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Four NACUBO members testified on November 30 at an Internal Revenue Service (IRS) public hearing on a Notice of Proposed Rulemaking (NPRM) that calls for significant reporting changes to the IRS Form 1098-T. While they expressed support for aspects of the IRS proposal, they also described how some requirements under consideration would increase burden and confusion and do not reflect current university business practices.

 NACUBO’s witnesses were:

  • Charmaine Daniels, director of student accounts, Georgia State University 
  • Joel Levenson, associate director, Tax Compliance, University of Central Florida
  • Patrick Quinn, director, Student Financial Services, George Mason University
  • Beth Stack, associate vice chancellor, Student Financial Services, University of Pittsburgh 

Daniels focused on the complexities of academic schedules and student accounts, pointing out that student account activity is constant, with charges and payments regularly being applied.  Further, she noted that because academic schedules do not match the tax reporting year, 1098-T reporting is inherently complex.

She also argued for sufficient time for software development and staff training, explaining that changes to college and university information systems can take months to implement and test, and adequate training for staff demands additional time following software deployment. 

Levenson, a member of NACUBO’s Tax Council and NACUBO's representative to the IRS Information Reporting Program Advisory Committee (IRPAC), focused on the challenges of information reporting and stressed that it should be a simple, straightforward portrayal of data readily available as a part of standard college and university business practices. He further urged the IRS to retain the reporting exemption for nonresident aliens, because tax credits are generally not available to these international students, who are currently able to obtain a 1098-T upon request. Levenson also reiterated NACUBO’s overarching concerns about taxpayer and public information about the education tax credits and the 1098-T. 

Echoing points made in NACUBO’s October 31 comment letter to the agency, Quinn and Stack  expressed opposition to the IRS proposals to require reporting enrollment by calendar month, since schools don’t maintain enrollment records that way and report amounts paid for qualified tuition and related expenses (QTRE) for terms beginning in the next calendar year. They also articulated NACUBO’s opposition to the elimination of the exemption where classes are offered through a formal billing arrangement with a third party and the school maintains no financial account for the student. Since the school doesn’t have a financial account for such students, generating 1098-Ts would be impossible, they noted. 

Quinn and Stack said they support the proposal’s change to  keep the exception for reporting on noncredit classes. They also expressed support for eliminating the exception for reporting on students whose aid exceeds payments for qualified tuition and related expenses (QTRE) since the majority of schools already do so, it is not hard to do, and it will be useful to students/taxpayers.

The IRS and Treasury Department were represented at the hearing by:

  • Kathryn A. Zuba, deputy associate chief counsel (Procedure & Administration), Office of Chief Counsel
  • Emily M. Lesniak, special counsel, (Procedure & Administration), Office of Chief Counsel
  • Karla M. Meola, special counsel to the associate chief counsel, (Income Tax & Accounting), Office of Chief Counsel
  • Donna J. Welsh, senior technician reviewer, (Income Tax & Accounting), Office of Chief Counsel
  • Blaise G. Dusenberry, senior technician reviewer, (Procedure & Administration), Office of Chief Counsel
  • Gerald Semasek, attorney, (Procedure & Administration), Office of Chief Counsel
  • Shelley Leonard, attorney-advisor, Tax Legislative Counsel, Department of Treasury

It is unclear how long it will take for the final rules to be published; the timeline is further complicated by the transition from the current administration to the incoming Trump administration.


Mary Bachinger

Director, Tax Policy



Liz Clark

Vice President, Policy and Research



Liz Clark

Vice President, Policy and Research


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