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 “receives a gift from” or “enters into a contract with” a “foreign source” 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 § 1011f(a)).  These procedures were designed to ensure compliance with federal law as well as to minimize reporting burden at the individual unit level. 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 “signing authority” in attesting to these gifts and contracts. 

In addition, the Department of Education is in the process of amending this reporting requirement further.  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.

The Institutional Compliance webpage contains detailed information on our obligations regarding foreign gifts and contracts, including links to University policy in this area, underlying procedures, required data to provide, and a training video.

Relevant Links

Section 117 of the Higher Education Act (foreign gifts/contracts reporting requirements)

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

Foreign Gifts & Contracts Reporting Procedures

Last Updated: 6/27/22