Under Section 117 of the Higher Education Act, universities that receive federal financial assistance under Title IV, like the University of Oregon, must report incoming gifts and contracts from foreign entities of $250,000 or greater. The reporting threshold is determined at the institutional level, not at the individual department level. Section 117 reporting occurs biannually (due July 31 and January 31) for reporting periods January 1 – June 30 and July 1 – December 31.
Under the CHIPS and Science Act, universities that receive funding from the National Science Foundation, like the University of Oregon, must report incoming gifts and contracts from foreign entities located in a country of concern of $50,000 or greater. The reporting threshold is determined at the institutional level, not at the individual department level. The report occurs annually, due October 31, for a reporting period of July 1 – June 30.
The Export Control Office completes and submits the required reporting on behalf of the UO. The office collects potentially reportable transactions from individual units and aggregates the data to determine if reporting thresholds have been met.
Department Responsibilities
Departments are responsible for reporting incoming transactions from foreign entities to the Export Control Office. Departments that enter into a contract with a foreign source or receive a gift from a foreign source must submit information about that transaction. The Export Control Office conducts biannual outreach (in July and January) to departments most likely to have reportable transactions.
Consequences of Noncompliance or Inaccurate Reporting
Consequences of noncompliance with Section 117 and CHIPS and Science Act reporting can be severe. Noncompliance with Section 117 can lead to the termination of Title IV eligibility, meaning the institution would lose access to federal student aid programs. The Trump Administration’s Executive Order 14282 makes accurate reporting under Section 117 a condition of receiving federal grant funds. Noncompliance with CHIPS and Science Act reporting can include potential penalties and restrictions on future funding.
Contact
Questions about foreign financial reporting can be directed to Associate Director of Conflicts of Interest and Export Controls Mandy Gettler.