Compliance with Section 117 of the Higher Education Act
In June 2019, the U.S. Department of Education announced it was working with two of our peer institutions to review their compliance with the Department’s Section 117 foreign gift and contract reporting requirements, with a specific focus on work occurring in Qatar. Given that Cornell operates a medical school in Qatar, the University began to examine its own Section 117 reporting in June of that year to be sure that we had fulfilled our compliance obligations. This was before we received notice from the Department on July 3, 2019 that it was expanding its review to include Cornell.
Through our internal review, the University identified gaps in our reporting of funds received from the Qatar Foundation to operate our medical school in Qatar. Weill Cornell Medicine–Qatar – the first American medical school outside the United States to award medical degrees from its home institution – has graduated 422 men and women from the Middle East, Asia and many other countries, including the U.S., who are now aiding the ongoing transformation of patient care, biomedical research and overall quality of life in the region and around the world. We promptly and proactively shared those omissions with the Department in July 2019. Cornell has reported the Qatar medical school’s operating budget to the United States Government in our Form 990 filings with the Internal Revenue Service; however, Cornell discovered that the medical campus funding had not separately and additionally been reported to the Education Department through this process.
Since July 2019, as the University cooperated fully with the Department’s review, we determined the extent to which our prior efforts to comply with Section 117 reporting requirements were incomplete. The University had properly reported about $150 million in foreign gifts and contracts since 2012; however, in addition to missing the Weill Cornell Medicine – Qatar operating budget (totaling over $1 billion since 2012), the University identified an additional approximately $150 million in gifts and contracts with foreign sources since 2012 that were potentially required to have been reported under Section 117. In 2019 Cornell filed a fully corrected Section 117 report with the Department and implemented substantial changes to enhance compliance and oversight in the University’s international operations, including hiring a new central Chief Compliance Officer.
Our review found a number of Huawei gifts that had been made to support research that had not been reported. These omissions were corrected. As has been reported in the media, Cornell independently decided in 2018 that it would no longer accept additional grant funding or gifts from Huawei.
The University sincerely regrets our Section 117 reporting shortcomings. Cornell has undertaken significant efforts to file timely and accurate Section 117 reports since July of 2019.
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