Section 117 Requirement
Over 30 years ago, Congress enacted Section 117 of the Higher Education Act of 1965 (HEA) in light of concerns about the growing financial relationship between U.S. universities and foreign sources. Congress balanced academic freedom and national security by mandating financial transparency through required reporting of contracts with and gifts from a foreign source that, alone or combined, are valued at $250,000 or more in a calendar year.
New Reporting Requirements will include:- Required identification of donors,
- Expanded definition of institutions,
- Expanded definitions and information requirements for foreign sources,
- Identification of intermediaries, and
- Detailed information on foreign contract restrictions.
Dept of Education guidelines on reporting
https://ifap.ed.gov/electronic-announcements/062220ReminderRprtOwnerContrlContrctsGiftsForeignSrcDept of Education Report
October 20, 2020https://www.ed.gov/news/press-releases/us-department-education-uncovers-vast-underreporting-foreign-gifts-and-contracts-higher-education-institutions
Section 117 Disclosure Submission Form
Over 30 years ago, Congress enacted Section 117 of the Higher Education Act of 1965 (HEA) in light of concerns about the growing financial relationship between U.S. universities and foreign sources. Congress balanced academic freedom and national security by mandating financial transparency through required reporting of contracts with and gifts from a foreign source that, alone or combined, are valued at $250,000 or more in a calendar year.
The University of New Mexico has a process by which we collect foreign source gifts and contracts that are routed through the various UNM accounting offices (i.e. UNM Foundation, the Office of Sponsored Projects and Contract and Grant Accounting, Global Education Office, etc.). In the event a foreign source gift or contract is received directly by a department or PI, in connection with research done at UNM, and wasn’t first routed or approved by a UNM accounting office, we require that information be disclosed using the newly created Section 117 Disclosure Submission Form. This form was created based on the Department of Education’s Foreign Gift and Contract Disclosure Form, and is intended to fulfill the reporting and compliance requirements of Section 117. Please report any monetary gifts or contracts received from a foreign source, regardless of dollar amount. If the gift or contract received was routed through a UNM accounting office or UNM Foundation, there is no need to complete the disclosure form, as this information is being captured and reported by the responsible accounting office.
Submit Disclosures here
Note
Please note that Section 117 Reporting requirements have different disclosure responsibilities required of the PI.
For more information contact
Jeremy Hamlin
Associate Controller
Email: jhamlin@unm.edu Phone: 277-7721
Email: jhamlin@unm.edu Phone: 277-7721