U.S. Department of Education provides notice of new, expanded Section 117 foreign gift and contract reporting requirements for higher education institutions

On 17 December 2019, the U.S. Department of Education (ED) published in the Federal Register notice of a new information collection request (ICR) related to reporting requirements under Section 117 of the Higher Education Act (20 U.S.C. § 1011f). Section 117 requires an "institution" to file a disclosure report when it "receives a gift from" or "enters into a contract with" a "foreign source" that is valued at US$250,000 or more, either alone or when combined with other gifts and contracts with the same foreign source in the same calendar year. See 20 U.S. C. §1011f. Because ED aims to implement the ICR in time for Section 117 reports due by 31 January, it has requested the Office of Management and Budget (OMB) to complete an emergency review by 2 January. If OMB approves the ICR, institutions will have the option to use the ICR for Section 117 reports due by 31 January 2020.

This alert summarizes ED's position on certain aspects of Section 117 compliance, as conveyed in its Response to Public Comments received after its September 2019 initial ICR notice, and provides information on additional Section 117 developments.

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