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Compliance Calendar

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

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

January


Tuition Payment Credit Reporting Requirements

26 U.S.C. § 6050S ; 26 C.F.R. 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 C.F.R. 1.6050S-3 and 26 C.F.R. 1.6050S-4 (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 pay or on or before January 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 C.F.R. § 1304.33

Reporting obligations for those registered to manufacture and distribute controlled substances. By January 15 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 January 15 for prior calendar year.

Acquisition/Distribution reports shall be filed every quarter not later than the 15th 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 , 49 , 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. See the IPEDS reporting schedule for the most recent dates which occur throughout the year.

Internal Revenue Code: W-2 Forms

26 C.F.R. § 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.

Animal Welfare Act:

Report by Licensees

9 C.F.R. § 2.7

Each year, within 30 days prior to the expiration date of his or her license, a licensee shall file with the AC Regional Director an application for license renewal and annual report. At CUA this report is filed in January of each year. See the Animal Welfare Act page for specifics.

February

Duties Of Employer and Employees- Occupational Safety and Health Act of 1970 (OSHA)


29 U.S.C. § 654 ; 29 C.F.R. §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 C.F.R. 1.6050S- 2

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.

Access period: Statements furnished on a Web site must be retained on the Web site through October 15 of the year following the calendar year to which the statements relate (or the first business day after such October 15, if October 15 falls on a Saturday, Sunday, or legal holiday). The furnisher must maintain access to corrected statements that are posted on the Web site through October 15 of the year following the calendar year to which the statements relate (or the first business day after such October 15, if October 15 falls on a Saturday, Sunday, or legal holiday) or the date 90 days after the corrected statements are posted, whichever is later.

Student Loan Interest Reporting

26 U.S.C. § 6050S; 26 C.F.R. 1.6050S- (a)3 and 26 CFR 1.6050S-4

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 February 28, or March 31 if filed electronically. Copies B, C and 2 must be furnished to the employee by February 1.

Effective Period of Withholding Exemption Certificate

26 CFR § 31.3402(f)(4)-2

A Form W-4 filed by an employee expires on February 15 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.

PHS Annual Report on Possible Research Misconduct

Once established, institutions maintain their assurance by filing the Annual Report on Possible Research Misconduct (between January 1 and March 1 each year), submitting their policy for responding to allegations of research misconduct for review when requested by ORI, revising their policy when requested by ORI to bring the policy into compliance with the PHS regulation, and complying with the PHS regulation. See The Office of Research Integrity web page on this compliance requirement.

March

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


42 U.S.C. §§ 11021 and 11022 ; 40 CFR § 370.21- 25


By March 1st 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 form at 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- 2

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 March 1, or March 31 if filed electronically. The required statement to all persons who made student loan interest payments must be sent to the pay or on or before January 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 March 1, or March 31 if filed electronically. Copies B, C and 2 are due to the employee by February 1.

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 (Marked as Reserved)

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 December 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 the TIAA-CREF ERISA 5500 Calendar for due dates and extension dates based upon when your plan year ends.

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 , 49 , 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.

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

No reporting deadlines given.

June


Hazardous Materials Transportation Act of 1994


49 USC § 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.

Foreign Bank Accounts and Tax Filings (FBAR)

31 USC 5314(a)

U.S. institutions and citizens that have an ownership interest in foreign bank accounts, or US citizens with signature authority over a foreign bank account have to file form TD F 90.22-1 (FBAR). The latter must report the account on an FBAR even if the foreign financial account is reported on an FBAR filed by the owner of the account (or other person that has a financial interest in the account). This form must be filed by June 30 of the year following any year during which they possessed signature or other authority over, or had a monetary interest in foreign financial accounts whose value exceeded $10,000 at any time during the calendar year. Note the regulations contain an exception for governmental entities such as a state university, but not private universities.[1] The proposed regulations also state that the IRS must have received the form by June 30, a postmark by June 30th does not count.

[1] See IRS FBAR Reference Guide ; last accessed 10/10/2019.

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 December 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 the TIAA-CREF ERISA 5500 Calendar for due dates and extension dates based upon when your plan year ends.

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 print 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, buyback 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.

Toxic Substances Control Act

15 USC § 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 of each year.

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.

Annual Report for all J-1 Sponsors for the Exchange Visitor ProgramAll J-1 sponsors must submit an annual report generated from SEVIS along with a narrative of the year. Sponsors must submit an annual report to DoS. The report must be filed on an academic calendar, or fiscal year, as stipulated on the program's designation or re-designation letter. The annual reporting cycle is also listed on the Program Information screen. The due dates are:

• Academic Year ends: June 30 Report due to DoS: July 31;

• Calendar Year ends: December 31 Report due to DoS: January 31;

• Fiscal Year ends: September 30 Report due to DoS: October 31.

See 22 CFR 62.15 for what must be included in the report.

August


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 , 49 , 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.

September

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 15th 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, the return is due September 15 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 , 49 , 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. See the IPEDS summary of HEO changes in Reporting for IPEDS 2009-2010 . New data will be made available on the College Navigator website by August 2009. See also the NAICU Calendar of new Reporting Requirements .

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. BYU–Hawaii provides Federal Aid information at https://financialaid.byuh.edu/federal-financial-aid-programs .

The Veterans' Readjustment Benefits Act

41 C.F.R. § 61-250.10

By September 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

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


20 U.S.C. § 1092(a)(1) (O ) and § 1092 (f) (5) and 34 C.F.R. § 668.46 and § 668.41
The Clery Act requires colleges to report campus crime statistics, campus safety policies and procedures, security measures, and campus fire safety statistics and information, to all students and employees by October 1 of each year. The annual security statistics must also be submitted to the Secretary of Education (over the internet) each year, by October 15 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 , 49 , 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 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 of each year.

November

No reporting deadlines given.

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 , 49 , 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.

A list of federal laws applicable to institutions of higher education can be found at the Higher Education Compliance Alliance .