This is a reminder of the upcoming deadline for the biannual Higher Education Act Section 117 report. Please review your unit's records to identify and submit all relevant transactions to the Office of Risk Management and Compliance by January 16th.
Did your unit have any transactions (contracts, grants, gifts, etc.) valued at $1,000 or more that involved a foreign source?
If YES, then:
- Complete the Section 117 Reporting Template - Foreign Gifts and Contracts spreadsheet detailing the transaction(s).
- Email the completed spreadsheet to Brandie Roberts (brandie.roberts@uah.edu) and CC Kevin Bennett (kevin.bennett@uah.edu) by January 16, 2026.
If NO, then:
- Email “no reportable transactions” to Brandie Roberts (brandie.roberts@uah.edu) and CC Kevin Bennett (kevin.bennett@uah.edu) by January 16, 2026.
|
Example Scenarios
|
Do I report this transaction?
|
|
Contract for housing and event space received from a foreign source
|
YES
|
|
Gift from a foreign source valued in the aggregate at less than $1,000
|
NO
|
|
Multi-year contract or grant that began between July 1 and December 31, 2025 and exceeds $250,000 in total value
|
YES
|
|
Multi-year contract or grant that began between January 1 and June 30, 2025 and exceeds $250,000 in total value
|
YES
|
|
Tuition payments received directly from private individuals who are foreign nationals that do not exceed $50,000 in any 6 month period (with no knowledge of additional receipt of other gift/contract funds from the same individual)
|
NO
|
|
Monies received from different subdivisions within a foreign government (e.g. health, education, and defense ministries)
|
YES
|
Section 117 of the Higher Education Act requires that UAH file a US Department of Education disclosure report twice annually that identifies each and every gift received from, or contracts with, any foreign source that exceeds, alone or in the aggregate, $250,000.00 in value (when considered alone or in combination with other gifts or contracts from the same foreign source) within a calendar year.
Foreign source is broadly defined to include:
- a foreign government, including an agency, subdivision, unit, or instrumentality of a foreign government;
- a legal entity - whether governmental, non-profit, corporate, or other - created under the laws of a foreign state or states;
- an individual who is not a citizen or a national of the U.S. or of a U.S. territory or protectorate; or
- an agent, including intermediaries and any subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.
Questions regarding whether a transaction is reportable should be forwarded to Brandie Roberts (brandie.roberts@uah.edu) and Kevin Bennett (kevin.bennett@uah.edu). The Office of Risk Management and Compliance will work with appropriate offices to determine whether a source is reportable.