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Institutions have until October 31 to share thoughts and concerns about proposed changes to the reporting requirements for Internal Revenue Service (IRS) Form 1098-T, Tuition Statement. NACUBO urges members to respond.

In less than two weeks, nearly 400 institutions responded to NACUBO’s survey on the IRS' proposed rules for Form 1098-T. The resulting data are vital to help the association develop a community response.

But this will not be enough—the IRS needs to hear the perspectives of individual colleges and universities as well. These comments can carry just as much weight as comments from associations like NACUBO. 

Comments may be filed online at the website. Go to this link or enter the Docket Number IRS REG-131418-14 in the search box. Within the docket folder you will be able to review the proposed rules as well as comments that have previously been filed. Click the “Comment Now!” box, complete the information, and either copy and paste your comments (if they are brief) or upload your comments as an attachment.

Helpful Hints for Filing Comments on Proposed Regulations


  • Read the notice of proposed rulemaking—don’t try to comment based on summaries or news stories.
  • Check with your institution’s public affairs or governmental relations staff to share your concerns about the proposed rules and ensure that you have authority to file comments on behalf of your institution.
  • Introduce your institution (public/private, size, number of 1098-Ts filed annually, etc.) 
  • Clearly identify the parts of the proposed rule you are discussing, either by topic or by a citation to the proposed regulation.
  • Explain what you do or don’t like about the proposal and why. What will the impact be on your institution or your students?
  • Suggest an alternative or better language, if possible.
  • You needn’t address every aspect of the proposed rules, just those that are most important to you.
  • Comments may be filed anonymously but may seem less professional and carry less weight.

Specific to 1098-T Proposed Regulations

  • Congress eliminated the option to report amounts billed in Box 2. The IRS cannot change this. Comment on how the Service proposes to implement the change and challenges you will face in doing so, but don’t question whether IRS should require Box 1 reporting.
  • Because Congress decided that students must have a Form 1098-T in order to claim education tax benefits, the IRS has proposed eliminating the current reporting exceptions for nonresident aliens; students whose grants exceed amounts paid; and students whose education is paid for under a third-party billing arrangement and for whom the school does not maintain a separate account. How many more forms would your school need to file? What challenges would you face in doing so?

The exception for noncredit courses would survive, but the IRS specifically asks if it should be retained or if changes should be made to it. If you agree that this exemption is important, say so.

  • The IRS has proposed adding two new data fields to the 1098-T. Instead of just indicating that payments attributable to an academic term that begins in the first three months of the following year are reported, the school would need to provide the amount of payments for that future term. Institutions would also be asked to report the number of calendar months that the student was enrolled full time. Any month in which the student was enrolled for even one day would count. What difficulties would your institution face in providing this information? Could you ensure accuracy? How much would it cost?


Liz Clark

Vice President, Policy and Research



Mary Bachinger

Director, Tax Policy


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