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The Department of Education’s new requirements for foreign gift reporting under Section 117 of the Higher Education Act are set to take effect following approval from the White House Office of Management and Budget.

ED’s initial proposed changes drew concern from the higher education community, and this final rule remains largely unchanged despite multiple comment letters from NACUBO and other associations requesting substantive modifications. A provision in the first draft requiring schools to provide true copies of gift and contract agreements with foreign entities was removed, but ED has indicated that it likely will engage in a formal rulemaking process to try to add that requirement in the future.

It is still possible for ED to delay implementation, as the higher education community has requested in light of the current COVID-19 pandemic. However, ED has indicated that it will create a new portal to be used for the upcoming July 31, 2020, reporting deadline. NACUBO will continue to monitor and report developments.


Megan Schneider

Senior Director, Government Affairs


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