Foreign Gifts and Contracts Reporting changes

Section 117 of the Higher Education Act requires schools to submit reports about gifts and contracts that are $250,000 or greater from any foreign source. In the recent past, this was done through OSF and the E-App two times a year (January and July), with information collected by Accounting Services. Recent congressional concerns about foreign influence in schools has resulted in a new reporting tool that requires significantly more information reported, including student tuition paid for by embassies and foreign quasi-government agencies.

In addition, copies of the contracts and donations must be supplied as supporting documentation. You can imagine the volume this represents for an institution of our size and diversity. The new reporting tool appears to have been designed without end user input. For example, thousands of data elements cannot be uploaded in a spreadsheet, but rather, it must be uploaded individually. The Controller's Office has taken the lead on the data and its submission. To our knowledge, there is no pending legal action by school(s) to address this significant expansion of federal oversight or the administrative burden this new tool represents.

Unfortunately, data entry in the new reporting tool will be frustrating as it was poorly designed. The tool requires more data elements but has no ability for multiple uploads. To better understand how this system works, see the grocery store analogy below.

You’ve been given a shopping list with various items, such as meat, baked goods, dairy products, and beverages. Typically, you’d go through the aisles at your grocery store to get all of your meat, all of your bakery, and so on, until you can check out with a full cart.

However, with this system, there is institutional information that has four categories, just like the shopping list. But first, you can only go to the meat department and take one item, then you can go to the bakery and take one item, and so on, until you have to check out with no more than four items total in your cart.

Then, in order to get the rest of your items, you have to go back to the store with a new shopping cat, and like the first time, get no more than one item from each department. Even when you have nothing left on your list from a department, you still have to go through that aisle in order to get the last item on your list.

For a small college with one or two gifts, this system is perfectly designed since they would only need to check out once or twice. However, for a large school with hundreds, if not thousands of discrete entries, due to different transaction dates, etc., this process is a lot more complicated and tedious.