Compliance

Cardinal Stritch University is dedicated to operating in accordance with all applicable laws, regulations and policies. A Compliance Program has been developed to ensure that the University remains in good standing and to help all members of the University community become aware of the compliance requirements and responsibilities that we all share.

The Office of Institutional Effectiveness coordinates compliance activities at the University and reports to the Provost & Vice President of Academic Affairs. The responsibilities of the Office of Institutional Effectiveness are to coordinate and monitor University-wide compliance efforts and to act as a resource for compliance related questions.

The Compliance Program demonstrates the University’s commitment to honest and ethical behavior and remaining compliant. It is designed to assist the University in fulfilling its compliance responsibilities by establishing a process to monitor the University’s compliance efforts and to document the University’s policies and expectations for all members of the University community.

Below are the department-specific calendars aid the Office of Institutional Effectiveness in keeping track of the compliance requirements of the University. Each item has a corresponding footnote which provides a detailed explanation of that particular reporting requirement. Departments should use these calendars as a tool when assessing compliance obligations.

Compliance Calendars

Advancement Calendar

January
Higher Education Act Disclosure of Foreign Gifts/Contracts [1]

July
Higher Education Act Disclosure of Foreign Gifts/Contracts [1]

[1] Higher Education Act of 1965 and Higher Education Amendments of 1998

(Disclosure Requirements on Foreign Source Interests)

By January and July 31 of each year, a postsecondary institution must file a disclosure report about ownership or control by, or contracts with or gifts from foreign sources. The institution must make the disclosure by January 31 for the prior year July 1 to December 31, and by July 31 for the immediately preceding January 1 to June 30 period.

Gifts and contracts of $250,000 or more (individual or in combination with other gifts from and/or contracts with the same foreign source) received or contracted within a calendar year must be reported to the Department of Education. This report must also be made available to the public during regular business hours (20 U.S.C. §1011f(e)). This disclosure report should contain the dollar amount of gifts received from and/or contracts entered into with a foreign source other than a foreign government, the amount of gifts received from or contracts entered into with a foreign government, and if the U.S. institution is owned or controlled by a foreign source, the identity of the foreign source, the date the foreign source gained ownership or control, and institutional program or structural changes that took place as a result of the change in ownership or control.

If a restricted or conditional gift and/or contract is received by an institution, the following must also be disclosed: 1) the amount, date, and description of the conditions and restrictions for gifts received from and/or contracts entered into with a foreign source (other than a foreign government) as well as country of citizenship and country of incorporation; and 2) the amount, date, description of conditions and restrictions, name of foreign governments for gifts received from and/or contracts entered into with a foreign government.

A "foreign source" is defined as: 1) a foreign government, or agency of a foreign government; 2) a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states; 3) an individual who is not a citizen or national of the United States or a trust territory or protectorate thereof; and/or 4) an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.

Athletics Calendar

September
NAIA Annual Report [1]

October
Equity in Athletics Disclosure Act [2]

[1] NAIA Annual Report
Each member institution is required to file a year-end-report with the NAIA National Office on an annual basis. Institutions have until September 1 to complete the certificates and submit information to the NAIA National Office via www.NAIAhelp.com. Athletics Directors should work with coaches and the institution’s financial aid department to complete the report.

[2] Equity in Athletics Disclosure Act
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. If the report is available online, the school must also provide notice, either through mail, e-mail, or campus mail, giving the specific web site address where the request can be viewed and including a statement that a paper copy is available upon request. 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. This is done online at http://surveys.ope.ed.gov/athletics/.

Business Office Calendar

January
W-2 and W-3 Forms [1]
Form 1098-E [2]
Form 1098-T [3]
Form 1099-MISC [4]
Higher Education Act Disclosure of Foreign Gifts/Contracts [5]

February
W-2 and W-3 Forms [1]
Form 1098-E [2]
Form 1098-T [3]

March
W-2 and W-3 Forms [1]
Form 1098-E [2]
Form 1098-T [3]
Form 1099-MISC [4]

July
Higher Education Act Disclosure of Foreign Gifts/Contracts [5]
ACA: PCOR Fee Reporting and Payment [6]

November
Internal Revenue Code: Filing Form 990 [7]

December
Tuition Payment Credit Reporting Requirements [8]

[1] W-2 and W-3 Forms

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.
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.

[2] Form 1098-E

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.

[3] Form 1098-T

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. 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.

[4] Form 1099-MISC

Used to report miscellaneous income for each person paid during the year: 1) At least $10 in royalties or broker payments in lieu of dividends or tax-exempt interest; 2) At least $600 in rents, services (including parts and materials), prizes and awards, other income payments, medical and health care payments, crop insurance proceeds, cash payments for fish (or other aquatic life) purchased from anyone engaged in the trade or business of catching fish, or generally, the cash paid from a notional principal contract to an individual, partnership, or estate; 3) Any fishing boat proceeds; or 4) Gross proceeds to an attorney. Due to be mailed to individuals by January 31 and to the IRS by March 15, if filed electronically.

[5] Higher Education Act of 1965 and Higher Education Amendments of 1998

(Disclosure Requirements on Foreign Source Interests) By January and July 31 of each year, a postsecondary institution must file a disclosure report about ownership or control by, or contracts with or gifts from foreign sources. The institution must make the disclosure by January 31 for the prior year July 1 to December 31, and by July 31 for the immediately preceding January 1 to June 30 period.
Gifts and contracts of $250,000 or more (individual or in combination with other gifts from and/or contracts with the same foreign source) received or contracted within a calendar year must be reported to the Department of Education. This report must also be made available to the public during regular business hours (20 U.S.C. §1011f(e)). This disclosure report should contain the dollar amount of gifts received from and/or contracts entered into with a foreign source other than a foreign government, the amount of gifts received from or contracts entered into with a foreign government, and if the U.S. institution is owned or controlled by a foreign source, the identity of the foreign source, the date the foreign source gained ownership or control, and institutional program or structural changes that took place as a result of the change in ownership or control.
If a restricted or conditional gift and/or contract is received by an institution, the following must also be disclosed: 1) the amount, date, and description of the conditions and restrictions for gifts received from and/or contracts entered into with a foreign source (other than a foreign government) as well as country of citizenship and country of incorporation; and 2) the amount, date, description of conditions and restrictions, name of foreign governments for gifts received from and/or contracts entered into with a foreign government.
A "foreign source" is defined as: 1) a foreign government, or agency of a foreign government; 2) a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states; 3) an individual who is not a citizen or national of the United States or a trust territory or protectorate thereof; and/or 4) an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.

[6] ACA: PCOR Fee Reporting and Payment

By July 31 of each year between 2013 and 2019 (for plan years ending on or after 10/1/12 and before 10/1/19), the university must file IRS Form 720 and pay applicable PCOR (Patient Centered Outcome Research Institute) fees for any covered self-insured plans, at the applicable rate ($1.00 per covered life for 2012, $2.00 for 2013, adjusted for inflation thereafter).

[7] Internal Revenue Code: Filing Form 990

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.

[8] Tuition Payment Credit Reporting Requirements

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.

Financial Aid Calendar

February
Yellow Ribbon Participation Renewal [1]

September
HEOA Code of Conduct and Other Notices [2]
FISAP: Fiscal Operations Report and Application to Participate [3]
NAIA Annual Report [4]

[1] Yellow Ribbon Participation Renewal

In order to participate in the GI-Bill Yellow Ribbon Program and receive matching funds from Veterans Administration, the institution must submit completed Yellow Ribbon Participation Agreements by February 15 of year for the following academic year.

[2] HEOA Code of Conduct and Other Notices

The institution must annually inform all of its employees who have responsibilities with respect to Federal education loans of the provisions of the institution’s Financial Aid Code of Conduct. This annual distribution should include a reminder that funds received from the Federal government under Title IV of the Higher Education Act, as amended, are not to be used to influence any branch of government.

[3] FISAP: Fiscal Operations Report and Application to Participate

The institution must report to the Department of Education all Perkins, FWS, and FSEOG funds from the previous fiscal year and apply for funds for the next fiscal year. The FISAP can be filed online at www.cbfisap.ed.gov and must be submitted during the fall of each year.

[4] NAIA Annual Report

Each member institution is required to file a year-end-report with the NAIA National Office on an annual basis. Institutions have until September 1 to complete the certificates and submit information to the NAIA National Office via www.NAIAhelp.com. Athletics Directors should work with coaches and the institution’s financial aid department to complete the report.

Human Resources Calendar

January
IPEDS: Winter Collection Closes [1]

February
Effective Period of Withholding Exemption Certificate [2]

July
ERISA: Form 5500 [3]
ACA: PCOR Fee Reporting and Payment [4]

September
IPEDS: Fall Collection Opens [5]
Drug-Free Schools and Communities Act: Annual Distribution [6]

October
Campus Security Act: Annual Security Report [7]
Campus Sex Crimes Prevention Act [8]
WHCRA Notice [9]
Notice for Creditable Coverage [10]
IPEDS: Fall Collection Closes [5]

December
IPEDS: Winter Collection Opens [1]
U.S. Tax Code: Withholding Exemption Certificates [11]
Drug-Free Schools and Communities Act: Biennial Review [12]

[1] IPEDS: Winter Collection

The Winter collection includes the Employees by Assigned Position component to classify all institutional staff, as well as the Faculty Salaries and the Fall Staff components of IPEDS. In addition, institutions have the opportunity to provide Enrollment data at this time. Institutions will be able to lock the Enrollment Component in the Winter or Spring. The Fall Staff component is provided for convenience, but data are NOT required this year. The Winter collection opens in December and closes in January. See http://surveys.nces.ed.gov/ipeds/ for exact dates.

[2] Effective Period of Withholding Exemption Certificate

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.

[3] ERISA: Form 5500

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.

[4] ACA: PCOR Fee Reporting and Payment

[5] IPEDS: Fall Collection

The Fall collection for IPEDS (Institutional Characteristics and Completions) opens in September and closes in October. Reporting is done online. See http://surveys.nces.ed.gov/ipeds/ for exact dates for submission of data on tuition and completion (the Fall Collection). This is the first of three annual data collection periods. Designated institutional personnel should have received User IDs and passwords.

[6] Drug-Free Schools and Communities Act: Annual Distribution

Annual distribution to employees of 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. Must also include a statement on sanctions the institution will impose for violation of the standards of conduct. The distribution method must be one that ensures that the information will reach every faculty and staff employee and is suggested to occur concurrent with beginning of academic year.

[7] Campus Security Act: Annual Security Report

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 report can be provided through publications, mailings, or electronic media sent directly to individuals. If it is posted to a website, notice must be sent through U.S. mail, campus mail, or directly to the email address of all enrolled students and current employees. [The notice must include the following: 1) identification of the information required to be disclosed, 2) the exact electronic web site address, 3) a statement that the individual is entitled to a paper copy, upon request, and 4) information as to how the individual can request a paper copy.]
Information noting the availability of the campus security report, including an opportunity to request a copy, must be included in appropriate publications, mailings, and/or electronic communications to prospective students. Information regarding the availability of this report must be made to prospective employees. The annual security report must also be submitted to the Secretary of Education (over the internet) each year, by Oct. 15th of each year.

[8] Campus Sex Crimes Prevention Act

This law requires a statement advising the campus community where law enforcement agency information provided by a State concerning registered sex offenders may be obtained, such as the law enforcement office of the institution, a local law enforcement agency with jurisdiction for the campus, or a computer network address. 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.

[9] WHCRA Notice

Written notice of the availability of coverage for breast reconstruction in connection with a mastectomy must be delivered to the health plan participants upon enrollment and annually thereafter (suggested to coincide with Notice for Creditable Coverage, which currently occurs annually in October).

[10] Notice for Creditable Coverage

The university must disclose to all Part D eligible individuals enrolled in or seeking to enroll in the coverage whether the coverage is creditable prescription drug coverage prior to the commencement of the Annual Coordinated Election Period that begins on November 15 of each year. (Note: this disclosure currently occurs in October).

[11] U.S. Tax Code: Withholding Exemption Certificates

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.

[12] Drug-Free Schools and Communities Act: Biennial Review

By the end of every-other calendar year, the University must conduct a biennial review covering the two-year period preceding that year. The biennial review must assess the University's efforts to comply with the annual distribution requirements of the Drug-Free Schools and Communities Act to 1) determine effectiveness and implement changes if necessary, and 2) ensure that sanctions are developed and enforced consistently. The University must keep a copy of the biennial review, as well as a "certification" signed by the President indicating that he has read the report and will act on its recommendations. These documents must be made available to the Dept. of Education upon request.

Institutional Research Calendar

January
IPEDS: Winter Collection Closes [1]

March
IPEDS: Spring Collection Opens [2]

April
IPEDS: Spring Collection Closes [2]

August
IPEDS: Registration [3]

September
IPEDS: Fall Collection Opens [4]
Program Participation Agreements: Financial Aid & Institutional Information [5]

October
IPEDS: Fall Collection Closes [4]

December
IPEDS: Winter Collection Opens [1]

[1] IPEDS: Winter Collection

[2] IPEDS: Spring Collection

The Spring IPEDS collection includes Finance and Student Financial Aid information, Graduation Rates data (including information required under the Student Right to Know Law), and Enrollment for those schools that did not lock in Winter. The Spring collection period opens in March and closes in April. Reporting is done online. See http://surveys.nces.ed.gov/ipeds/ for exact dates.

[3] IPEDS: Registration

Registration opens in August. Passwords and IDs are distributed in August. IDs and passwords for the upcoming collection cycle will be distributed to all institutions. Those with designated key-holders will receive information via email. All institutions for which there is no designated key-holder will receive a letter directed to the CEO containing registration information.

[4] IPEDS: Fall Collection

The Fall collection for IPEDS (Institutional Characteristics and Completions) opens in September and closes in October. Reporting is done online.
See http://surveys.nces.ed.gov/ipeds/ for exact dates for submission of data on tuition and completion (the Fall Collection). This is the first of three annual data collection periods. Designated institutional personnel should have received new 2006-07 User IDs and passwords (if not, contact the Helpdesk).

[5] Program Participation Agreements: Financial Aid & Institutional Information

Financial Aid and Institutional Information - 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; however, September 1 is suggested.
This disclosure must be provided directly to enrolled students through direct mailing, electronic mail, or provision at orientation/matriculation. If a the required disclosures are posted on a website, the direct mailing or electronic mail must be sent to all enrolled students, and must: 1) identify the information required to be disclosed, 2) provide the exact electronic Web site address where the information can be found, 3) state that, upon request, the student is entitled to a paper copy, and 4) inform the student how to request a paper copy.
Information noting the availability of each of these reports, including an opportunity to request a copy, must be included in appropriate publications, mailings, and/or electronic communications to prospective students.

International Education Calendar

January
SEVIS: Student Registration [1]

April
SEVIS: Student Registration [1]

June
J-1 Annual Report to the U.S. Department of State [2]

August
SEVIS: Student Registration [1]

September
SEVIS: Student Registration [1]

[1] SEVIS: Student Registration

Initial Student Reporting: Within 30 days of the Program Start Date, register the student record or terminate for no show.
Active Student Reporting for Each Term or Semester: Within 30 days of the Next Session Start Date, register the student record or terminate for Failure to Enroll.
Additional Note:
Final Rule on SEVIS Fees
This rule amends the DHS regulations to provide for the collection of a fee to be paid by students who are seeking status as F-1, F-3, M-1, or M-3 nonimmigrant students or as J-1 nonimmigrant exchange visitors. The rule levies a fee of $100, (with certain J-1 exchange visitors such as camp counselors paying a reduced fee of $35) and certain others will be exempt from the fee altogether. This final rule explains which students will be required to pay the fee.
The rule became effective on September 1, 2004, and applies to potential nonimmigrants who are initially issued a Form I-20 or Form DS-2019 on or after that date. If a Form I-20 or Form DS-2019 for initial status in a new program is issued on or after the effective date, the nonimmigrant traveling on that document will be required to pay the fee. Applicants, schools, and exchange visitor program sponsors should refer to the fee pay table contained in the rule for more detailed information concerning when a fee is required.

[2] J-1 Annual Report to the U.S. Department of State

The U.S. Department of State requires an annual report of all J-1 exchange visitors (students and others) during July 1 - June 30 of each year. The report is due June 30 each year and includes the number of exchange visitors in each category, challenges and opportunities, and goals for the following year.

Registrar Calendar

January
NSC/NSLDS Reporting [1]
Higher Education Amendments Voter Registration Provision [2]

February
NSC/NSLDS Reporting [1]

March
NSC/NSLDS Reporting [1]

April
NSC/NSLDS Reporting [1]

May
NSC/NSLDS Reporting [1]

June
NSC/NSLDS Reporting [1]

July
NSC/NSLDS Reporting [1]

August
NSC/NSLDS Reporting [1]

September
NSC/NSLDS Reporting [1]
Higher Education Amendments Voter Registration Provision[2]
FERPA: Notification of Rights [3]

October
NSC/NSLDS Reporting [1]

November
NSC/NSLDS Reporting [1]

December
NSC/NSLDS Reporting [1]

[1] NSC/NSLDS Reporting
The institution must report student enrollment and loan information to the National Student Clearinghouse and the National Student Loan Data System on at least a monthly basis.

[2] Higher Education Amendments Voter Registration Provision
The institution must make a good faith effort to distribute voter registration information to each student enrolled in a degree or certificate program and physically in attendance at the institution, and to make such information widely available to students at the institution.

[3] FERPA: Notification of Rights
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 University has identified as directory information and notified of his/her opportunity to place a hold on release of directory information.

Security Calendar

March
HEOA Emergency Procedures [1]

October
Campus Security Act: Annual Security Report [2]
Campus Sex Crimes Prevention Act [3]

[1] HEOA Emergency Procedures

The institution is required to publicize its emergency response and evacuation procedures on an annual basis in a manner designed to reach students and staff, and test those emergency response and evacuation procedures on an annual basis. The notice and test need not be done at the same time.

[2] Campus Security Act: Annual Security Report

[3] Campus Sex Crimes Prevention Act

Student Affairs Calendar

September
Drug Free Schools and Communities Act: Annual Distribution [1]
Constitution Day [2]

October
Campus Security Act: Annual Security Report [3]
Campus Sex Crimes Prevention Act [4]

December
Drug-Free Schools and Communities Act: Biennial Review [5]

[1] Drug Free Schools and Communities Act: Annual Distribution

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 distribution method used must be one that ensures that the information will reach every student, faculty member, and employee. The University's current practice of including the information in the Student Handbook meets this requirement as long as each individual student is offered an actual copy of the handbook during matriculation. Suggested to occur concurrent with beginning of academic year.

[2] Constitution Day

President George W. Bush signed a bill on December 8, 2004 (public law 108-447) which designates every September 17 as Constitution Day. All institutions of higher education that receive federal funding are required to prepare a program to inform students about the US Constitution. https://www.loc.gov/law/help/guide/federal/108-477cd.pdf

[3] Campus Security Act: Annual Security Report

[4] Campus Sex Crimes Prevention Act

[5] Drug-Free Schools and Communities Act: Biennial Review

By the end of every even-numbered calendar year, the University must conduct a biennial review covering the two-year period preceding that year. The biennial review must assess the University's efforts to comply with the annual distribution requirements of the Drug-Free Schools and Communities Act to 1) determine effectiveness and implement changes if necessary, and 2) ensure that sanctions are developed and enforced consistently. The University must keep a copy of the biennial review, as well as a "certification" signed by the President indicating that he has read the report and will act on its recommendations. These documents must be made available to the Dept. of Education upon request.

Reportable Compliance Concerns

Criminal conduct – If any University faculty, staff, administration or representative has actual knowledge of job-related criminal conduct, it is their duty to report it.
Safety concerns – If any University faculty, staff, administration or representative has actual knowledge of a job-related situation that endangers the health or safety of any individual, it is their duty to report it.
Violations of law or policy – All University faculty, staff, administration and representatives are encouraged to report any concerns related to the violation of University policies or state, local or federal laws.
Submitting False Claims – The Federal False Claims Act (FCA) sets forth liability for any person who knowingly submits a false claim to the government or causes another to submit a false claim to the government or knowingly makes a false record or statement to get a false claim paid by the government. Anyone who suspects a violation of the FCA is required to report the situation promptly.

Compliance Resources

Higher Education Compliance Alliance (HECA) – provides the higher education community with a centralized repository of information and resources for compliance with federal laws and regulations.