The calendar highlights important reporting deadlines for institutions of higher education based on federal obligations described in the Higher Education Compliance Alliance matrix and other obligations addressed in UW System PoliciesHigher Learning Commission Policies, the State Authorization Reciprocity AgreementIntegrated Postsecondary Education Data System, and the Wisconsin Ethics Commission’s Eye on Lobbying. It is not meant to be a comprehensive compliance calendar.

January

Higher Education Opportunity Act (also see July)

By January 31st or July 31st 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.

Independent Contractors

Form 1099-MISC must be filed with the IRS if the employer makes payments to independent contractors in the amount of $600 or more during the year. A copy of same must be provided to the independent contractor by January 31 of the following year.

Reporting of Payments of Royalties (also see February)

Annual reporting is required for payments:

  • Of $400 or more made for non-payroll purposes;
  • Of $10 or more made for royalties; and
  • Made to attorneys not performing services under a contract with the university.

Reporting is done on Form 1099-MISC. Deadline to payment recipients is January 31st. Deadline for reporting to the IRS is February 28th.

Internal Revenue Code: W-2 Forms

By January 31 of the year succeeding the calendar year in which wages were paid to an employee, the employer must furnish the tax return copy and the employee’s copy of Form W-2.

Wisconsin Ethics Commission Principal Lobbying Efforts (also see July)

By January 31 and July 31 lobbying hours and efforts for the preceding six months to be filed.

Honest Leadership and Open Government Act of 2007 (also see July)

Requires active lobbying registrants and individual lobbyists to file a semi-annual report of certain contributions along with certification that the filer understands the gift and travel rules of both the House and the Senate by the following deadlines: July 30 Mid-Year (January 1 – June 30) January 30 Year End (July 1 – December 31)

Qualified Tuition and Student Loan Interest Reporting (also see February)

The required statement to all persons who made qualified tuition or student loan interest payments must be sent to the payor on or before January 31st of the year following the calendar year in which payments were received or amounts were billed for qualified tuition and related expenses, or in which the student loan interest payments were received. The statement may simply be a copy of Form 1098-T or Form 1098-E, respectively.

February

Qualified Tuition and Student Loan Interest Reporting

Institutions must complete Form 1098-T (qualified tuition payments) and Form 1098-E (student loan interest payments), both of which must be filed with the IRS on or before February 28th, or March 31st if filed electronically.

Program Participation Agreements and IPEDS (Winter Collection)

As part of the program participation agreements signed in connection with any Federal financial assistance program authorized by Title IV of the Higher Education Act (HEA) of 1965 as amended, an institution must complete the surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) in a timely manner and to the satisfaction of the Secretary.

Reporting of Payments of Royalties (also see January)

Annual reporting is required for payments:

  • Of $400 or more made for non-payroll purposes;
  • Of $10 or more made for royalties; and
  • Made to attorneys not performing services under a contract with the university.

Reporting is done on Form 1099-MISC. Deadline to payment recipients is January 31st. Deadline for reporting to the IRS is February 28th.

March

Emergency Planning and Community Right to Know Act (EPCRA)

By March 1st of each year, the owner or operator of any facility which is required to have available a material safety data sheet for a hazardous chemical under OSHA shall prepare and submit an emergency and hazardous chemical inventory format the appropriate local emergency planning committee; the state emergency response commission; and the fire department with jurisdiction over the facility. Hazardous chemical training must be conducted annually. Facilities must report the storage, use, and release of certain hazardous chemicals bi-annually.

Higher Learning Commission Institutional Update

Submission of the Institutional Update is a requirement for maintaining accreditation or candidacy with the Higher Learning Commission.

April

Program Participation Agreements and IPEDS (Spring Collection)

As part of the program participation agreements signed in connection with any Federal financial assistance program authorized by Title IV of the Higher Education Act (HEA) of 1965 as amended, an institution must complete the surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) in a timely manner and to the satisfaction of the Secretary.

May

Title IX Narrative Report to UW System due May 1.

There are no scheduled federal reports due in May.

June

Hazardous Materials Transportation Act

University personnel who transport or cause to be transported hazardous materials must file annually a registration statement by June 30.

Foreign Bank Accounts and Tax Filings

Form TD F 90.22-1 must be filed and received by June 30th of the year following any year during which the institution possessed signature or other authority over, or had a monetary interest in, foreign financial accounts.

NC-SARA Enrollment Data Reporting

Institutions participating in the State Authorization Reciprocity Agreement shall annually report to the National Council for State Authorization Reciprocity Agreements the number of students enrolled in the institution via distance education delivered outside the home state of the institution, disaggregated by state, territory, or district in which the students reside.

July

Student Right to Know Act

The University must publish [select financial aid] data by July 1st and the Spring IPEDS reporting satisfies that deadline.

Higher Education Opportunity Act (also see January)

By January 31st or July 31st 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 Exchange and Visitor Information System (SEVIS)

All J-1 sponsors must submit an annual report generated from SEVIS and a narrative report. Sponsors must submit an annual report to the Department of State. The report must be filed on an academic, calendar, or fiscal year basis, as stipulated on the program’s designation or re-designation letter. The due dates are:

  • For Academic Year end designees (June 30th): report due to the Department of State July 31st.
  • For Calendar Year end designees (December 31st): report due to the Department of State January 31st.
  • For Fiscal Year end designees (September 30th): report due to Department of State October 31st.

Toxic Substances Control Act

A written annual document log of the disposition of PCBs and PCB items must be prepared for each facility by July 1st, covering the previous calendar year (January through December). The written annual report, which summarizes the records and annual document log shall be submitted to the EPA Regional Administrator by July 15th of each year.

American Jobs Creation Act of 2004

The institution is expected to file Form 8899 (Notice of Income from Donated Intellectual Property) by the last day of the first full month following the close of the institution’s taxable year to which the net income from the contribution is properly allocable.

Wisconsin Ethics Commission Principal Lobbying Efforts (also see January)

By January 31 and July 31 lobbying hours and efforts for the preceding six months to be filed.

Honest Leadership and Open Government Act of 2007 (see also January)

Requires active lobbying registrants and individual lobbyists to file a semi-annual report of certain contributions along with certification that the filer understands the gift and travel rules of both the House and the Senate by the following deadlines: July 30 Mid-Year (January 1 – June 30) January 30 Year End (July 1 – December 31)

August

There are no scheduled federal reports due in August.

September

Higher Education Act (No deadline is mandated, but September 1 is recommended. Additional disclosure information is located in the NPEC Report.)

(Sections 152 and 153) – Require the following disclosures to enrolled students: “. . . c) transfer of credit policies; . . . f) diversity statistics; g) retention rates; h) employment placement data; i) fire safety report; . . . k) along with the course schedule, the International Standard Book Number (ISBN) of every required and recommended textbook and supplemental material and retail price info . . . Disclosures c) – k) must be available to prospective students as well.”

(Sections 152 & 153) – Require the following disclosures to enrolled students: a) Policies/sanctions for copyright infringement; and b) annual disclosure detailing federal copyright penalties.

Information Distributed to Students – No deadline for disclosures to enrolled students is set, but September 1 is suggested. Annually the institution must distribute to all enrolled students a notice of availability of the following: 1) financial assistance available; 2) institutional information (e.g., cost of attendance including tuition, room, board, books and transportation; refund policy; description of academic programs and facilities; withdrawal requirements, facilities for the disabled; names of accrediting or licensing entities); 3) retention, completion, graduation, and transfer-out rates; 4) employment and graduate school enrollment information for graduates of the institution’s degree programs; 5) annual security report; 6) report on athletic program participation rates and financial support data; 7) FERPA notice regarding how to obtain student information.

Penalties for Drug Violations – An institution must provide to each student (at time of enrollment) a written notice that advises the student that a conviction for any drug offense while receiving Title IV aid will result in a loss of eligibility for any Title IV, HEA grant, loan or work-study assistance.

Federal Supplemental Educational Opportunity Grant Program – Fiscal Operations Report and Application to Participate (FISAP) reports cover the institution’s fiscal operations and request for future funding for Title IV Federal campus-based funds (SEOG, Perkins Loans, Work-study, and Federal Pell Grants). Due by September 30 each year.

Perkins Loans – Operations Report and Application to Participate (FISAP) reports cover the institution’s fiscal operations and request for future funding for Title IV Federal campus-based funds (SEOG, Perkins Loans, Work Study, and Federal Pell Grants). Due by September 30 each year.

PLUS Loans – If applications are made for an FFEL PLUS loan, the University must: 1) Verify the parent’s immigration status and social security number in the same manner verified for students; 2) extend PLUS loans only to parents who do not have an adverse credit history; 3) extend such loans on the same terms, conditions and benefits as other FFEL loans; 4) for any academic year, limit the loan amount to the student’s estimated cost of attendance minus other financial aid; and 5) be disbursed to the institution electronically or co-payable to the school and parent.

Program Participation Agreements – 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. Although no deadline is specifically enumerated, September 1st is suggested. The institution should request the voter registration forms from the state at least 120 days before the deadline to register to vote. Employment statistics and state licensing requirements, if required, must be provided to prospective students at or before the time they apply.

Federal Work Study – Fiscal Operations Report and Application to Participate (FISAP) reports cover the institution’s fiscal operations and request for future funding for Title IV Federal campus-based funds (SEOG, Perkins Loans, Work-study, and Federal Pell Grants). Due by September 30 each year. The University must reconcile reported student earnings to complete Department of Education Fiscal Operations Report (Form 646-1) at the end of the academic year.

The Veterans’ Readjustment Benefits Act

By September 30th of each year the University must file Federal Contractor Veterans Employment Report (VETS-100) reporting the number of disabled veterans, Vietnam veterans and protected veterans employed and hired.

Energy Policy Act

Underground Storage Tank annual registration and postings required September 1 of each year.

Resource Conservation and Recovery Act

Underground Storage Tank annual registration and postings required by September 1 of each year.

Family Educational Rights and Privacy Act (FERPA)

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 told what information the student has identified as directory information and notified of his/her opportunity to place a hold on release of directory information.

October

Drug Free Schools and Communities Act

Requires annual distribution of the college or university’s drug and alcohol prevention and policy to students and employees and biennial review of drug and alcohol prevention program. The law does not mandate a particular date for distribution, but suggested distribution is to make this information part of the Annual Security Report distribution which is required by October 1st of each year.

Campus Sex Crimes Prevention Act

Institution must issue a statement advising the campus community on where information concerning registered sex offenders can be obtained. Notification may be accomplished by adding the statement to the Annual Security Report required by the Campus Security Act. Suggested deadline of October 1st of each year to coincide with the Annual Security Report.

Higher Education Opportunity Act

  • Annual Security Report. Institutions are required to disclose emergency response policies, evacuation procedures, and crime statistics to students and employees. Suggested deadline of October 1. The report must include a policy statement regarding missing student notification procedures for students who reside in on-campus student housing facilities.
  • Fire Safety Report. Publish a campus Fire Safety Report that provides policy statements and statistics on a dorm-by-dorm basis showing the number of fires, deaths, injuries, fire drills, property damage, type of fire detection systems, etc.
  • Exit counseling to borrowers. Requires exit counseling to borrowers by institutions to include information on repayment plans, debt management, and forbearance programs, among other specific information…. Requires institutions to provide comprehensive information on the terms and conditions of loans and borrowers’ responsibilities prior to loan disbursement to a first-time borrower.

Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) and Violence against Women Act

By October 1 of each year, an institution must distribute its Annual Security Report to all enrolled students and current employees. The campus safety web-based statistical survey is also submitted to the U.S. Department of Education “by the date and in a form specified by the Secretary.”

Equity in Athletics Disclosure Act

Each coed institution of higher education that participates in Title IV programs, and has an intercollegiate athletic program, must no later than October 15th of each year, make available on request to enrolled students, prospective students, and the public, the report required to be produced under this law. Within 15 days of making the report available to students, prospective students, and the public, (i.e., no later than October 30th of each year) the school must submit the report to the Secretary of Education.

Program Participation Agreements and IPEDS (Fall Collection)

As part of the program participation agreements signed in connection with any Federal financial assistance program authorized by Title IV of the Higher Education Act (HEA) of 1965 as amended, an institution must complete the surveys conducted as a part of the Integrated Postsecondary Education Data System (IPEDS) in a timely manner and to the satisfaction of the Secretary.

November

There are no scheduled federal reports due in November.

December

Higher Education Act: Audits

The compliance audit and audited financial statements must be submitted to the Secretary no later than six months after the last day of the institution’s fiscal year.