HEA 117 Reporting FAQ

Section 117 of the Higher Education Act (HEA) of 1965 requires that institutions of higher education participating in Title IX student assistance programs must report gifts or contracts from a foreign source that, alone or combined, have a value of $250,000 or more for a calendar year. The University must report this information by January 31 or July 31 (whichever is sooner) after the date of receipt of the gift or contract.

To help fulfill its reporting obligations, the University has enlisted the help of select representatives from schools, colleges, units, and departments. For additional questions about the University’s process to fulfill HEA 117 requirements and the role schools, colleges, units, and departments play in the process, please email HEA.117.Disclosures@umich.edu(link is external).

The following FAQs have been developed to help unit representatives fulfill their role in this process. if you have additional questions please email HEA.117.Disclosures@umich.edu(link is external). We’ll be updating this page regularly. If you have suggestions for additions to this page, please email HEA.117.Disclosures@umich.edu(link is external).

My gift/contract information was processed through DART/eRPM. Do I need to include it in the Unit Data Collection spreadsheet?

No. Gifts and contracts that were processed through the DART system and the eRPM system that need to be reported to the Department of Education to comply with the HEA 117 reporting requirement will be identified through system queries run by staff in the Office of University Development (OUD) and the Office of Research and Sponsored Projects (ORSP).

I have contracts that were handled though the U-M Tech Transfer. Do they need to be reported on the Unit Data Collection spreadsheet?

While we’re working with to U-M Tech Transfer to get this information, we encourage you to still report it to us using the Unit Data Collection spreadsheet and we’ll ensure that no duplicate information is reported to the Department of Education.

Do gifts of equipment, materials, supplies, etc. need to be reported on the Unit Data Collection spreadsheet?

Yes. “In-kind” gifts of property need to be reported if they have a value of $10,000 or more.

Do I need to report my procurement transactions (i.e., purchases) with foreign countries?

No. HEA 117 reporting is only concerned with incoming funds to the institution, not outgoing.

Do I need to report tuition payments from a foreign source?

Yes. In general, the Department of Education considers instances where a foreign source pays tuition for a student or students to meet the definition of a “contract” under Section 117(h)(1).