Congress enacted section 117 of the Higher Education Act, as amended, (Section 117) mandating financial transparency of institutions of higher education (institution) through required reporting of gifts from and contracts with a foreign source. Applicable institutions must file a disclosure report by one of the two annual reporting deadlines, January 31 or July 31, whichever is sooner, once the reporting obligation has been triggered. Section 117 helps to raise awareness of potential foreign influence on college campuses which could help stakeholders assess, detect, and respond to potential threats to U.S. academic and research pursuits, free speech on campuses, and national security. We conducted an inspection to evaluate FSA’s oversight of institutions’ reporting of foreign gifts and contracts under Section 117. To answer our objective, we reviewed FSA’s oversight activities, along with FSA’s monitoring plan, policies, and procedures related to its oversight of institutional reporting under Section 117. We also determined if FSA is accurately posting the data it receives from institutions. We found that FSA’s oversight of institutions’ reporting of foreign gifts and contracts under Section 117 needs improvement. Specifically, FSA’s oversight activities are limited to reviewing whistleblower tips, Department of Education news bulletins, and other media reports for potential institutional noncompliance with Section 117 and providing technical assistance to institutions. FSA does not have any monitoring plans, policies, or procedures in place for its oversight of Section 117 reporting. Additionally, we found that FSA is accurately posting the data it receives from institutions through its Section 117 reporting portal onto its public-facing website; however, FSA could improve its Section 117 reporting portal to assist in identifying and reducing data input errors.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 1.1 | Yes | $0 | $0 | ||
| We recommend the FSA Chief Operating Officer— Assess FSA’s planned resourcing to ensure institutional compliance with Section 117 reporting requirements and make changes, as appropriate. | |||||
| 1.2 | Yes | $0 | $0 | ||
| We recommend the FSA Chief Operating Officer— Develop and implement a monitoring plan, policies, and procedures, along with a related timeframe for doing so, that includes a risk-based framework and activities designed to assist with detecting inaccuracies, incomplete submissions, or instances of non-reporting and that motivates institutions to comply with the requirements of Section 117. | |||||
| 1.3 | Yes | $0 | $0 | ||
| We recommend the FSA Chief Operating Officer— Require an annual certification, to cover the preceding year, from a high-level official at all institutions receiving Title IV funds certifying full compliance with Section 117 reporting requirements. | |||||
| 1.4 | Yes | $0 | $0 | ||
| We recommend the FSA Chief Operating Officer— Include edit checks in the Department’s Section 117 reporting portal system or implement other data monitoring processes that would ensure: (1) institutions are properly classifying gifts and contracts as restricted based on answers to related questions, (2) all restricted gifts and contracts include required descriptions, and (3) potential duplicate entries are flagged for further review. | |||||
| 1.5 | Yes | $0 | $0 | ||
| We recommend the FSA Chief Operating Officer— Ensure that the portal includes adequate descriptors of country names for those that may be confusing (e.g., North Korea). | |||||
| 1.6 | Yes | $0 | $0 | ||
| We recommend the FSA Chief Operating Officer— Develop a more efficient process for preparing data for posting on the website. | |||||
