News & Analysis as of

Higher Education Act Reporting Requirements

Husch Blackwell LLP

The Long and Winding Road to the New Financial Value Transparency and Gainful Employment Rules

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Effective July 1, 2024, institutions of higher education participating in Title IV Federal Student Aid programs must comply with the U.S. Department of Education’s (Department) Financial Value Transparency and Gainful...more

Ballard Spahr LLP

California DFPI Finalizes Regulations Governing Student Loan Servicers

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On October 13, 2023, the California Department of Financial Innovation (DFPI) published final regulations implementing the Student Loan Servicing Act (“SLSA”) and the Student Loans: Borrower Rights Law. The final regulations...more

Akin Gump Strauss Hauer & Feld LLP

Renewed Congressional Focus on Foreign Gifts and Contract Reporting Under Section 117

Congressional Republicans are increasingly focused on ensuring that U.S. colleges and universities are properly disclosing gifts and contracts from foreign sources under Section 117 of the Higher Education Act of 1965, 20...more

Husch Blackwell LLP

Update: U.S. Department of Education Third-Party Servicer Guidance

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UPDATE: On February 28, 2023, the Department updated the Dear Colleague Letter issued February 15, 2023 to establish a future effective date for the guidance, extend the public comment period, and extend the reporting...more

Hogan Lovells

Updated U.S. Department of Education guidance on Section 117 Foreign Gift and Contract requirements

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This advisory summarizes Section 117 requirements and enforcement, highlights key aspects of the updated guidance, and identifies considerations for higher education institutions given the U.S Department of Education’s...more

Bricker Graydon LLP

Foreign gift and contract reporting: Tuition paid by foreign source applies

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As we rapidly approach the New Year, higher education institutions should ensure they have met their foreign gift and contract reporting requirements. Institutions are required by Section 117 of the Higher Education Act to...more

King & Spalding

Heightened Focus on Foreign Influence in Academia

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Department of Education Report Warns that Academic Institutions Are Failing to Meet Compliance Obligations in Fight Against Foreign Influence Last month the Department of Education (“DOE” or “Department”) released an...more

Faegre Drinker Biddle & Reath LLP

Education Department Unveils New Portal for Foreign Contract and Gift Reporting

As described in previous alerts dated June 18, 2019 and January 17, 2020, the U.S. Department of Education (ED) has been increasing its scrutiny of higher education institutions’ contracts with, and gifts from, foreign...more

Cooley LLP

Blog: ED Announces New System for Institutions to Report Foreign Ownership, Contracts and Gifts

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On June 22, the United States Department of Education announced its new information collection system for postsecondary institutions that participate in the Title IV programs to comply with the foreign owner, contract and...more

Husch Blackwell LLP

New U.S. Department Of Education Section 117 Foreign Source Reporting Investigation & Information-UPDATED June, 2020 #1

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Update on June 22, 2020: On June 22, ED unveiled its new online portal for college and university reports of foreign gifts and contracts. Original post on May 5, 2020: Mid-pandemic, the U.S. Department of Education...more

Husch Blackwell LLP

New U.S. Department Of Education Section 117 Foreign Source Reporting Investigation & Information

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Mid-pandemic, the U.S. Department of Education (ED) has weighed in on controversial new requirements for reporting college and university foreign gifts and contracts. ED has: •Published the disclosure form it included with...more

Ballard Spahr LLP

DOE Signals Renewed Commitment to Enforcement of Foreign Gift Reporting Requirements

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The U.S. Department of Education (DOE) recently announced that it is launching an investigation into the foreign gifts reporting practices of two higher education institutions. ...more

Hogan Lovells

U.S. Department of Education withdraws proposed Section 117 foreign gift and contract information collection request; plans to...

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On 4 February 2020, the Office of Management and Budget (OMB) announced that OMB and the U.S. Department of Education (ED) have decided to withdraw the emergency information collection request that ED had submitted to OCR on...more

Bricker Graydon LLP

Disclosing foreign gifts and contracts: An expanding area of compliance for higher education institutions

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The Higher Education Act was passed by Congress in 1986. Since then, higher education institutions have been required by Section 117 of the act to biannually report to the U.S. Department of Education (ED) gifts from or...more

Faegre Drinker Biddle & Reath LLP

Foreign Contract and Gift Reporting Deadline Approaches for Higher Education Institutions, As Does a Revised Reporting Process

As discussed in a previous alert dated June 18, 2019, the U.S. Department of Education (the “Department”) over the last year increased its scrutiny of postsecondary institutions’ contracts with, and gifts from, foreign...more

Hogan Lovells

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

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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...more

Sheppard Mullin Richter & Hampton LLP

One Higher Ed Requirement To Know Now

The U.S. Department of Education is just now starting to pay attention to a reporting requirement in the Higher Education Act (HEA) that harkens back to the 1980s. Penalties for failure to properly report can be stark,...more

Sheppard Mullin Richter & Hampton LLP

The U.S. Government Investigates U.S. Universities Participating in the “Confucius Institutes” Program

In July, the U.S. Department of Education Notices of Investigation to four U.S. universities seeking information on the “Confucius Institutes” operating on their campuses. The investigations center on provisions of the Higher...more

Holland & Knight LLP

Foreign Gifts to U.S. Educational Institutions Under Increased Scrutiny

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• U.S. institutions of higher education are required to report foreign gifts and contracts under Section 117 of the Higher Education Act. • The U.S. Department of Education has launched investigations into at least four...more

Faegre Drinker Biddle & Reath LLP

Higher Education Institutions under Increased Scrutiny for Foreign Contracts and Gifts

The U.S. Department of Education (the Department) in recent months has undertaken increased scrutiny of postsecondary institutions’ contracts with, and gifts from, foreign entities and individuals. Although long-required to...more

Ballard Spahr LLP

CFPB releases report on college credit card agreements and compliance bulletin

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The CFPB released its annual report on college credit card agreements (the fifth issued by the CFPB), together with a compliance bulletin regarding the obligation of colleges and universities under the CARD Act to publicly...more

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