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Gifts and Contracts

Guidance for Reporting Foreign Gifts and Contracts

Federal Foreign Gifts & Contracts Reporting Guidelines
Requirements

Federal:
Higher Education Act of 1965, Sec. 117

Type of Transactions to be Reported Gifts and contracts received from foreign sources, to include subsidiaries and affiliates; e.g., monies, properties, or services to the institution.
Threshold $250,000 or more from the same entity in the calendar year (January 1st to December 31st); aggregated amounts must be considered when reporting.
Reporting Periods
Twice a year; January 31st and July 31st
Supplementary Documentation Required
None
State Foreign Gifts & Contracts Reporting Guidelines
Requirements State:
Fla. Stat. §1010.25 
Type of Transactions to be Reported Gifts and contracts received from foreign sources, to include subsidiaries and affiliates; e.g., monies, properties, or services to the institution.
Threshold $50,000 or more, from and/or to the same foreign entity in a fiscal year (July 1st to June 30th); aggregated amounts must be considered when reporting.
Reporting Periods Twice a year; January 31st and July 31st
Supplementary Documentation Required
  • Copies of contracts and/or agreements for each reportable transaction, redacted where applicable by state law i.e., Fla. Stat. § 1004.22(2): Foreign Contracts/Agreements and/or Fla. Stat. § 1004.28: Foreign Gifts Agreements
  • Redacted contracts and/or agreements must be accompanied by an abstract. See abstract form below.
  • Student sponsorship transactions must be accompanied by FL BOG student sponsorship summary form and sample sponsorship letter; protected student information must be redacted in accordance with the Family Educational Rights and Privacy Act (FERPA). See FL BOG Summary Form below.
Reporting Units & Reportable Transactions
Reporting Units Transactions to Report, meeting reporting threshold
±«Óãtv Athletics

Contracts, agreements, gifts, donations, pledges from foreign sources.

±«Óãtv Controller's Office Tuition and fees paid by foreign source or a foreign student.
±«Óãtv Health Office of Clinical Research
Contracts and/or agreements from foreign sources.
±«Óãtv Controller's Office-Purchasing
Purchases made from foreign sources; both inbound and outbound transactions should be reported. 
±«Óãtv Sponsored Research Contracts and/or agreements from foreign sources.
±«Óãtv Foundation Gifts, donations, pledges from foreign sources.

Reporting Unit Responsibilities

  • Keep a record of all gifts and contracts received from foreign sources.
  • Monitor the purchase of goods and services from countries of concern.
  • Identify companies connected to foreign sources.
  • Submit all relevant transactions to the Office of Compliance and Ethics using the designated spreadsheet and within the specified deadline.
  • Provide the Office of Compliance and Ethics with agreements in PDF format with required supplementary documentation.
  • Ensure to redact agreements as required by law, submitting an abstract with the redacted agreement.
  • Notify the Office of Compliance and Ethics promptly if any foreign gifts/contracts worth $50,000 or more are discovered after the reporting deadline.

Forms and Additional Information

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