Reporting Foreign Gifts and Contracts


Penn must comply with current state and federal laws requiring reporting of gifts received from and contracts entered into with foreign individuals and entities, including Section 117 of the Higher Education Act (20 U.S.C. 1011f) and the Pennsylvania Higher Education Gift Disclosure Act (24 P.S.§§ 6301-6307).  The required reporting of foreign gifts and contracts at Penn is managed under the auspices of the Vice President for Finance.  The Vice President for Finance has designated the Office of Research Services as the responsible unit for aggregating data from every School, Center, and Administrative/Business unit across Penn, and submitting the reports to the federal and Pennsylvania Departments of Education.

Central units at Penn manage the reporting of activities as follows:

Central Unit Data Reporting Responsibility
Office of Research Services Sponsored grants and contracts managed through PennERA
Development and Alumni Relations Gifts
Penn Center for Innovation Licensing agreements
Student Registration and Financial Services Tuition paid by a foreign source

Each School and Administrative/Business unit at Penn is responsible for tracking and reporting each foreign gift and contract that is not tracked through one of these central offices.

How and When to Report

What must be reported to the Vice President for Finance designee?

Every gift and contract with a foreign entity or individual, regardless of dollar value.

What are the reporting deadlines?

Data must be submitted utilizing the Penn Foreign Gift and Contract reporting template according to the schedule:

Activity Reporting Period Reporting Deadline
January 1 – June 30 April 15 and July 15
July 1 – December 31 October 15 and January 15


Where do I submit the reports?

Please submit your reports to Bob Speakman, Director of Research Reporting in the Office of Research Services, at

Where can I get training/additional information on what to report?

If you have been assigned responsibility to assist with reporting foreign gifts and contracts for your school or center, please contact Bob Speakman at to receive training. When your training is complete, you will receive the reporting template document and access to additional helpful definitions, frequently asked questions, and other materials.

I have also been asked to report on foreign revenues and expenses  for the Department of Commerce BE 125 surveys. Is this the same requirement?

No. The BE-125 is a quarterly report on foreign activities that is submitted quarterly to the U.S. Department of Commerce. However, some of the data and contracts you report may be responsive for both requirements: reporting foreign gifts and contracts to the federal and state Departments of Education, and reporting foreign revenues and expenses for foreign activities to the federal Department of Commerce.

Staff Resources

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