Run the annual cycle: 990, audit, renewals

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Exactly what to do

1. 1.1File the right Form 990, on time
   Due the 15th day of the 5th month after your fiscal year ends (May 15 for calendar-year orgs). 990-N if gross receipts are normally $50,000 or less; 990-EZ under $200,000 receipts AND under $500,000 assets; full 990 at or above either. File electronically, and remember the death penalty: three consecutive missed years and the IRS automatically revokes exemption. For any year you’re on a state’s list, the proposed regulations add an annual §25F certification and report (that you met every requirement, plus applications, awards, award sizes, schools, expense categories, income, and the share of income spent), attached to your annual information return; an organization not required to file one sends it separately by the same 15th day of the 5th month. A copy goes to each state that lists you. The IRS hasn’t released the form yet.
2. 1.2Run the independent audit
   Under the proposed regulations, every year after a year in which you were an SGO you need an annual financial and programmatic audit by a qualified independent third party, with the results sent to every state whose list you appeared on. If your total receipts (all of them, not just the §25F account) were more than $500,000, that means an external, independent professional or accredited body; at $500,000 or less you may use a committee of independent people unrelated to your management, who sign the report under penalties of perjury (the $500,000 line). It covers how you find and verify applicants, select recipients (priority and disqualified-person screening included), set award amounts, pay and track scholarship money, and verify expenses, plus your location in each state and every operational requirement. It’s an administrative cost, so it never counts toward the 90%. Keep audit-ready books all year so it's a review, not an archaeology dig. (Using the tutoring and special-needs income safe harbor? That needs its own annual third-party audit, also sent to the state.)
3. 1.3Renew everything else
   The corporate annual report and registered agent in your home state, every charitable-solicitation renewal from stage 3, any reports your listing states require, and the stage 4 re-listing itself. All of it should be on the deadline list you’ve kept since stage 3: one page in the records book, every renewal with its date, checked at each board meeting.

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