CUA COMPLIANCE CALENDER

 

Go to Month:

January    February    March    April    May    June    July   August    September   October    November    December

 

This calendar is not meant to be a comprehensive compliance calendar, rather it aims to highlight import reporting deadlines for institutions of higher education.

 

January

 

Higher Education Act of 1965 and Higher Education Amendments of 1998 (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. 

 

Tuition Payment Credit Reporting Requirements

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

An institution or insurer must furnish a statement to each individual for whom it is required to file a Form 1098-T, on or before January 31 of the year following the calendar year in which payments were received, or amounts were billed, for qualified tuition and related expenses, or reimbursements, refunds, or reductions of such amounts were made.

 

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)

Under I.R.C. § 6050S 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. This is done by filing Form 1098-E, which must be filed with 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 Jan. 31 of the year following the calendar year in which the interest payments were received. The statement may simply be a copy of Form 1098-E. 

 

The Controlled Substances Act of 1970

21 U.S.C. 827; 21 CFR § 1304.33

Reporting obligations for those registered to manufacture and distribute controlled substances. By Jan. 15^th of every year, file reports with data on the stocks of each controlled substance on hand by close of business on Dec. 31 of prior year. Manufacturing transaction reports are also to be filed by Jan. 15^th for prior calendar year.

Acquisition/Distribution reports shall be filed every quarter not later than the 15^th day of the month succeeding the quarter for which it is submitted.

 

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 2007/2008 collection includes the Human Resources component. In addition, institutions have the opportunity to provide Fall Enrollment data and Finance data at this time.opens Dec.5th, 2007 and closes January 23, 2008.

 

Internal Revenue Code: W-2 Forms
26 CFR § 31.6051-1

By Jan. 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.

 

February

 

Occupational Safety and Health Act of 1970 (OSHA)

29 U.S.C. § 654; 29 CFR 1904.32

Employers with 11 or more employees must post, from February 1 to April 30, a summary of the total number of job-related injuries and illnesses that occurred in the prior calendar year.  Required to post the annual totals of the information contained on the right-hand portion of OSHA Form 300, "Log and Summary of Occupational Injuries and Illnesses.  The form is to be displayed wherever notices to employees are usually posted. Download the form from the OSHA website.

 

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.  The proposed regulations requiring filing Forms 1098-T on magnetic media impose no additional reporting or record keeping and only prescribe the method of filing information returns that are already required to be filed.

 

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)

Under I.R.C. § 6050S 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. This is done by filing Form 1098-E, which must be filed with 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 Jan. 31 of the year following the calendar year in which the interest payments were received. The statement may simply be a copy of Form 1098-E. 

 

Return of Information as to Payments to Employees

26 CFR § 1.6041-2

Employers must file Form W-2 for wages paid to each employee from whom income, social security or Medicare taxes were withheld or income tax would have been withheld if the employee had claimed no more than one withholding allowance or had not claimed exemption from withholding on Form W-4. Anyone required to file Form W-2 must file Form W-3 to transmit Copy A of Forms W-2. The employer must file these forms with the IRS by Feb. 28, or
March 31 if filed electronically.

 

Effective Period of Withholding Exemption Certificate

26 CFR § 31.3402(f)(4)-2

A Form W-4 filed by an employee expires on February 15th of the year following the year in which the Form W-4 was given to employer. The employer must now begin withholding for any employee who previously claimed an exemption, but has not given the employer a new Form W-4 for the current year. If the employee does not give the employer a new Form W-4 (see December), withhold tax as if the employee is single, with zero withholding allowances. See the Internal Revenue Service Calendar.

 

March

 

Emergency Planning and Community Right-to-Know Act (EPCRA)

42 U.S.C. §§ 11021 and 11022; 40 CFR §370.21 and 370.25

By March 1^st  of each year, the owner or operator of any facility which is required to prepare or 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.

 

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.  The proposed regulations requiring filing Forms 1098-T on magnetic media impose no additional reporting or record keeping and only prescribe the method of filing information returns that are already required to be filed.

 

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)

Under I.R.C. § 6050S 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. This is done by filing Form 1098-E, which must be filed with 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 Jan. 31 of the year following the calendar year in which the interest payments were received. The statement may simply be a copy of Form 1098-E. 

 

Return of Information as to Payments to Employees

26 CFR § 1.6041-2

Employers must file Form W-2 for wages paid to each employee from whom income, social security or Medicare taxes were withheld or income tax would have been withheld if the employee had claimed no more than one withholding allowance or had not claimed exemption from withholding on Form W-4. Anyone required to file Form W-2 must file Form W-3 to transmit Copy A of Forms W-2. The employer must file these forms with the IRS by Feb. 28, or March 31 if filed electronically.

 

Form 1042/1042-S Filing and Information Returns

26 USCS § 871; 26 CFR 1.146-1

Form 1042-S is used to report all non-employee payments to non-resident aliens and payments to nonresident employees who claim exemptions from federal income taxes due to a tax treaty. (The taxable portion of payments to nonresident employees are reported on IRS Form W-2 in January.)

 

The institution must file Form 1042, and copies of all Forms 1042-S with the IRS by March 15 of the calendar year following the year in which the income was paid. In addition, Form 1042-S must be sent to each recipient of an amount subject to reporting by March 15 of the calendar year following the year in which the income was paid.

 

Employee Retirement and Income Security Act (ERISA)

29 USC § 1024; 29 CFR § 2520.104a-5; 29 CFR § 2520.104b-10

The administrator of an employee benefit plan must file a form 5500 within 210 days after the close of the plan year. Thus, if the plan year is the same as the calendar year, and ends Dec. 31, then the filing deadline is July 31 of the next year. An extension of the filing deadline of up to two-and-a-half months can be obtained by using form 5558. If the plan year and tax year are the same, and you obtain an extension for filing the institution's tax return, then the deadline for the 5500 is automatically extended as well.

 

A summary annual report must be sent to each plan participant and beneficiary receiving benefits within nine months of the end of the plan year. If the institution obtains an extension for filing the 5500, the extension for distributing is extended to two months after the filing of the form 5500. See TIAA-CREF Important Dates for ERISA Reporting.

 

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) meets the reporting requirements of the Student Right to Know Law. The Spring collection period extends from March 5 through April 16, 2008.

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.

 

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 2008 collection includes Graduation Rates and Student Financial Aid, as well as Fall Enrollment and Finance (for those institutions that did not lock in Winter). The Spring collection period extends from March 5 through April 16, 2008.

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. Link to reports on the ED website.

 

May

 

Health Insurance Portability and Accountability Act of 1996 (HIPAA) 

Codified at  42 U.S.C. § 300gg and  29 U.S.C § 1181 et seq.

Standard Unique Health Identifier for Health Care Providers, 69 Feg. Reg. 3433, Jan. 23, 2004                               

Covered entities must use the identifier in connection with standard transactions.  The final rule is effective May 23, 2005, except for Sec. 162.210 governing employer identification numbers. The effective date of this final rule marks the beginning of the implementation period for the NPI, which is distinct form the compliance dates of the NPI. For the compliance date, HHS  adopts the requirement that covered entities (except small health plans) must obtain an NPI and must use the NPI in standard transactions no later than May 23, 2007. Small health plans must do so no later than May 23, 2008.

 

June

 

Hazardous Materials Transportation Act of 1994

49 USCS § 5108; 49 CFR § 107.608

Each person who transports or causes to be transported hazardous material shall file annually a complete and accurate registration statement on DOT Form F 5800.2 not later than June 30 for each registration year. Each registration year begins on July 1 and ends on June 20.

July

 

Employee Retirement and Income Security Act (ERISA)

29 USC § 1024; 29 CFR § 2520.104a-5; 29 CFR § 2520.104b-10

The administrator of an employee benefit plan must file a form 5500 within 210 days after the close of the plan year. Thus, if the plan year is the same as the calendar year, and ends Dec. 31, then the filing deadline is July 31 of the next year. An extension of the filing deadline of up to two-and-a-half months can be obtained by using form 5558. If the plan year and tax year are the same, and you obtain an extension for filing the institution's tax return, then the deadline for the 5500 is automatically extended as well.

A summary annual report must be sent to each plan participant and beneficiary receiving benefits within nine months of the end of the plan year. If the institution obtains an extension for filing the 5500, the extension for distributing is extended to two months after the filing of the form 5500.

 

See TIAA-CREF Important Dates for ERISA Reporting.

 

Toxic Substances Control Act

15 USCS § 2607; 40 CFR 761.180

A written annual document log of the disposition of PCBs and PCB items must be prepared for each facility by July 1, 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 15^th of each year.

 

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)

This law does not apply in states without a voter registration requirement, or if the voter can register at the time of voting. For all other states, 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. Many states have voter registration forms online, which makes compliance easier and  the timeline less onerous, as links can be posted in September for November elections covered under the law. [1]

 

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

 

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. The annual security report must also be submitted to the Secretary of Education (over the internet) each year, by Oct. 15^th of each year.

 

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 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.

 

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.

 

Registration for the entire 2007-08 collection cycle will begin August 1, 2007. All keyholders are requested to register prior to August 29.  After that date, the Help Desk will be contacting CEOs to ask to have a keyholder appointed. Institutions will be given one UserID and password for the entire year (all 3 collection periods). Institutions may change keyholders at any time during the year. Please refer to the FAQs or the Registration Help for instructions. 
 

September

 

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)

This law does not apply in states without a voter registration requirement, or if the voter can register at the time of voting. For all other states, 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. Many states have voter registration forms online, which makes compliance easier, and the timeline less onerous, as links can be posted in August or September for November elections covered under the law. [2]

 

Internal Revenue Code: Filing Form 990
26 U.S.C § 6033 and 26 CFR § 1.6033-2

Exempt organizations who do not fall under a statutory exception must file an annual return with the Internal Revenue Service. The return must be filed on or before the 15^th day of the fifth calendar month following the close of the institution's fiscal year. As the fiscal year at CUA ends on April 30^th, the return is due Sept. 15^th of each year.

 

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 2007 collection includes the Institutional Characteristics, Completions, and 12-month Enrollment components. The Fall collection opens September 5 and closes October 17, 2007.

 

Executive Orders 11,246 and 11,375

41 CFR§ 60-1.7

Contractors and subcontractors with 50 or more employees or who have a contract, subcontract, or purchase order with the federal government amounting to $50,000 or more must file the IPEDS forms as required each year. This is what is used by IHE's in place of EEO-6 forms.

 

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. No deadline specifically enumerated,September 1 is suggested. CUA required disclosures are online at http://counsel.cua.edu/StudLife/publications/consumerinfo.cfm.

 

The Veterans' Readjustment Benefits Act

41 C.F.R. § 61-250.10

By Sept. 30 of each year, federal contractors and subcontractors must file Federal Contractor Veterans' Employment Report (VETS-100).  See the DOL web page  for more on this requirement. The report is for information required with respect to the prior calendar year.

 

October

 

 

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.

Deadline is October 17, 2007 for submission of the Institutional Characteristics, Completions, and 12-month Enrollment components(the Fall Collection). This is the first of three annual data collection periods. Click here for information, schedules, and links to survey instruments.
Reach the Helpdesk at 877-225-2568 or ipedshelp@rti.org.

 

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 no later than Oct. 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,  (so at the latest Oct. 30th of each year) the school must submit the report to the Secretary of Education. ED mailed a letter with instructions and passwords to campus presidents in September.
Click here for the survey, instructions, and FAQs. Reach the Helpdesk at 888-233-5421 or EADAhelp@westat.com.

 

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. The annual security report must also be submitted to the Secretary of Education (over the internet) each year, by Oct. 15^th of each year. For calendar year 2003 the deadline is October 13. ED mailed a letter with instructions and passwords to campus presidents in August. Click here for survey, instructions, and FAQs. Reach the Helpdesk at 800-435-5985 or campussecurityhelp@westat.com.

 

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)

This law was signed on October 28, 2000, and becomes effective on October 27, 2002.  Notification may be accomplished by adding the statement to the Annual Security Report required by the Campus Security Act.  Suggested deadline of Oct. 1 of each year to coincide with Annual Security Report.  The notice requirement is ongoing.

 

The Drug-Free Schools and Communities Act Amendments of 1989

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

Annual distribution 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. Must also include a statement on sanctions the institution will impose for violation of the standards of conduct. 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 of which is required by October 1^st of each year.

 

 

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 2007-08 collection includes the Human Resources component. In addition, institutions have the opportunity to provide Fall Enrollment data and Finance data at this time. The Winter collection opens December 5, 2007 and closes January 23, 2008.

 

Animal Welfare Act

9 CFR § 2.36

If live animals are used by the institution in research, tests, experiments or for teaching, then the part of the institution responsible for the research must submit an annual report to the AC Regional Director for the state where the institution is located on or before December 1 of each calendar year. The report shall be signed by the CEO of Institutional Official and shall cover the previous fiscal year.

 

U.S. Tax Code: Withholding exemption certificates

26 C.F.R. § 31.3402(f)(2)-1(c)(3).

The employer is required to request a withholding exemption certificate from each employee, but if the employee fails to furnish such certificate, the employer shall consider that employee a single person claiming no withholding.  On or before December 1 of each year, every employer should request of each employee a newly completed withholding exemption certificate for the ensuing calendar year. 

 

Internal Revenue Code: Tuition Payment Credit Reporting Requirements

26 CFR § 1.6050S-3 and 26 C.F.R. § 301.6109

If the institution does not have a record of the individual's correct TIN, then it must solicit the TIN on or before December 31.

 

Occupational Safety and Health Act of 1970 (OSHA)

29 U.S.C. § 654 and 29 CFR 1904.32

By Dec. 31 of each calendar year, the employer must review the OSHA 300 Log to verify entries, create an annual summary of injuries and illnesses, and certify the summary, which must be posted no later than Feb. 1 of the following year and kept in place until April 30.

 

---