Question & Answer: revenue recognition dilemma of vaccine stockpiles…..

a) The revenue must be realized or realizable and earned. “revenues are considered to have been earned when the entity has substantially accomplished what it must do to be entitled to the benefits represented by the revenues

b) The ordered goods must have been segregated from the seller’s inventory and not be subject to being used to fill other orders

The SEC updated its interpretation on vaccine stockpile programs to conform to the guidance in the new revenue standard. The updated interpretation states that vaccine manufacturers should recognize revenue when vaccines are placed into Federal Government stockpile programs because control of the vaccines has transferred to the customer and the criteria in the new revenue standard for recognizing revenue in a bill and-hold arrangement are satisfied. Manufacturers should provide disclosures in accordance with the new revenue standard when vaccines are placed into the stockpile. This interpretive guidance is only applicable to the specific vaccines listed in the release.