I've received a NACUBO Public Policy Report dated April 10, 1995 that
references a Dear Colleague letter (GEN-95-12) detailing requirements for
disclosure of gifts and contracts of more than $250,000 from a foreign
source in any calendar year.  The notice indicates that foreign gift
disclosure is required under section 1209 of the Higher Education Act of
1965, as amended.  Section 1209 was added to the Higher Education Act
amendments of 1992 and took effect with its enactment on July 23, 1992.
The disclosure is apparently due 07/31/95 for things received since
07/23/92.

 The notice suggests that only gifts are required to be disclosed by
legislation, but that the U.S. Dept. Ed. is asking for contract disclosure
as well.

 1) Does anyone know the facts of this?  Were contracts added without a
legislative basis?

 2) I have never seen this published as a regularory requirement;
therefore, are institutions planning to comply?

 3) If so, will the disclosure be based upon $$ actually received or
upon total amount committed during a particular time period?

Terry A. May, Ph.D.                       Voice:    520-523-6788
 Director of Research Administration     FAX:      520-523-1075
 Office of Grant & Contract Services     INTERNET: xxxxxx@nauvax.ucc.nau.edu
 100 Babbitt Admin. Ctr., Box 4130
 Northern Arizona University
  Flagstaff, AZ  86011-4130