Section 117 Reporting

Section 117 of the Higher Education Act of 1965 requires U.S. colleges and universities to report to the U.S. Department of Education any gifts from or contracts with a foreign source that meet or exceed $250,000 in value, alone or combined, within a calendar year.  This federal reporting requirement is designed to promote transparency in higher education funding, especially as it relates to potential foreign influence or investment in U.S. institutions.  We take our compliance obligations seriously, and departments that engage with international funders may be contacted to help ensure accurate and timely reporting.

Under Section 117, a foreign gift is any donation or transfer of money or value from a foreign source, without an expectation of return. A foreign contract refers to any agreement in which CMU receives something of value from a foreign source in exchange for services, research, instruction, or other deliverables. 

A foreign source includes:

• A foreign government, including national, regional, or local entities
• A foreign legal entity, such as a corporation, partnership, or foundation that is created or organized under foreign law
• A foreign individual who is not a U.S. citizen or lawful permanent resident
• Any U.S.-based entity that is controlled by a foreign source, such as a U.S. subsidiary of a foreign corporation 

Gifts or contracts must be reported if the total value received from a single foreign source is $250,000 or more within a calendar year, whether as a single transaction or as a combination of multiple transactions. 

If you're unsure whether a gift or agreement meets the definition, you are encouraged to submit a report for review by the coordinator.

If you believe your department has received a foreign gift or entered into a contract with a foreign source, you will be asked to provide enough detail to determine whether the transaction is reportable under Section 117.

The following information is requested:

• Name of the foreign source (individual, organization, or government entity)
• Country of origin
• Type of transaction (gift or contract)
• Total dollar amount received or committed
• Date(s) the gift or contract was received or executed
• Purpose or use of the funds (e.g., research support, student scholarships, program development)
• Copies of relevant documentation, such as:
  • Gift letters or agreements
  • Contracts or MOUs
  • Invoices or payment records
  • Email confirmations, if formal agreements are not available 

This information helps determine whether the transaction meets the $250,000 reporting threshold and qualifies as reportable under federal regulations. 

If you're unsure whether documentation is sufficient, or if the foreign source meets the federal definition, please contact the Section 117 coordinator for assistance before submitting.

To ensure consistency and accuracy in reporting, we encourage you to use the Section 117 reporting form.  This fillable form is designed to collect all the key information that we are required to submit to the Department of Education.

• Name and contact information of the submitting department
• Name and country of the foreign source
• Type of transaction (gift or contract)
• Total amount received or committed
• Dates of the transaction
• Purpose or use of the funds
• Description of the transaction
• Attachments or supporting documentation
  

Completed forms and any accompanying documents should be submitted to the Section 117 coordinator by the date indicated in the reporting period announcement. 

If you need assistance completing the form or are unsure which documents to include, please contact the Section 117 coordinator for guidance.