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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.

For questions, contact your ED Case Management Team. The NACUBO contact is Anne Gross, 202.861.2544.