary provisions to the standard form, but also re-approve it if it was not previously approved by the financial authority.

At the federal level, such work has already been carried out. Changes to the standard form[7], approved by Order of the Ministry of Finance of the Russian Federation dated October 31, 2016 No. 197n, were introduced by Order of the Ministry of Finance of the Russian Federation dated October 30, 2019 No. 172n and will be applied starting with agreements concluded for 2021.

For example, the founder’s responsibilities include establishing the values ​​for the results of providing a subsidy, and the federal agency will have to ensure that these values ​​are achieved. If the specified indicators are not met, the founding body will be able to unilaterally terminate the agreement with the institution.

General rules

According to the Agreement with the founder, a budgetary (autonomous) institution may receive the following types of subsidies:

• subsidies for the implementation of state (municipal) tasks (hereinafter referred to as subsidies for the implementation of state tasks);
• subsidies for capital investments in capital construction projects of state (municipal) property and the acquisition of real estate in state (municipal) property (hereinafter referred to as subsidies for capital investments);
• subsidies for other purposes, including grants in the form of subsidies (hereinafter referred to as subsidies for other purposes).

In accordance with clause 54 of the “Revenue” Standard, subsidies for the implementation of government tasks are recognized in accounting as deferred income on the date the right to receive them arises, i.e. on the date of conclusion of the Agreement. A similar rule applies to other types of subsidies presented above, if they are provided on the basis of the return of part of the funds due to failure to comply with the terms of the Agreements (non-use of subsidy funds) (clause 40 of the “Revenue” Standard).

An option when a subsidy is provided without such a condition is to provide a subsidy for another purpose to an autonomous institution that has accounts opened in a commercial bank. According to the conditions, initially in such a situation the autonomous institution must spend its own funds on expenses that will be provided for in the Agreement and provide a report to the founder. Then the founder allocates a subsidy for another purpose to reimburse the expenses incurred by the autonomous institution.

Other situations where, on the basis of the Agreement, it is possible to recognize income in the form of a subsidy as current year income immediately have not yet been established. Therefore, according to the general rule established by the “Revenue” Standard, on the basis of the Agreement concluded with the founder, the institution should reflect deferred income in accounting.

Income of future periods can be recognized as income of the current year on the basis of the following documents:

1. for a subsidy for the implementation of a state task - on the basis of the Report on the implementation of the state (municipal) task;
2. for other types of subsidies - on the basis of the Report on the fulfillment of the conditions for the provision of a subsidy;
3. and (or) information on the results of the use of subsidies - Notice (f. 0504805), generated in order to reflect the financial results on an accrual basis in the absence of the Reports specified in paragraph “1” on the date of reporting;
4. and (or) other document provided for in the Agreement.

The Notification (f. 0504805) is generated by a budgetary (autonomous) institution, two copies are sent to the founder. If the founder agrees with the amount specified in the Notice (f. 0504805), then he confirms this by sending a second copy of the completed Notice (f. 0504805) to the institution. To quickly reflect information, we allow the exchange of scanned copies of documents.

Exchange of Notices (f. 0504805) does not exempt the institution from submitting the reports specified in paragraph “1” above. Based on the results of compiling such reports, the amounts indicated earlier in the Notice (f. 0504805) may be updated. Such adjustments are reflected by the founder by sending a Notice (f. 0504805) to the institution receiving the subsidy, indicating the correcting entries. The corresponding accounting entries do not correct the error and are reflected in the financial year in which the decision to adjust the calculations was made.

More on the topic: Customer actions regarding the report on the execution of contract stages will be simplified from July 1, 2021

After submitting the financial statements, the institution may be required to return part of the subsidy, including as a result of reviewing the Subsidy Reports and identifying misuse (failure to comply with the terms of the subsidy). The corresponding requirements are reflected in the next year as new calculations, without correcting the errors of previous years.

The error of previous years will have to be corrected only if income in the form of a subsidy was recognized incorrectly as income of the current year. For example, accrual was carried out on a cash basis, and not based on the fact that the conditions for providing a subsidy were fulfilled.