Resources

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
USF Athletics

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