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Higher Education Act Compliance Calendar

(Adapted from the Catholic University of America Compliance Calendar on the CUA Office of General Counsel website) 

This calendar sets forth the major deadlines required for compliance with the Higher Education Act and other federal requirements for institutions participating in financial aid programs.

 

January

Higher Education Act of 1965 as amended (See also, July)

20 U.S.C. § 1011f 

By January or July 31 of each year, whichever is sooner depending on the time of the gift, a postsecondary institution must file a disclosure report about ownership or control by, or contracts with or gifts from foreign sources. The institution shall file a disclosure report with the Department of Education for gifts and contracts of $250,000 or more received within a calendar year. 

Student Loan Interest Reporting

26 U.S.C. § 6050S; 26 CFR 1.6050S-3 and 26 CFR 1.6050S-4T (see 67 Fed. Reg. 20901 final and temporary regulations)

Lenders, including most colleges and universities that participate in the Perkins Loan Program or operate institutional loan programs, must report student loan interest payments to the IRS on or before February 28, or March 31 if filed electronically. The required statement to all persons who made student loan interest payments must be sent to the payor on or before January 31 of the year following the calendar year in which the interest payments were received. 

Program Participation Agreements and IPEDS

20 U.S.C. § 1094(a)(17); 34 C.F.R. § 100.6; 29 C.F.R. §§ 1602.48-50

As part of the program participation agreements signed in connection with financial aid, an institution must complete surveys conducted four times a year as a part of the Integrated Postsecondary Education Data System (IPEDS) or any other Federal postsecondary institution data collection effort, as designated by the Secretary, in a timely manner and to the satisfaction of the Secretary. Filing the required IPEDS forms also fulfills certain reporting requirements under Titles VI and VII and the ADA

 

February 

Student Loan Interest Reporting

26 U.S.C. § 6050S; 26 CFR 1.6050S-3 and 26 CFR 1.6050S-4T (see 67 Fed. Reg. 20901 final and temporary regulations)

Lenders, including most colleges and universities that participate in the Perkins Loan Program or operate institutional loan programs, must report student loan interest payments to the IRS on or before February 28, or March 31 if filed electronically.

Tuition Payment Credit Reporting Requirements 

26 U.S.C. § 6050S; 26 CFR 1.6050S- 2T 

Form 1098-T must be filed with the IRS by February 28 (or March 31, if filed electronically) of the year following the calendar year during which payments were received.

 

March 

The Student Right to Know Law: Information on Completion or Graduation Rates  

20 U.S.C § 1092; 34 CFR §§ 668.41 and 668.45

The disclosure date is July 1 following 150% of the normal time for completion/graduation from its programs. Completion of the Graduation Rate Survey (GRS) (part of IPEDS reporting done in March -April meets the reporting requirements of the Student Right to Know Law). 

Program Participation Agreements and IPEDS  

20 U.S.C. § 1094(a)(17); 34 C.F.R. § 100.6; 29 C.F.R. §§ 1602.48-50

As part of the program participation agreements signed in connection with financial aid, an institution must complete surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) or any other Federal postsecondary institution data collection effort, as designated by the Secretary, in a timely manner and to the satisfaction of the Secretary. Filing the required IPEDS forms also fulfills certain reporting requirements under Titles VI and VII and the ADA. The Spring data collection typically opens in March and closes in April.

 

April  

Teacher Education Program Reporting Requirements  

20 U.S.C. § 1027 (f)

Universities must report annually to their state government and the public the pass rate on state teacher certification examinations taken by their graduates. The reporting deadline is April 1

 

May

 

June

 

July 

The Student Right to Know Law: Report on Completion or Graduation Rates for Student Athletes 

20 U.S.C § 1092; 34 CFR §§ 668.41 and 668.48

By July 1st of each year, an institution that offers athletically related student aid must submit a report to the Secretary of Education that covers the 1-year period ending August 31 of the previous year. If the school is a member of the NCAA, the NCAA satisfies the individual institution's responsibility to provide prospective student-athletes and their parents, high school coach and guidance counselor their report on completion or graduation rates for student athletes by distributing the NCAA compilation of graduation rate statistics to all secondary schools in the United States. 

The Student Right to Know Law: Information on Completion or Graduation Rates  

20 U.S.C § 1092; 34 CFR §§ 668.41 and 668.45

The disclosure date is July 1 following 150% of the normal time for completion/graduation from its programs. Completion of the Graduation Rate Survey (GRS) (part of IPEDS reporting done in March -April meets the reporting requirements of the Student Right to Know Law). 

Program Participation Agreements and IPEDS  

20 U.S.C. § 1094(a)(17); 34 C.F.R. § 100.6; 29 C.F.R. §§ 1602.48-50

As part of the program participation agreements signed in connection with financial aid, an institution must complete surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) or any other Federal postsecondary institution data collection effort, as designated by the Secretary, in a timely manner and to the satisfaction of the Secretary. Filing the required IPEDS forms also fulfills certain reporting requirements under Titles VI and VII and the ADA. 

Higher Education Opportunity Act of 2008 and ISBN Textbook Provision  

Effective July 1, 2010 (to the maximum extent feasible) each school shall disclose the International Standards Book Number ("ISBN") and retail price for required and recommended textbooks and supplemental materials for each course listed on the schedule (posted on the web or printed course schedule). If no ISBN is available, the institution may provide the textbook's author, title, publisher, and copyright date. If the disclosure is not practical for a certain text, a designation of *to be determined* can be noted. Written course schedules should indicate where on the university web page this info will be posted. HEOA encourages schools to disseminate information regarding book rentals, used textbooks, buy back programs, and alternative delivery programs or other cost saving strategies. Schools shall make available to the college bookstore, upon request, the most accurate information regarding the course schedule for the next academic period and for each course offered, the information described above, the number of students enrolled in such course, and the maximum enrollment for each class. 

Higher Education Act of 1965 and Higher Education Amendments of 1998  

20 U.S.C. § 1011f (see also January)

By January or July 31 of each year, whichever is sooner depending on the time of the gift, a postsecondary institution must file a disclosure report about ownership or control by, or contracts with or gifts from foreign sources. The institution shall file a disclosure report with the Department of Education for gifts and contracts of $250,000 or more received within a calendar year.

 

August  

Voter Registration Provision in Higher Education Amendments of 1998  

Pub. L. No. 105-244, 112 Stat. 1581 (1998) and 20 U.S.C. § 1094(a)(23)(A)

In states with a voter registration requirement, the institution must request voter registration forms from the state 120 days prior to the deadline for registering to vote and make the forms "widely available" to each student enrolled in a degree or certificate program and physically in attendance at the institution. This requirement may be satisfied by providing students with a link to state online registration forms. This requirement applies to all primaries and elections for federal office and state gubernatorial elections. 

The Family Educational Rights and Privacy Act of 1974 (FERPA)  

20 U.S.C. § 1232g(e); 34 CFR § 99.7 and distribution also referred to in 20 U.S.C. § 1092(a)

Each educational agency or institution shall annually notify students currently in attendance, of their rights under FERPA. Notification of these rights concurrent with fall registration is suggested, as the student needs to be notified of his/her opportunity to place a hold on release of directory information. 

 

September  

Campus Security Act of 1990  

20 U.S.C. § 1092(a)(1) (O ) and § 1092 (f) (5) and 34 C.F.R. § 668.46 and § 668.41

The Campus Security Act requires colleges to report campus crime statistics and security measures to all students and employees by October 1 of each year. Crime statistics must be submitted to the Department of Education by October 15th of each year. 

Disclosure of Fire Safety Statistics and Safety Measures 

Section 485 of the Higher Education Opportunity Act of 2008; 20 USC §1092(i)

The institution must annually report to the Department of Education statistics regarding any fires that may have occurred in campus housing by October 15th of each year. An annual report summarizing fire safety measures and procedures and fire statistics for campus housing must be made available to students and prospective students by October 1 of each year. 

Emergency Response Policies and Procedures as required by HEOA 2008 

Institutions are required to disclose emergency response policies and evacuation procedures in the annual security report, which must be available by October 1 of each year.

Campus Sex Crimes Prevention Act  

Pub. L. No. 106-386 and 42 U.S.C. § 14071j and 20 U.S.C. § 1092(f)(1)(I)

Notification may be accomplished by adding a statement to the annual security report required by the Campus Security Act. Suggested deadline of October 1 of each year to coincide with Annual Security Report.  

General Provisions Relating to Student Assistance Programs (Program Participation Agreements):

Financial Aid and Institutional Information  

20 U.S.C. §§ 1092(a) and 1094; 34 C.F.R. §§ 668.42 and 668.43 et seq

The institution must publish and make readily available to current and prospective students information on the entire Federal, State, local, private and institutional financial assistance programs available to students who enroll at the institution. Institutional information must also be made available as well. Students must receive annual notice of the availability of this information. No deadline specifically enumerated, but typically occurs before the end of September. 

Missing Student Notification Policy and Procedures 

20 USC §1092 (j)

Any institution participating in a Title IV federal student financial aid program that maintains on campus housing facilities must establish a missing student notification policy and related procedures for those students who live in on campus housing and who have been missing for 24 hours. Students must receive an annual notice of this policy and procedures. No deadline is specifically enumerated, but typically occurs before the end of September. 

Equity in Athletics Disclosure Act of 1994  

20 U.S.C. § 1092g; 34 C.F.R. §§ 668.41 and 47

Each coed institution of higher education that participates in Title IV programs and has an intercollegiate athletic program must make available on request by October 15 of each year to enrolled students, prospective students, and the public a report regarding gender equity in its athletic programs. Students must receive an annual notice of the availability f this report. No deadline is specifically enumerated, but typically occurs before the end of September. Within 15 days of making the report available to students, prospective students, and the public and no later than October 30th of each year, the institution must submit the report to the Secretary of Education. 

The Drug-Free Schools and Communities Act Amendments of 1989 

20 U.S.C. § 1011i and 34 C.F.R. § 86.100

The institution is required to annually distribute to students and employees the institution's standards of conduct with respect to illegal drugs and alcohol, a description of the applicable legal sanctions and health risks; as well as availability of drug and alcohol counseling available to employees and students. The disclosure must also include a statement on sanctions the institution will impose for violation of the standards of conduct. No deadline is specifically enumerated, but typically occurs before the end of September. 

Program Participation Agreements and IPEDS  

20 U.S.C. § 1094(a)(17); 34 C.F.R. § 100.6; 29 C.F.R. §§ 1602.48-50

As part of the program participation agreements signed in connection with financial aid, an institution must complete surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) or any other Federal postsecondary institution data collection effort, as designated by the Secretary, in a timely manner and to the satisfaction of the Secretary. Filing the required IPEDS forms also fulfills certain reporting requirements under Titles VI and VII and the ADA. The Fall data collection typically opens in September and closes in October. 

 

November

 

December  

Program Participation Agreements and IPEDS  

20 U.S.C. § 1094(a)(17); 34 C.F.R. § 100.6; 29 C.F.R. §§ 1602.48-50

As part of the program participation agreements signed in connection with financial aid, an institution must complete surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) or any other Federal postsecondary institution data collection effort, as designated by the Secretary, in a timely manner and to the satisfaction of the Secretary. Filing the required IPEDS forms also fulfills certain reporting requirements under Titles VI and VII and the ADA. The Winter collection typically opens in December and closes in January.


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