Form 990 Data Request for Reportable Activities, Expenses, and Benefits Provided to Listed Individuals

This questionnaire is being completed in connection with the FY26 Form 990 filing and covers the reporting period for activities, expenses and benefits provided to listed individuals from January 1, 2025, through December 31, 2025.

GW's annual information return, Form 990, requires the University to disclose certain compensation, benefit information and expense reimbursements for individuals identified by the IRS as reportable persons. These "listed individuals" generally include trustees, officers, key employees, and certain highly compensated employees who must be disclosed on the University's annual Form 990 filing. To comply with these reporting requirements and ensure the accuracy and completeness of its filing, the University must obtain relevant expense and benefit information from the appropriate schools, departments, and administrative units.

For more information, refer to the IRS guidance: 


  • Officer: An individual who has authority to manage the organization's daily operations, such as the president, chief executive officer, chief financial officer, treasurer, secretary, provost, or other senior executive with significant organizational responsibilities.
  • Key Employee: An employee who is not an officer but who has substantial responsibility, influence, or authority over the organization's activities, finances, or operations and meets certain compensation and responsibility thresholds established by the IRS.
  • Highly Compensated Employee (HCE): An employee who is among the organization's highest-paid employees and meets IRS compensation thresholds, but who is not otherwise reportable as an officer, trustee, or key employee.


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For 990 purposes, fundraising activities is defined as: Activities undertaken to induce potential donors to contribute money, securities, services, materials, facilities, other assets, or time. They include publicizing and conducting fundraising campaigns; maintaining donor mailing lists; conducting fundraising events, preparing and distributing fundraising manuals, instructions, and other materials; and conducting other activities involved with soliciting contributions from individuals, foundations, governments, and others.


During the reporting period identified in the instructions above, were any of the following benefits, arrangements, or services provided to you? Please select Yes or No for each item below. If you select Yes, please provide a description of the arrangement or transaction.
  • First-class travel refers to any travel on a passenger airplane, train, or boat with first-class seats or accommodations by a listed person or companion if any portion of the cost above the lower-class fare is paid by the organization. First-class travel doesn't include intermediate classes between first class and coach, such as business class on commercial airlines. Bump-ups to first class free of charge or as a result of using frequent flyer benefits, or similar arrangements that are at no additional cost to the organization, can be disregarded.
  • Charter travel refers to travel on an airplane, train, or boat under a charter or rental arrangement. Charter travel also includes any travel on an airplane or boat that is owned or leased by the organization.
  • Travel for companions refers to any travel of a  listed person's guest not traveling primarily for bona fide business purposes of the organization. It also  refers to any travel of a listed person's family members, whether or not for bona fide business purposes.
  • Tax indemnification and gross-up payments refer to the organization's payment or reimbursement of any tax obligations of a listed person.
  • Housing allowance or residence for personal use refers to any payment for, or provision of, housing by the organization for personal use by a listed person, including a ministerial housing or parsonage allowance.
  • Payments for business use of personal residence refers to any payment by the organization for the use of all or part of a listed person's residence for any purpose of the organization.
  • Health or social club dues or initiation fees refers to any payment of dues by the organization for the membership of a listed person in a health or fitness club or a social or recreational club, whether or not such clubs are tax exempt. It doesn't include membership fees for an organization described in section 501(c)(3) or section 501(c)(6) unless such organization provides health, fitness, or recreational facilities available for the regular use of a listed person.
  • Health club dues don't include provision by the organization of an on-premises athletic facility described in section 132(j) (4), or provision by a school of an athletic facility available for general use by its students, faculty, and employees. Dues include the entrance fee, periodic fees, and amounts paid for use of such facilities.
  • Personal services refers to any services for the personal benefit of a listed person or the family or friends of a listed person, whether provided regularly (on a full-time or part-time basis) or as needed, whether provided by an employee of the organization or independent contractor (and whether the independent contractor is an individual or an organization). They include, but aren't limited to, services of a babysitter, bodyguard, butler, chauffeur, chef, concierge or other person who regularly runs non-incidental personal errands, escort, financial planner, handyman, landscaper, lawyer, maid, masseur/masseuse, nanny, personal trainer, personal advisor or counselor, pet sitter, physician or other medical specialist, tax preparer, and tutor for nonbusiness purposes. Personal services don't include services provided to all employees on a nondiscriminatory basis under a qualified employee benefit plan.



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