The deadline is approaching for NCAA member institutions to submit their athletics gender-equity data to the federal government.

Amendments adopted in 1998 to the federal Higher Education Act require all coeducational postsecondary institutions that receive federal funds and have athletics programs to report gender-specific data on their athletics programs to the federal government annually on or before October 30. A Web-based system has been implemented by the U.S. Department of Education to collect the data.

Known as the EADA [Equity in Athletics Disclosure Act, section 485 (g) of the Higher Education Act of 1965], the Act was first adopted in 1994 to provide Congress and the public with a snapshot of collegiate athletics participation by gender. Under the provisions of EADA, data similar to that requested this year have been required to be reported to the public since 1996. In addition to the new requirement that data be reported to the Department of Education by October 30, this year's report also requires for the first time that data on revenues and expenses associated with athletics programs be reported as part of the EADA report. The department expects to submit its report on gender-equity data to Congress on December 24.

The NCAA also requires its membership to submit these data to the NCAA national office. Completing the NCAA form before submitting data to the federal government will assist member institutions to complete the online federal form. The NCAA form is available on the NCAA Web site (www.ncaa.org). The NCAA form is designed to match the federal data collection effort so that the burden on the NCAA membership is minimized.

Once the data are received, the department is charged with providing a report to Congress on aggregate gender trends in intercollegiate athletics based on the reports submitted by individual institutions. The 1998 amendments also require the department to make institutional-specific reports available to the public. The department plans to provide public access to each institution's data over the Internet later this year. As in the past, by October 15 of each year, institutions remain responsible for making their own data available to the public upon request.

To alert institutions to the new Web-based EADA data collection, the department sent a letter August 11 to CEOs of all coeducational colleges and universities announcing the collection of 2000 EADA data (plans to collect 1999 data were abandoned during the summer). A follow-up letter was sent August 21 that provided institutional representatives with the Web URL site (http://surveys.ope.ed.gov/athletics), a user ID and a primary and secondary password.

The department's Web site for the 2000 collection opened September 5 and will remain open until October 30. Upon receipt of the August 21 letter, institutions were asked to register with the department and provide the name of that institution's EADA coordinator. As of September 28, only 50 percent of institutions had registered. The department has provided a toll-free telephone number (888/233-5421) for support in accessing and completing the EADA data collection forms.

The NCAA has successfully worked with the department to provide NCAA member institutions with a link to the NCAA's Web site directly from the department's Web site. NCAA member institutions will be able to access the NCAA's gender-equity reporting tables and worksheets by clicking on the NCAA link. NCAA members can use the NCAA worksheets to organize the data required by the federal government (Tables 1-10), as well as to complete the separate data reported to the NCAA (included on the worksheets).

NCAA members are asked to mail a copy of all the data on the worksheets and tables to the NCAA Research Staff, P.O. Box 6222, Indianapolis, Indiana 46206-6222. Individuals with questions concerning the completion of the NCAA form can call Maria DeJulio at 913/397-7668.

Questions and answers about EADA reporting forms

In order to obtain more clarity on ambiguous aspects of the EADA reporting, in September 1999, the NCAA submitted a list of questions to the department based on inquiries received from the NCAA membership on EADA-related matters. The department's responses to the NCAA should assist institutions in completing the EADA form.

Q The Notice of Proposed Rulemaking (NPRM) does not address how capital expenses are to be counted under revenues. The NCAA recommends that two totals be provided, one with the capital and debt incorporated and another without these components.

A The data required by the EADA do not include data concerning capital assets. The EADA requires data concerning expenses and revenues that are akin to data from an income and expense statement. Such statements do not report capital assets that generally are presented on a balance sheet. Therefore, an institution should not include information about capital assets and related debts in its EADA report.

Q Some institutions do not include the campus's administrative overhead in the facilities and ground costs under operating expenses. The NCAA recommends that the definition of overall expenses define whether campus administrative costs are to be included under operating expenses. The NCAA suggests that administrative overhead not be included.

A We agree with the NCAA's recommendation. Administrative overhead should not be included as operating expenses in an institution's EADA data. Section 668.47(b)(I)(ii) of the Student Assistance General Provisions defines operating expenses as all expenses an institution incurs attributable to home, away and neutral-site athletics contests for lodging, meals, transportation, uniforms and equipment for coaches, team members, support staff and others, including costs incurred for officials. Section 668.47(c)(5) states that an institution should include general and administrative overhead not attributable to a particular sport under total expenses.

Q How should institutional support be counted? NCAA Division III institutions raise little funding from outside revenues. Support for athletics programs are part of the institution's budgeted expenses. This is the first year Division III institutions will be completing the revenues and expenses reporting and they are certain to have questions about how institutional support is to be counted and whether the amount should be "budgeted dollars" or "actual dollars spent" (and how surpluses or deficits in spending should be reported). The NCAA suggests that it be "budgeted dollars" since the monies actually spent will be reported in the expense section. If not all budgeted revenue is spent, there simply will be a surplus of revenues over expenses. The act requires no explanation of how surpluses or deficits are treated but could be explained in the comment section of the report.

A When reporting revenues from institutional support, an institution should report budgeted dollars if the budgeted dollars not spent remained in the athletics department's or team's budget at the end of the year. If not, the institution should report only the actual dollars spent.

Q At Division III institutions, the athletics recruiting dollars of some institutions are budgeted through the admissions department. The NCAA recommends that the department clarify that if recruiting dollars of student-athletes is done and paid for by the admissions office, the institution still has a responsibility to report the actual expenditures made for recruiting purposes by the institution. On the other hand, if all that is involved in the identification of students who happen to be athletes, incidental to the process of recruiting students generally, such expenditures would not be reportable.

A We recognize that it may be difficult for a Division III institution to determine whether it is recruiting a person because of his or her athletics ability and therefore should include related recruiting expenses in its report. Therefore, if a Division III institution cannot determine whether it recruited a particular student primarily as a regular student or as a student-athlete, the institution should include in its EADA report only recruiting expenses incurred by persons representing its athletics department.

Q Are special team trips taken over the summer months considered team expenses when the expenses are paid by fund-raising activities? The NCAA recommends that summer trips not be treated any differently than school-year trips.

A An institution's EADA report must include data for a 12-month period defined by the institution. Neither the time a particular expense is incurred nor the source of revenues used to pay for a particular expense (for example, from fund-raising) is relevant.

Q Should postseason team travel be included under team travel? Teams that earn a berth in a bowl game or NCAA championship have their expenses paid by the host. These teams are selected based on a winning season and are not planned and budgeted expenses of the institution. Including this travel distorts the expenses total for that team. The NCAA recommends a separate category for postseason expenses and revenues.

A Postseason revenues and expenses, including those paid by a host, must be included in an institution's EADA report. Our current Web-based collection form does not include a separate category for postseason expenses and revenues. An institution may use the comment section of the form to explain these data.

Q What are the criteria for determining if a team is a varsity team? Should junior varsity, club and freshman team members be counted as participants under EADA since they receive coaching, travel per diem, etc.? The NCAA believes the department's clarification of this distinction has been clear, but this question continues to be asked. The NCAA recommends that the department's position on this issue be restated as part of the new rules.

A A varsity team is one that either is designated by its institution or athletics association as a varsity team or that primarily competes against other teams that are designated by their institutions or athletics associations as varsity teams. 34 C.F.R. 668.47(a)(7).

Members of non-varsity teams (for example, junior varsity, freshman and club teams) should be counted as participants if, as of the day of a varsity team's first scheduled contest, they are listed by the institution on the varsity team's roster, receive athletically related student aid or practice with the varsity team and receive coaching from one or more varsity coaches. Any student who meets one of these criteria is a participant, including a student on a team the institution designates or defines as junior varsity, freshman or novice, or a student withheld from competition to preserve eligibility (i.e., a redshirt), or for academic, medical or other reasons. 34 C.F.R. 668.47(a)(3).

Q What is the definition of athletics aid? Where should financial aid for fifth-year, non-competing student-athletes be reported? It was recommended that financial aid should be reported in three categories: regular athletics aid, summer aid and fifth-year non-competing. The institution making this recommendation felt such a change would make the EADA data more comparable to the way Title IX participation opportunities are calculated. The NCAA recommends that the distinction between different types of aid be explained in the comment section of the form, with no separate columns for this information.

A Athletically related student aid is any form of financial assistance offered by an institution the terms of which required the recipient to participate in the institution's intercollegiate athletics program {34. C.F.R. 668.41(a)]. Aid received by a student-athlete that is not conditioned on his or her participation in athletics is not athletically related student aid. Our current Web-based collection form does not distinguish among types of athletically related student aid. An institution may use the comment section of the form to explain data.