We are looking at our processes and reviewing the best way to manage the requirements of the Section 117 Reporting (notes added below for quick reference)
Section 117 of the Higher Education Act of 1965 (www2.ed.gov/policy/highered/leg/hea98/sec101B.html) requires institutions that receive Title IV student assistance to self-report foreign sourced gifts and contracts, and to disclose if a foreign entity has an ownership interest or control over the institution. The threshold that triggers the reporting requirement is $250,00/calendar year, from a single foreign source or combined gifts/contracts from that source. In June of 2019, the Dept. of Education opened investigations at 4 institutions claiming they underreported, and Inside Higher Ed is reporting that the letters received by 2 of these institutions seemed "to indicate an expectation that gifts routed through university foundations should be reported." (www.insidehighered.com/print/news/2019/07/09/colleges-call-more-clarity-rules-requiring-disclosure-foreign-gifts-and-contracts)
The language in Sec. 117 Disclosures of Foreign Gifts addresses receipt of a gift or contract (restricted or conditional) from a foreign source. "Contract", "foreign source", "institution" and "restricted or conditional gift or contract" are defined, although leave room for interpretation. "Institution" as defined does not, in the strictest sense, include separate university foundations. COGR was part of 2 letters to the Department of Education, asking for clarification of the reporting requirements.
The Foreign Gift and Contract Report for the last 6 years (all data is self-reported) can be found here: studentaid.ed.gov/sa/about/data-center/school/...
Questions for the you:
Thank you for any insight you can provide.