Reminder: Report Foreign Gifts and Contracts to ED
June 1, 2005
Colleges and universities that participate in the Title IV federal student aid programs must file reports on January 31 and July 31 disclosing foreign gifts, contracts with foreign sources, and ownership or control by foreign entities, subject to certain reporting thresholds. This is not a new homeland security requirement; it was required by law as part of the 1992 reauthorization of the Higher Education Act. The Department of Education (ED) updated its system for collecting these reports online last year using its electronic application process (eAPP).
Institutions need to file a report if the total of all gifts from and contracts with a foreign source exceeds $250,000 in any calendar year. The report needs to provide
- the aggregate amount of gifts and contracts with a foreign government, by country;
- the aggregate amount of gifts and contracts with a foreign source other than a government, by country;
- for restricted or conditional gifts or contracts, additional information including a description of the conditions.
An institution that is owned or controlled by a foreign source needs to report initially and then file a new report if there are any substantive changes to its ownership status, program, or structure.
The reports are due no later than January 31 or July 31, whichever is sooner, after the threshold is met. Note that while the report is filed electronically, the signature page must be printed, signed, and mailed to the appropriate ED Case Management Team. An October 2004 Dear Colleague letter, GEN-04-11, provides specific instructions and answers to frequently asked questions. The orginial requirements were laid out in GEN-95-12, released in February 1995.
- NACUBO Responds to FASB's NFP Proposal
- Results Are In: The 2014 NACUBO Tuition Discounting Study
- NLRB Dismisses Union Bid from Northwestern Football Players
- WEBCAST: Legislative Lunchcast: A 30-Minute Washington Update from NACUBO
Wednesday, September 9, 2015 12:00PM ET
- WEBCAST: A Financially Sustainable Approach to Innovate Academic Programs
Wednesday, October 21, 2015 1:00PM ET
- ON-DEMAND: Developing Your Campus Distance Learning Strategy
- ON-DEMAND: VIRTUAL: 2015 Annual Meeting
- ON-DEMAND: NACUBO Live!: CBO Speaks
- ON-DEMAND: A Just-in-Time Webcast to Explain FASB’s NFP Reporting Proposal
- ON-DEMAND: Decoding ED's Cash Management Proposal
- A Guide to College and University Budgeting: Foundations for Institutional Effectiveness, 4th ed. - by Larry Goldstein
- NACUBO's Guide to Unitizing Investment Pools - by Mary S. Wheeler
- Managing and Collecting Student Accounts and Loans - by David R. Glezerman and Dennis DeSantis