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Institutional Compliance

Foreign Gifts and Contracts

Section 117 of the Higher Education Act requires institutions of higher education to file a disclosure report when the institution 鈥渞eceives a gift from鈥 or 鈥渆nters into a contract with鈥 a 鈥渇oreign source鈥 where that gift or contract is valued at $250,000 or more, considered alone or in combination with all other gifts from or contracts with that foreign source within a calendar year (see 20 United States Code 搂 1011f(a)).听 These procedures were designed to ensure compliance with federal law as well as to minimize reporting burden at the individual unit level.听The Foreign Gifts & Contracts Reporting policy, #3364-15-19, states that every department is responsible for identifying and reporting gifts received from any foreign source, contracts with any foreign entity, and any ownership interest in, or control over the higher education institution by a foreign entity. The Vice President of each division serves as the 鈥渟igning authority鈥 in attesting to these gifts and contracts.听

In addition, the Department of Education is in the process of amending this reporting requirement further.听 Final regulations have not been issued at this point, but we expect changes to our current process again when new guidance is released either in the form of federal regulations or directives.

Relevant Links

听(foreign gifts/contracts reporting requirements)

University Policy 3364--15-19 Foreign Gifts & Contracts Reporting

Foreign Gifts & Contracts Reporting Procedures