Foreign Financial Support Reporting
Background
UNM must report certain foreign gifts received and contracts entered into as required by federal law. Considering these laws, granting institutions, such as the National Science Foundation, are also requiring reporting of gifts and contracts related to foreign countries of concern.
Section 117 of the Higher Education Act
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.
CHIPS and Science Act
Congress passed the CHIPS and Science Act of 2022 (42 U.S.C. §19040) which showed a concern of financial support given to U.S. Higher Education Institutions received by foreign countries of concern, as determined by the Secretary of State. In accordance with Section 10339B, Foreign FInancial Support, of this act, the National Science Foundation in 2024 started requiring a report of gifts, contracts, money, and other items that value $50,000 or more from July through June that originated from countries of concern. This includes financial support received through agents associated with the foreign country of concern.
Reporting Requirements 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.
Internal Reporting Requirements
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 Foreign Gifts Reporting Disclosure Submission Form located https://app.smartsheet.com/b/form/2a94d7e28624455f83570e28384fcb23. This form was created based on the Department of Education’s Foreign Gift and Contract Disclosure Form as well as the National Science Foundation report and is intended to fulfill the reporting and compliance requirements of both Section 117 and NSF. Please report any monetary gifts or contracts received from a foreign source, regardless of dollar value. 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.
Please note that the Foreign Financial Support reporting has different disclosure responsibilities required of the PI.
Resources
Dept of Education guidelines on reporting - https://ifap.ed.gov/electronic-announcements/062220ReminderRprtOwnerContrlContrctsGiftsForeignSrc
National Science Foundation guidelines on reporting - https://new.nsf.gov/policies/pappg/24-1/ch-7-award-administration Chapter VII, D. 3.
University of New Mexico Policy [Currently undergoing review]
FAQs – Please see the FAQ page for additional information.
For more information or if questions, contact
Contract and Grant Accounting ~ Email: indexcga@unm.edu
