UW–Madison is required to report to the U.S. Department of Education (ED) each January and July regarding gifts received from foreign sources and contracts entered into with foreign sources. The reporting threshold is when gifts and contracts, alone or combined with other gifts and contracts from the same foreign source, have a value of $250,000 or more in a calendar year period. If the reporting threshold is met between January through June, the institution must report the information to ED in July. If the reporting threshold is met between January through December, the institution must report the information to ED in January of the following calendar year.
In 2020, ED explicitly stated foreign source contracts include tuition for students paid by a foreign source, intellectual property license fees from a foreign licensee, and data or materials sold, leased, or bartered to a foreign source. ED also expressly stated that foreign source gifts or contracts received at an intermediary organization are required to be included in an institution’s disclosure report to ED. This means when an organization other than UW–Madison receives a gift from or enters into a contract with a foreign source where the gift or contract is for the benefit of the institution, the gift or contract is to be considered when determining which UW–Madison receipts meet the reporting threshold.