ED’s Office of General Counsel announced some major changes to institutions obligations under Section 117 of the Higher Education Act which requires institutions to disclose information about ownership and control by foreign sources, contracts with foreign sources, and gifts from foreign sources. Schools have historically reported this information on their E-App (Electronic Application) in question 71, however the Department announced that beginning on June 22, 2020 Section 117 information must be reported using the Department’s new reporting system available at

Federal law requires most 2-year and 4-year postsecondary schools to report ownership or control by foreign sources and contracts with or gifts from the same foreign source that, alone or combined, have a value of $250,000 or more for a calendar year.

Generally, a school must report this information by January 31 or July 31 (whichever is sooner) after the date of receipt of the gift, date of the contract, or date of ownership or control. The January 31 report should cover the period July 1–December 31 of the previous year, and the July 31 report should cover January 1–June 30 of the same year.