GASB 104 and Community Colleges: Why Disclosures of Leases, SBITA, and Intangible Assets Matter

Practical Guidance from Maher Duessel’s Community College Specialists

GASB Statement No. 104 is a narrow but important standard for community colleges. In the Board’s own words, the objective of the Statement is to provide users of government financial statements with essential information about certain capital assets. GASB 104 does that by requiring certain types of capital assets to be disclosed separately in the capital assets note disclosures and by establishing requirements for capital assets held for sale.

Just as important, GASB 104 is a disclosure standard, not a new recognition or measurement model. The Statement says its provisions are limited to the disclosure of certain types of capital assets and do not include changes to current recognition or measurement requirements.

For community colleges, that means the biggest impact will usually be in the notes and comparative presentation rather than on the face amounts recorded for capital assets. Still, that should not be confused with a minor change. Colleges now hold more lease related and technology related intangible assets than they did when GASB 34 became the baseline capital asset disclosure model, so the way those assets are described in the footnotes matters more than ever.

What GASB 104 Requires

GASB 104 requires certain capital assets to be disclosed separately in the capital asset note. Based on the Statement and related implementation materials, that separate disclosure includes:

• Lease assets recognized under GASB 87 by major class of underlying asset
• Intangible right-to-use assets recognized under GASB 94 by major class of underlying asset
• Subscription assets recognized under GASB 96
• Other intangible assets by major class of asset

The official Statement also makes an important presentation point: intangible assets that represent the right to use a type of underlying asset should not be disclosed in the same major class as owned capital assets.

That distinction is especially relevant for community colleges. A college may already group equipment, buildings, and software-related balances in ways that made sense under older disclosure habits. GASB 104 requires a more precise breakout of right-to-use and other intangible asset categories.

Why Community Colleges Should Pay Attention

This is not just theoretical for higher education. Community colleges often have lease assets under GASB 87, subscription assets under GASB 96, and other technology related intangibles that have become increasingly significant to operations. In practice, that often includes enterprise and academic platforms such as Ellucian Banner or Colleague, learning management systems such as Blackboard or Canvas, finance and HR platforms, student success and advising platforms, document management systems, cybersecurity tools, and other cloud-based administrative and instructional software. These arrangements should be evaluated carefully to determine whether they create subscription assets or other intangible assets that need to be separately disclosed under GASB 104.

The New Held-For-Sale Disclosure

GASB 104 also addresses capital assets held for sale. Under the Statement, a capital asset is held for sale if the government has decided to pursue the sale of the asset and it is probable that the sale will be finalized within one year of the financial statement date.

The Statement requires governments to evaluate that conclusion each reporting period. If the criteria are met, the notes should disclose the ending balance of capital assets held for sale, with a separate disclosure of historical cost and accumulated depreciation or amortization by major class. If those assets are pledged as collateral, the carrying amount of the related debt also should be disclosed.

For many community colleges, this may not be an every year issue. But it does mean management should document whether any buildings, equipment, land, or other capital assets meet the held-for-sale criteria at year end rather than assuming the issue does not apply.

What Community College Finance Teams Should Update

For community college finance staff and controllers, a practical GASB 104 implementation list includes:

• Review the capital asset footnote and identify where lease assets are currently disclosed.
• Separate subscription assets and other intangible assets from traditional owned capital asset categories where needed.
• Confirm that right-to-use assets are not combined into the same major class as owned assets.
• Evaluate annually whether any capital assets meet the held-for-sale criteria and, if so, prepare the required disclosures for historical cost, accumulated depreciation or amortization, and related collateralized debt.
• Update pending pronouncement and implementation disclosures for FY 2026 reporting.

The Bottom Line

GASB 104 does not change how community colleges recognize capital assets, but it does change how certain capital assets are described to readers. By requiring separate disclosure of lease assets, subscription assets, certain other intangible assets, and capital assets held for sale, the Statement pushes colleges toward clearer and more decision useful footnotes. For finance teams, the work now is to make sure the capital asset note, disclosure checklist, and comparative presentation reflect that more precise structure before FY 2026 statements are issued.