From: by way of Lynn Davis
Date: Thu Dec 07 2000 - 17:33:47 EST
In Tuesday's COHEAO teleconference, it was stated that institutions would
need to find a way to identify students who had received employer
reimbursements for courses. That was contrary to my interpretation of the
regs which state
SEC. 6050S. RETURNS RELATING TO HIGHER EDUCATION TUITION AND RELATED
EXPENSES.
(a) IN GENERAL- Any person--
(1) which is an eligible educational institution--
(B) which makes reimbursements or refunds (or similar amounts) to any
individual of qualified tuition and related expenses,
2) which is engaged in a trade or business of making payments to any
individual under an insurance arrangement as reimbursements or refunds (or
similar amounts) of qualified tuition and related expenses, or [and which,
in the course of such trade or business,]
shall make the return described in subsection (b) with respect to the
individual at such time as the Secretary may by regulations prescribe.
(b) FORM AND MANNER OF RETURNS- A return is described in this subsection if
such return--
(1) is in such form as the Secretary may prescribe,
(2) contains--
(iii)[(ii)] aggregate amount of reimbursements or refunds (or similar
amounts) paid to such individual during the calendar year by the person
making such return,
My interpretation was that the section of (2) (iii) regarding
reimbursements applied to the types of organizations listed under (a) (2)
since we as an institution do not "make" reimbursements to our students--we
receive them.
I spoke with Mary Bachinger at NACUBO this morning, and she affirmed that
my interpretation is the intent of the regulations. She stated that early
on in discussions between NACUBO and treasury it was made clear that
schools were not expected to report reimbursement information. (a) (2) was
added in 1998 to clarify this (in a roundabout way at least).
I spoke with Sharon Bob, and her interpretation is that we do need to
report reimbursements as stated in the teleconference.
I just wanted other schools to realize that there is another interpretation
to consider before they spend time setting up a system to gather the
reimbursement information.
I recommend that you consult your auditors for guidance in this area.
Geoff Marsh
Director of Student Financial Services
Cornerstone University
616-222-1419
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