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The next deadline for foreign gift reporting is January 31, but since the Department of Education’s proposed new reporting rules remain stalled within the Office of Management and Budget (OMB), ED has published interim guidance for colleges and universities.

NACUBO and 13 other higher education associations, in a letter led by the American Council on Education, expressed concerns with ED’s proposed changes to foreign gift reporting. The current delay may be due to OMB’s attempt to address those concerns with ED before allowing implementation of the rules.

ED has indicated that for the January 31 deadline, institutions will be permitted to choose between its new proposed reporting method, pending OMB approval, or the current reporting system. Because the reporting system for the new method is not yet live, schools can either:

  • Use the current system by accessing the electronic application. Schools should enter the information in Section K, Question 71; any restrictions or conditions pertaining to gifts or contracts can be entered in Question 69. Schools should then complete the signature page in Section L and submit the report; or
  • Wait for a link to the new system from ED (pending its approval by OMB), and then submit the new information. ED intends to provide access to the new system via an Electronic Announcement later this month.

It remains unclear whether the OMB will approve the new system before January 31.


Megan Schneider

Senior Director, Government Affairs


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