TY 2024 Form 990

(A) Name and title	(B) Average hours per week (list any hours for related organizations below dotted line)	(C) Position (do not check more than one box, unless person is both an officer and a director/trustee)	(E) Reportable compensation from related organizations (W-2/1099-MISC/1099-NEC)
(1) FELIX V MATOS RODRIGUEZ...................................................................... CHAIR	1.00 .................	X	X
(2) TOM STRITIKUS...................................................................... VICE CHAIR/CHAIR ELECT	1.00 .................	X	X
(3) ANNE M KRESS...................................................................... INCOMING VICE CHAIR	1.00 .................	X
(4) LINDA A LIVINGSTONE...................................................................... IMMEDIATE PAST CHAIR	1.00 .................	X	X
(5) NEELI BENDAPUDI...................................................................... DIRECTOR	1.00 .................	X
(6) SCOTT PULSIPHER...................................................................... DIRECTOR	1.00 .................	X
(7) SIAN LEAH BEILOCK...................................................................... DIRECTOR	1.00 .................	X
(8) PAM EDDINGER...................................................................... DIRECTOR	1.00 .................	X
(9) ROBERT W IULIANO...................................................................... DIRECTOR	1.00 .................	X
(10) PHILOMENA V MANTELLA...................................................................... DIRECTOR	1.00 .................	X
(11) JAMES B MILLIKEN...................................................................... DIRECTOR	1.00 .................	X
(12) CARMEN TWILLIE AMBAR...................................................................... DIRECTOR	1.00 .................	X
(13) TED CARTER...................................................................... DIRECTOR	1.00 .................	X
(14) JUAN SANCHEZ MUNOZ...................................................................... DIRECTOR	1.00 .................	X
(15) MADELINE PUMARIEGA...................................................................... DIRECTOR	1.00 .................	X
(16) VALERIE SMITH...................................................................... DIRECTOR	1.00 .................	X
(17) FRANK J DOOLEY...................................................................... DIRECTOR	1.00 .................	X

(A) Name and title	(B) Average hours per week (list any hours for related organizations below dotted line)	(C) Position (do not check more than one box, unless person is both an officer and a director/trustee)	(E) Reportable compensation from related organizations (W-2/1099-MISC/1099-NEC)
(18) JOAN GABEL........................................................................ DIRECTOR	1.00 .......................	X			0	0
(19) WILLIAM SERRATA........................................................................ DIRECTOR	1.00 .......................	X			0	0
(20) RONALD S ROCHON........................................................................ DIRECTOR (AS OF 2/2025)	1.00 .......................	X			0	0
(21) ADAM BUSH........................................................................ DIRECTOR (AS OF 6/2025)	1.00 .......................	X			0	0
(22) REYNOLD VERRET........................................................................ DIRECTOR	1.00 .......................	X			0	0
(23) TERRENCE M SAWYER........................................................................ DIRECTOR	1.00 .......................	X			0	0
(24) JORGE G GONZALEZ........................................................................ DIRECTOR	1.00 .......................	X			0	0
(25) MELVA K WALLACE........................................................................ DIRECTOR	1.00 .......................	X			0	0
(26) CONNIE LEDOUX BOOK........................................................................ DIRECTOR	1.00 .......................	X			0	0
(27) ANDY BRANTLEY........................................................................ DIRECTOR	1.00 .......................	X			0	0
(28) JOHN O'BRIEN........................................................................ DIRECTOR	1.00 .......................	X			0	0
(29) JEE HANG LEE........................................................................ DIRECTOR	1.00 .......................	X			0	0
(30) ANA MARI CAUCE........................................................................ DIRECTOR (TO 4/2025)	1.00 .......................	X			0	0
(31) BEN VINSON III........................................................................ DIRECTOR (TO 4/2025)	1.00 .......................	X			0	0
(32) DONDE PLOWMAN........................................................................ DIRECTOR (TO 4/2025)	1.00 .......................	X			0	0
(33) HEIDI M ANDERSON........................................................................ DIRECTOR (TO 1/2025)	1.00 .......................	X			0	0
(34) SANTA J ONO........................................................................ DIRECTOR (TO 5/2025)	1.00 .......................	X			0	0
(35) THEODORE MITCHELL........................................................................ PRESIDENT, EX OFFICIO	35.00 .......................		X		881,160	149,929
(36) DERRICK ANDERSON........................................................................ SVP, ED FUTURES (TO 5/2025)	35.00 .......................		X		343,492	53,198
(37) JON FANSMITH........................................................................ SVP, GOVERNMENT RELATIONS	35.00 .......................		X		328,170	28,426
(38) JESSIE BROWN........................................................................ EXECUTIVE VICE PRESIDENT	35.00 .......................		X		297,964	94,664
(39) ZENITTA ANDERSON........................................................................ SVP, CAO	35.00 .......................		X		294,477	63,047
(40) JANICE LAMBERT........................................................................ VP FINANCE, CFO	35.00 .......................		X		268,928	21,825
(41) ANNE MEEHAN........................................................................ ASST VP, GOVT RELATIONS (TO 8/2024)	35.00 .......................			X	519,838	36,721
(42) PETER MCDONOUGH........................................................................ GENERAL COUNSEL	35.00 .......................			X	358,088	82,426
(43) MUSHTAQ GUNJA........................................................................ EXEC. DIR., CCS	35.00 .......................			X	308,275	64,160
(44) JESSE O'CONNELL........................................................................ CHIEF ADVANCEMENT OFFICER	35.00 .......................			X	269,294	59,330
(45) MARLON SUKAL........................................................................ CHIEF PEOPLE AND CULTURE OFFICER	35.00 .......................			X	268,098	66,760

(A) Name and business address	(B) Description of services	(C) Compensation
FRONTRUNNER COLLABORATIONS LLC 2715 BRADBURY CT DAVIDSONVILLE,MD21035	CONSULTING	178,600
ERNST & YOUNG LLP PO BOX 640382 PITTSBURGH,PA152640382	CONSULTING	162,500
WIPFLI LLP PO BOX 3160 MILWAUKEE,WI532013160	IT CONSULTING	153,900
ARENTFOX SCHIFF LLP PO BOX 7247 PHILADELPHIA,PA191700001	LEGAL SERVICES	151,728
DELOITTE CONSULTING LLP 4022 SELLS DRIVE HERMITAGE,TN37076	CONSULTING	140,000
2 Total number of independent contractors (including but not limited to those listed above) who received more than $100,000 of compensation from the organization 7

- TIN:

SCHEDULE A
(Form 990)

Department of the Treasury
Internal Revenue Service

Public Charity Status and Public Support

Complete if the organization is a section 501(c)(3) organization or a section 4947(a)(1) nonexempt charitable trust.
right arrow

Attach to Form 990 or Form 990-EZ.
right arrow

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

2024

Open to Public
Inspection

Name of the organization

AMERICAN COUNCIL ON EDUCATION

Employer identification number

53-0196573

Part I

Reason for Public Charity Status (All organizations must complete this part.) See instructions.

The organization is not a private foundation because it is: (For lines 1 through 12, check only one box.)

A church, convention of churches, or association of churches described in section 170(b)(1)(A)(i).

A school described in section 170(b)(1)(A)(ii). (Attach Schedule E (Form 990).)

A hospital or a cooperative hospital service organization described in section 170(b)(1)(A)(iii).

A medical research organization operated in conjunction with a hospital described in section 170(b)(1)(A)(iii). Enter the hospital's name, city, and state:

An organization operated for the benefit of a college or university owned or operated by a governmental unit described in section 170(b)(1)(A)(iv). (Complete Part II.)

A federal, state, or local government or governmental unit described in section 170(b)(1)(A)(v).

An organization that normally receives a substantial part of its support from a governmental unit or from the general public described in section 170(b)(1)(A)(vi). (Complete Part II.)

A community trust described in section 170(b)(1)(A)(vi). (Complete Part II.)

An agricultural research organization described in 170(b)(1)(A)(ix) operated in conjunction with a land-grant college or university or a non-land grant college of agriculture. See instructions. Enter the name, city, and state of the college or university:

An organization that normally receives: (1) more than 33 1/3% of its support from contributions, membership fees, and gross receipts from activities related to its exempt functions—subject to certain exceptions, and (2) no more than 33 1/3% of its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.)

An organization organized and operated exclusively to test for public safety. See section 509(a)(4).

An organization organized and operated exclusively for the benefit of, to perform the functions of, or to carry out the purposes of one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2). See section 509(a)(3). Check the box on lines 12a through 12d that describes the type of supporting organization and complete lines 12e, 12f, and 12g.

Type I. A supporting organization operated, supervised, or controlled by its supported organization(s), typically by giving the supported organization(s) the power to regularly appoint or elect a majority of the directors or trustees of the supporting organization. You must complete Part IV, Sections A and B.

Type II. A supporting organization supervised or controlled in connection with its supported organization(s), by having control or management of the supporting organization vested in the same persons that control or manage the supported organization(s). You must complete Part IV, Sections A and C.

Type III functionally integrated. A supporting organization operated in connection with, and functionally integrated with, its supported organization(s) (see instructions). You must complete Part IV, Sections A, D, and E.

Type III non-functionally integrated. A supporting organization operated in connection with its supported organization(s) that is not functionally integrated. The organization generally must satisfy a distribution requirement and an attentiveness requirement (see instructions). You must complete Part IV, Sections A and D, and Part V.

Check this box if the organization received a written determination from the IRS that it is a Type I, Type II, Type III functionally integrated, or Type III non-functionally integrated supporting organization.

Enter the number of supported organizations ...............................

Provide the following information about the supported organization(s).

(i) Name of supported organization	(ii) EIN	(iv) Is the organization listed in your governing document?		(v) Amount of monetary support (see instructions)	(vi) Amount of other support (see instructions)
(i) Name of supported organization	(ii) EIN	Yes	No	(v) Amount of monetary support (see instructions)	(vi) Amount of other support (see instructions)


Total

For Paperwork Reduction Act Notice, see the Instructions for
Form 990 or 990-EZ.

Cat. No. 11285F

Schedule A (Form 990) 2024

Page 2

Part II

Support Schedule for Organizations Described in Sections 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)
(Complete only if you checked the box on line 5, 7, or 8 of Part I or if the organization failed to qualify under Part III. If the organization failed to qualify under the tests listed below, please complete Part III.)

Section A. Public Support

Calendar year (or fiscal year beginning in)		(a) 2020	(b) 2021	(c) 2022	(d) 2023	(e) 2024	(f) Total
1	Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grant.") ..
2	Tax revenues levied for the organization's benefit and either paid to or expended on its behalf ....
3	The value of services or facilities furnished by a governmental unit to the organization without charge..
4	Total. Add lines 1 through 3
5	The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included on line 1 that exceeds 2% of the amount shown on line 11, column (f) ..
6	Public support. Subtract line 5 from line 4.

Section B. Total Support

Calendar year (or fiscal year beginning in)		(a) 2020	(b) 2021	(c) 2022	(d) 2023	(e) 2024	(f) Total
7	Amounts from line 4..
8	Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources...
9	Net income from unrelated business activities, whether or not the business is regularly carried on..
10	Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.)..
11	Total support. Add lines 7 through 10

Gross receipts from related activities, etc. (see instructions) ..................

First 5 years. If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a section 501(c)(3) organization, check this box and stop here ........................................ right arrow

Section C. Computation of Public Support Percentage

Public support percentage for 2024 (line 6, column (f) divided by line 11, column (f)) .........

Public support percentage for 2023 Schedule A, Part II, line 14 ...............

16a

33 1/3% support test—2024. If the organization did not check the box on line 13, and line 14 is 33 1/3% or more, check this box
and stop here. The organization qualifies as a publicly supported organization ....................... right arrow

33 1/3% support test—2023. If the organization did not check a box on line 13 or 16a, and line 15 is 33 1/3% or more, check this
box and stop here. The organization qualifies as a publicly supported organization ..................... right arrow

17a

10%-facts-and-circumstances test—2024. If the organization did not check a box on line 13, 16a, or 16b, and line 14 is 10% or more, and if the organization meets the "facts-and-circumstances" test, check this box and stop here. Explain in Part VI how the organization meets the "facts-and-circumstances" test. The organization qualifies as a publicly supported organization ............ right arrow

10%-facts-and-circumstances test—2023. If the organization did not check a box on line 13, 16a, 16b, or 17a, and line 15 is 10% or more, and if the organization meets the "facts-and-circumstances" test, check this box and stop here. Explain in Part VI how the organization meets the "facts-and-circumstances" test. The organization qualifies as a publicly supported organization ............ right arrow

Private foundation. If the organization did not check a box on line 13, 16a, 16b, 17a, or 17b, check this box and see
instructions ..................................................... right arrow

Schedule A (Form 990) 2024

Page 3

Part III

Support Schedule for Organizations Described in Section 509(a)(2)
(Complete only if you checked the box on line 10 of Part I or if the organization failed to qualify under Part II. If the organization fails to qualify under the tests listed below, please complete Part II.)

Section A. Public Support

Calendar year (or fiscal year beginning in)		(a) 2020	(b) 2021	(c) 2022	(d) 2023	(e) 2024	(f) Total
1	Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .	6,141,600	5,502,448	10,422,157	4,510,606	6,029,504	32,606,315
2	Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose	20,072,627	21,089,310	21,172,541	22,771,833	18,495,869	103,602,180
3	Gross receipts from activities that are not an unrelated trade or business under section 513 .....
4	Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...
5	The value of services or facilities furnished by a governmental unit to the organization without charge
6	Total. Add lines 1 through 5	26,214,227	26,591,758	31,594,698	27,282,439	24,525,373	136,208,495
7a	Amounts included on lines 1, 2, and 3 received from disqualified persons	6,440	2,950	700	500	1,000	11,590
b	Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.	7,804,606	5,095,043	3,511,781	6,197,402	5,682,965	28,291,797
c	Add lines 7a and 7b..	7,811,046	5,097,993	3,512,481	6,197,902	5,683,965	28,303,387
8	Public support. (Subtract line 7c from line 6.)						107,905,108

Section B. Total Support

Calendar year (or fiscal year beginning in)		(a) 2020	(b) 2021	(c) 2022	(d) 2023	(e) 2024	(f) Total
9	Amounts from line 6...	26,214,227	26,591,758	31,594,698	27,282,439	24,525,373	136,208,495
10a	Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..	7,582,315	7,390,521	7,799,266	8,050,482	7,521,657	38,344,241
b	Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.
c	Add lines 10a and 10b.	7,582,315	7,390,521	7,799,266	8,050,482	7,521,657	38,344,241
11	Net income from unrelated business activities not included on line 10b, whether or not the business is regularly carried on.
12	Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.) ..	45,604	78,602	90,218	88,369	100,092	402,885
13	Total support. (Add lines 9, 10c, 11, and 12.)..	33,842,146	34,060,881	39,484,182	35,421,290	32,147,122	174,955,621

First 5 years. If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a section 501(c)(3) organization, check this box and stop here................................................. right arrow

Section C. Computation of Public Support Percentage

Public support percentage for 2024 (line 8, column (f) divided by line 13, column (f)) .........

61.680 %

Public support percentage from 2023 Schedule A, Part III, line 15 ...............

64.460 %

Section D. Computation of Investment Income Percentage

Investment income percentage for 2024 (line 10c, column (f) divided by line 13, column (f)) ......

21.920 %

Investment income percentage from 2023 Schedule A, Part III, line 17 .............

22.490 %

19a

33 1/3% support tests-2024. If the organization did not check the box on line 14, and line 15 is more than 33 1/3%, and line 17 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization ....... right arrow

33 1/3 % support tests—2023. If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3% and line 18 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization ..... right arrow

Private foundation. If the organization did not check a box on line 14, 19a, or 19b, check this box and see instructions .... right arrow

Schedule A (Form 990) 2024

Page 4

Part IV

Supporting Organizations

(Complete only if you checked a box on line 12 of Part I. If you checked box 12a, of Part I, complete Sections A and B. If you checked box 12b, of Part I, complete Sections A and C. If you checked box 12c, of Part I, complete Sections A, D, and E. If you checked box12d, of Part I, complete Sections A and D, and complete Part V.)

Section A. All Supporting Organizations

Yes

Are all of the organization’s supported organizations listed by name in the organization’s governing documents?
If "No," describe in Part VI how the supported organizations are designated. If designated by class or purpose,
describe the designation. If historic and continuing relationship, explain.

Did the organization have any supported organization that does not have an IRS determination of status under section 509(a)(1) or (2)? If "Yes," explain in Part VI how the organization determined that the supported organization was described in section 509(a)(1) or (2).

Did the organization have a supported organization described in section 501(c)(4), (5), or (6)? If "Yes," answer lines 3b and 3c below.

Did the organization confirm that each supported organization qualified under section 501(c)(4), (5), or (6) and satisfied the public support tests under section 509(a)(2)? If "Yes," describe in Part VI when and how the organization made the determination.

Did the organization ensure that all support to such organizations was used exclusively for section 170(c)(2)(B) purposes? If "Yes," explain in Part VI what controls the organization put in place to ensure such use.

Was any supported organization not organized in the United States ("foreign supported organization")? If “Yes” and if you checked box 12a or 12b in Part I, answer lines 4b and 4c below.

Did the organization have ultimate control and discretion in deciding whether to make grants to the foreign supported organization? If “Yes,” describe in Part VI how the organization had such control and discretion despite being controlled or supervised by or in connection with its supported organizations.

Did the organization support any foreign supported organization that does not have an IRS determination under sections 501(c)(3) and 509(a)(1) or (2)? If “Yes,” explain in Part VI what controls the organization used to ensure that all support to the foreign supported organization was used exclusively for section 170(c)(2)(B) purposes.

Did the organization add, substitute, or remove any supported organizations during the tax year? If “Yes,” answer lines 5b and 5c below (if applicable). Also, provide detail in Part VI, including (i) the names and EIN numbers of the supported organizations added, substituted, or removed; (ii) the reasons for each such action; (iii) the authority under the organization's organizing document authorizing such action; and (iv) how the action was accomplished (such as by amendment to the organizing document).

Type I or Type II only. Was any added or substituted supported organization part of a class already designated in the organization's organizing document?

Substitutions only. Was the substitution the result of an event beyond the organization's control?

Did the organization provide support (whether in the form of grants or the provision of services or facilities) to anyone other than (i) its supported organizations, (ii) individuals that are part of the charitable class benefited by one or more of its supported organizations, or (iii) other supporting organizations that also support or benefit one or more of the filing organization’s supported organizations? If “Yes,” provide detail in Part VI.

Did the organization provide a grant, loan, compensation, or other similar payment to a substantial contributor (defined in section 4958(c)(3)(C)), a family member of a substantial contributor, or a 35% controlled entity with regard to a substantial contributor? If “Yes,” complete Part I of Schedule L (Form 990) .

Did the organization make a loan to a disqualified person (as defined in section 4958) not described on line 7? If “Yes,” complete Part I of Schedule L (Form 990).

Was the organization controlled directly or indirectly at any time during the tax year by one or more disqualified persons, as defined in section 4946 (other than foundation managers and organizations described in section 509(a)(1) or (2))? If “Yes,” provide detail in Part VI.

Did one or more disqualified persons (as defined on line 9a) hold a controlling interest in any entity in which the supporting organization had an interest? If “Yes,” provide detail in Part VI.

Did a disqualified person (as defined on line 9a) have an ownership interest in, or derive any personal benefit from, assets in which the supporting organization also had an interest? If “Yes,” provide detail in Part VI.

10a

Was the organization subject to the excess business holdings rules of section 4943 because of section 4943(f) (regarding certain Type II supporting organizations, and all Type III non-functionally integrated supporting organizations)? If “Yes,” answer line 10b below.

10a

Did the organization have any excess business holdings in the tax year? (Use Schedule C, Form 4720, to determine whether the organization had excess business holdings).

10b

Schedule A (Form 990) 2024

Page 5

Part IV

Supporting Organizations (continued)

Yes

Has the organization accepted a gift or contribution from any of the following persons?

A person who directly or indirectly controls, either alone or together with persons described on lines 11b and 11c below, the governing body of a supported organization?

11a

A family member of a person described on 11a above?

11b

A 35% controlled entity of a person described on line 11a or 11b above? If “Yes” to 11a, 11b, or 11c, provide detail in Part VI.

11c

Section B. Type I Supporting Organizations

Yes

Did the officers, directors, trustees, or membership of one or more supported organizations have the power to regularly appoint or elect at least a majority of the organization’s directors or trustees at all times during the tax year? If “No,” describe in Part VI how the supported organization(s) effectively operated, supervised, or controlled the organization’s activities. If the organization had more than one supported organization, describe how the powers to appoint and/or remove directors or trustees were allocated among the supported organizations and what conditions or restrictions, if any, applied to such powers during the tax year.

Did the organization operate for the benefit of any supported organization other than the supported organization(s) that operated, supervised, or controlled the supporting organization? If “Yes,” explain in Part VI how providing such benefit carried out the purposes of the supported organization(s) that operated, supervised or controlled the supporting organization.

Section C. Type II Supporting Organizations

Yes

Were a majority of the organization’s directors or trustees during the tax year also a majority of the directors or trustees of each of the organization’s supported organization(s)? If “No,” describe in Part VI how control or management of the supporting organization was vested in the same persons that controlled or managed the supported organization(s).

Section D. All Type III Supporting Organizations

Yes

Did the organization provide to each of its supported organizations, by the last day of the fifth month of the organization’s tax year, (i) a written notice describing the type and amount of support provided during the prior tax year, (ii) a copy of the Form 990 that was most recently filed as of the date of notification, and (iii) copies of the organization’s governing documents in effect on the date of notification, to the extent not previously provided?

Were any of the organization’s officers, directors, or trustees either (i) appointed or elected by the supported organization(s) or (ii) serving on the governing body of a supported organization? If "No," explain in Part VI how the organization maintained a close and continuous working relationship with the supported organization(s).

By reason of the relationship described in line 2 above, did the organization’s supported organizations have a significant voice in the organization’s investment policies and in directing the use of the organization’s income or assets at all times during the tax year? If "Yes," describe in Part VI the role the organization’s supported organizations played in this regard.

Section E. Type III Functionally-Integrated Supporting Organizations

Check the box next to the method that the organization used to satisfy the Integral Part Test during the year (see instructions):

The organization satisfied the Activities Test. Complete line 2 below.

The organization is the parent of each of its supported organizations. Complete line 3 below.

The organization supported a governmental entity. Describe in Part VI how you supported a government entity (see instructions)

Activities Test. Answer lines 2a and 2b below.

Yes

Did substantially all of the organization’s activities during the tax year directly further the exempt purposes of the supported organization(s) to which the organization was responsive? If "Yes," then in Part VI identify those supported organizations and explain how these activities directly furthered their exempt purposes, how the organization was responsive to those supported organizations, and how the organization determined that these activities constituted substantially all of its activities.

Did the activities described on line 2a, above constitute activities that, but for the organization’s involvement, one or more of the organization’s supported organization(s) would have been engaged in? If "Yes," explain in Part VI the reasons for the organization’s position that its supported organization(s) would have engaged in these activities but for the organization’s involvement.

Parent of Supported Organizations. Answer lines 3a and 3b below.

Did the organization have the power to regularly appoint or elect a majority of the officers, directors, or trustees of each of the supported organizations?If "Yes" or "No", provide details in Part VI.

Did the organization exercise a substantial degree of direction over the policies, programs and activities of each of its supported organizations? If "Yes," describe in Part VI. the role played by the organization in this regard.

Schedule A (Form 990) 2024

Page 6

Part V

Type III Non-Functionally Integrated 509(a)(3) Supporting Organizations

Check here if the organization satisfied the Integral Part Test as a qualifying trust on Nov. 20, 1970 (explain in Part VI). See instructions. All other Type III non-functionally integrated supporting organizations must complete Sections A through E.

	Section A - Adjusted Net Income		(A) Prior Year	(B) Current Year (optional)
1	Net short-term capital gain	1
2	Recoveries of prior-year distributions	2
3	Other gross income (see instructions)	3
4	Add lines 1 through 3	4
5	Depreciation and depletion	5
6	Portion of operating expenses paid or incurred for production or collection of gross income or for management, conservation, or maintenance of property held for production of income (see instructions)	6
7	Other expenses (see instructions)	7
8	Adjusted Net Income (subtract lines 5, 6 and 7 from line 4)	8

	Section B - Minimum Asset Amount		(A) Prior Year	(B) Current Year (optional)
1	Aggregate fair market value of all non-exempt-use assets (see instructions for short tax year or assets held for part of year):	1
a	Average monthly value of securities	1a
b	Average monthly cash balances	1b
c	Fair market value of other non-exempt-use assets	1c
d	Total (add lines 1a, 1b, and 1c)	1d
e	Discount claimed for blockage or other factors (explain in detail in Part VI):
2	Acquisition indebtedness applicable to non-exempt use assets	2
3	Subtract line 2 from line 1d	3
4	Cash deemed held for exempt use. Enter 0.015 of line 3 (for greater amount, see instructions).	4
5	Net value of non-exempt-use assets (subtract line 4 from line 3)	5
6	Multiply line 5 by 0.035	6
7	Recoveries of prior-year distributions	7
8	Minimum Asset Amount (add line 7 to line 6)	8

	Section C - Distributable Amount		Current Year
1	Adjusted net income for prior year (from Section A, line 8, Column A)	1
2	Enter 85% of line 1	2
3	Minimum asset amount for prior year (from Section B, line 8, Column A)	3
4	Enter greater of line 2 or line 3	4
5	Income tax imposed in prior year	5
6	Distributable Amount. Subtract line 5 from line 4, unless subject to emergency temporary reduction (see instructions)	6

Check here if the current year is the organization's first as a non-functionally-integrated Type III supporting organization (see instructions)

Schedule A (Form 990) 2024

Page 7

Part V

Type III Non-Functionally Integrated 509(a)(3) Supporting Organizations(continued)

Section D - Distributions		Current Year
1 Amounts paid to supported organizations to accomplish exempt purposes	1
2 Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity	2
3 Administrative expenses paid to accomplish exempt purposes of supported organizations	3
4 Amounts paid to acquire exempt-use assets	4
5 Qualified set-aside amounts (prior IRS approval required - provide details in Part VI)	5
6 Other distributions (describe in Part VI). See instructions	6
7Total annual distributions. Add lines 1 through 6.	7
8 Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions	8
9 Distributable amount for 2024 from Section C, line 6	9
10 Line 8 amount divided by Line 9 amount	10

Section E - Distribution Allocations (see instructions)		(i) Excess Distributions	(ii) Underdistributions Pre-2024	(iii) Distributable Amount for 2024
1 Distributable amount for 2024 from Section C, line 6
2 Underdistributions, if any, for years prior to 2024 (reasonable cause required-- explain in Part VI). See instructions.
3 Excess distributions carryover, if any, to 2024:
a From 2019.......
b From 2020.......
c From 2021.......
d From 2022.......
e From 2023.......
fTotal of lines 3a through e
g Applied to underdistributions of prior years
h Applied to 2024 distributable amount
i Carryover from 2019 not applied (see instructions)
j Remainder. Subtract lines 3g, 3h, and 3i from line 3f.
4Distributions for 2024 from Section D, line 7:
$
a Applied to underdistributions of prior years
b Applied to 2024 distributable amount
c Remainder. Subtract lines 4a and 4b from line 4.
5 Remaining underdistributions for years prior to 2024, if any. Subtract lines 3g and 4a from line 2. If the amount is greater than zero, explain in Part VI. See instructions.
6 Remaining underdistributions for 2024. Subtract lines 3h and 4b from line 1. If the amount is greater than zero, explain in Part VI. See instructions.
7 Excess distributions carryover to 2025. Add lines 3j and 4c.
8 Breakdown of line 7:
a Excess from 2020.....
b Excess from 2021.....
c Excess from 2022.....
d Excess from 2023.....
e Excess from 2024.....

Schedule A (Form 990) (2024)

Schedule A (Form 990) 2024

Page 8

Part VI

Supplemental Information. Provide the explanations required by Part II, line 10; Part II, line 17a or 17b; Part III, line 12; Part IV, Section A, lines 1, 2, 3b, 3c, 4b, 4c, 5a, 6, 9a, 9b, 9c, 11a, 11b, and 11c; Part IV, Section B, lines 1 and 2; Part IV, Section C, line 1; Part IV, Section D, lines 2 and 3; Part IV, Section E, lines 1c, 2a, 2b, 3a and 3b; Part V, line 1; Part V, Section B, line 1e; Part V Section D, lines 5, 6, and 8; and Part V, Section E, lines 2, 5, and 6. Also complete this part for any additional information. (See instructions).

Facts And Circumstances Test

Return Reference	Explanation
SCHEDULE A, PART III, LINE 12, EXPLANATION OF OTHER INCOME:	GARAGE PARKING OTHER REVENUE VENDING MACHINE SERVICE REVENUE

Schedule A (Form 990) 2024

Additional Data

Software ID:
Software Version:

- TIN:

Schedule B
(Form 990)
(Rev. January 2025)

Department of the Treasury
Internal Revenue Service

Schedule of Contributors

Attach to Form 990, 990-EZ, or 990-PF.

Go to www.irs.gov/Form990 for the latest information.

OMB No. 1545-0047

Name of the organization

AMERICAN COUNCIL ON EDUCATION

Employer identification number

53-0196573

Organization type (check one):

Filers of:

Section:

Form 990 or 990-EZ

501(c)( ) (enter number) organization

4947(a)(1) nonexempt charitable trust not treated as a private foundation

527 political organization

Form 990-PF

501(c)(3) exempt private foundation

4947(a)(1) nonexempt charitable trust treated as a private foundation

501(c)(3) taxable private foundation

Check if your organization is covered by the General Rule or a Special Rule.
Note: Only a section 501(c)(7), (8), or (10) organization can check boxes for both the General Rule and a Special Rule. See instructions.

General Rule

For an organization filing Form 990, 990-EZ, or 990-PF that received, during the year, contributions totaling $5,000 or more (in money or other property) from any one contributor. Complete Parts I and II. See instructions for determining a contributor's total contributions.

Special Rules

For an organization described in section 501(c)(3) filing Form 990 or 990-EZ that met the 33¹/3% support test of the regulations
under sections 509(a)(1) and 170(b)(1)(A)(vi), that checked Schedule A (Form 990 or 990-EZ), Part II, line 13, 16a, or 16b, and that received from any one contributor, during the year, total contributions of the greater of (1) $5,000 or (2) 2% of the amount on (i) Form 990, Part VIII, line 1h, or (ii) Form 990-EZ, line 1. Complete Parts I and II.

For an organization described in section 501(c)(7), (8), or (10) filing Form 990 or 990-EZ that received from any one contributor,
during the year, total contributions of more than $1,000 exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals. Complete Parts I, II, and III.

For an organization described in section 501(c)(7), (8), or (10) filing Form 990 or 990-EZ that received from any one contributor,
during the year, contributions exclusively for religious, charitable, etc., purposes, but no such contributions totaled more than $1,000. If this box is checked, enter here the total contributions that were received during the year for an exclusively religious, charitable, etc., purpose. Don't complete any of the parts unless the General Rule applies to this organization because it received nonexclusively religious, charitable, etc., contributions totaling $5,000 or more during the year ......... Right Arrow

Caution: An organization that isn't covered by the General Rule and/or the Special Rules doesn't file Schedule B (Form 990,
990-EZ, or 990-PF), but it must answer “No” on Part IV, line 2, of its Form 990; or check the box on line H of its Form 990-EZ
or on its Form 990PF, Part I, line 2, to certify that it doesn't meet the filing requirements of Schedule B (Form 990,
990-EZ, or 990-PF).

For Paperwork Reduction Act Notice, see the Instructions
for Form 990, 990-EZ, or 990-PF.

Cat. No. 30613XSchedule B (Form 990) (Rev. 1-2025)

Schedule B (Form 990) (Rev. 1-2025) Page 2

Name of organization AMERICAN COUNCIL ON EDUCATION

Part I	Contributors (see instructions). Use duplicate copies of Part I if additional space is needed.
(a) No.	(b) Name, address, and ZIP + 4	(c) Total contributions	(d) Type of contribution
RESTRICTED	,	$ RESTRICTED	Person Payroll Noncash (Complete Part II for noncash contributions.)
(a) No.	(b) Name, address, and ZIP + 4	(c) Total contributions	(d) Type of contribution
		$	Person Payroll Noncash (Complete Part II for noncash contributions.)
(a) No.	(b) Name, address, and ZIP + 4	(c) Total contributions	(d) Type of contribution
		$	Person Payroll Noncash (Complete Part II for noncash contributions.)
(a) No.	(b) Name, address, and ZIP + 4	(c) Total contributions	(d) Type of contribution
		$	Person Payroll Noncash (Complete Part II for noncash contributions.)
(a) No.	(b) Name, address, and ZIP + 4	(c) Total contributions	(d) Type of contribution
		$	Person Payroll Noncash (Complete Part II for noncash contributions.)
(a) No.	(b) Name, address, and ZIP + 4	(c) Total contributions	(d) Type of contribution
		$	Person Payroll Noncash (Complete Part II for noncash contributions.)
Schedule B (Form 990) (Rev. 1-2025)

Schedule B (Form 990) (Rev. 1-2025)

Page 3

Name of organization AMERICAN COUNCIL ON EDUCATION		Employer identification number 53-0196573

Part II	Noncash Property (see instructions). Use duplicate copies of Part II if additional space is needed.
(a) No. from Part I	(b) Description of noncash property given	(c) FMV (or estimate) (See instructions)	(d) Date received
		$
(a) No. from Part I	(b) Description of noncash property given	(c) FMV (or estimate) (See instructions)	(d) Date received
		$
(a) No. from Part I	(b) Description of noncash property given	(c) FMV (or estimate) (See instructions)	(d) Date received
		$
(a) No. from Part I	(b) Description of noncash property given	(c) FMV (or estimate) (See instructions)	(d) Date received
		$
(a) No. from Part I	(b) Description of noncash property given	(c) FMV (or estimate) (See instructions)	(d) Date received
		$
(a) No. from Part I	(b) Description of noncash property given	(c) FMV (or estimate) (See instructions)	(d) Date received
		$
Schedule B (Form 990) (Rev. 1-2025)

Schedule B (Form 990) (Rev. 1-2025)

Page 4


Name of organization AMERICAN COUNCIL ON EDUCATION			Employer identification number 53-0196573
Part III Exclusively religious, charitable, etc., contributions to organizations described in section 501(c) (7), (8), or (10) that total more than $1,000 for the year from any one contributor. Complete columns (a) through (e) and the following line entry. For organizations completing Part III, enter the total of exclusively religious, charitable, etc., contributions of $1,000 or less for the year. (Enter this information once. See instructions.) $ Use duplicate copies of Part III if additional space is needed.

(a)
No. from Part I

(b) Purpose of gift

(d) Description of how gift is held

(e) Transfer of gift
Transferee's name, address, and ZIP 4	Relationship of transferor to transferee

(a)
No. from Part I

(b) Purpose of gift

(d) Description of how gift is held

(e) Transfer of gift
Transferee's name, address, and ZIP 4	Relationship of transferor to transferee

(a)
No. from Part I

(b) Purpose of gift

(d) Description of how gift is held

(e) Transfer of gift
Transferee's name, address, and ZIP 4	Relationship of transferor to transferee

(a)
No. from Part I

(b) Purpose of gift

(d) Description of how gift is held

(e) Transfer of gift
Transferee's name, address, and ZIP 4	Relationship of transferor to transferee

Schedule B (Form 990) (Rev. 1-2025)

Additional Data

Software ID:
Software Version:

- TIN:

SCHEDULE C
(Form 990)

Department of the Treasury
Internal Revenue Service

Political Campaign and Lobbying Activities

For Organizations Exempt From Income Tax Under section 501(c) and section 527

right arrow

Complete if the organization is described below. right arrow

Attach to Form 990 or Form 990-EZ.
right arrow

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

2024

Open to Public
Inspection

If the organization answered "Yes" on Form 990, Part IV, Line 3, or Form 990-EZ, Part V, line 46 (Political Campaign Activities), then
Round Bullet

Section 501(c)(3) organizations: Complete Parts I-A and B. Do not complete Part I-C.
Round Bullet

Section 501(c) (other than section 501(c)(3)) organizations: Complete Parts I-A and C below. Do not complete Part I-B.
Round Bullet

Section 527 organizations: Complete Part I-A only.
If the organization answered "Yes" on Form 990, Part IV, Line 4, or Form 990-EZ, Part VI, line 47 (Lobbying Activities), then
Round Bullet

Section 501(c)(3) organizations that have filed Form 5768 (election under section 501(h)): Complete Part II-A. Do not complete Part II-B.
Round Bullet

Section 501(c)(3) organizations that have NOT filed Form 5768 (election under section 501(h)): Complete Part II-B. Do not complete Part II-A.
If the organization answered "Yes" on Form 990, Part IV, Line 5 (Proxy Tax) (see separate instructions) or Form 990-EZ, Part V, line 35c (Proxy Tax) (see separate instructions), then
Round Bullet

Section 501(c)(4), (5), or (6) organizations: Complete Part III.

Name of the organization

AMERICAN COUNCIL ON EDUCATION

Employer identification number

53-0196573

Part I-A

Complete if the organization is exempt under section 501(c) or is a section 527 organization.

Provide a description of the organization’s direct and indirect political campaign activities in Part IV. See instructions for definition of “political campaign activities."

Political campaign activity expenditures. See instructions .................................................................... right arrow

Volunteer hours for political campaign activities. See instructions ..................................................................

Part I-B

Complete if the organization is exempt under section 501(c)(3).

Enter the amount of any excise tax incurred by the organization under section 4955 ................................ right arrow

Enter the amount of any excise tax incurred by organization managers under section 4955 ....................... right arrow

If the organization incurred a section 4955 tax, did it file Form 4720 for this year? .........................................

Yes No

Was a correction made? ......................................................................................................................

Yes No

If "Yes," describe in Part IV.

Part I-C

Complete if the organization is exempt under section 501(c), except section 501(c)(3).

Enter the amount directly expended by the filing organization for section 527 exempt function activities ..... right arrow

Enter the amount of the filing organization's funds contributed to other organizations for section 527 exempt function activities ............................................................................................................................ right arrow

Total exempt function expenditures. Add lines 1 and 2. Enter here and on Form 1120-POL, line 17b........... right arrow

Did the filing organization file Form 1120-POL for this year? ...................................................................

Yes No

Enter the names, addresses and employer identification number (EIN) of all section 527 political organizations to which the filing
organization made payments. For each organization listed, enter the amount paid from the filing organization’s funds. Also enter the amount of political contributions received that were promptly and directly delivered to a separate political organization, such as a separate segregated fund or a political action committee (PAC). If additional space is needed, provide information in Part IV.

(a) Name	(b) Address	(c) EIN	(d) Amount paid from filing organization's funds. If none, enter -0-.	(e) Amount of political contributions received and promptly and directly delivered to a separate political organization. If none, enter -0-.
1
2
3
4
5
6

For Paperwork Reduction Act Notice, see the instructions for Form 990.

Cat. No. 50084S

Schedule C (Form 990) 2024

Page 2

Part II-A

Complete if the organization is exempt under section 501(c)(3) and filed Form 5768 (election under section 501(h)).

A Check right arrow

if the filing organization belongs to an affiliated group (and list in Part IV each affiliated group member's name, address, EIN, expenses, and share of excess lobbying expenditures).
B Check right arrow

if the filing organization checked box A and "limited control" provisions apply.

Limits on Lobbying Expenditures (The term "expenditures" means amounts paid or incurred.)		(a) Filing organization's totals	(b) Affiliated group totals
1a	Total lobbying expenditures to influence public opinion (grass roots lobbying) ......................	0
b	Total lobbying expenditures to influence a legislative body (direct lobbying) ........................	248,474
c	Total lobbying expenditures (add lines 1a and 1b) ............................................................	248,474
d	Other exempt purpose expenditures ...............................................................................	40,901,809
e	Total exempt purpose expenditures (add lines 1c and 1d) ..................................................	41,150,283
f	Lobbying nontaxable amount. Enter the amount from the following table in both columns.	1,000,000
	If the amount on line 1e, column (a) or (b) is:The lobbying nontaxable amount is:
	Not over $500,00020% of the amount on line 1e.
	Over $500,000 but not over $1,000,000$100,000 plus 15% of the excess over $500,000.
	Over $1,000,000 but not over $1,500,000$175,000 plus 10% of the excess over $1,000,000.
	Over $1,500,000 but not over $17,000,000$225,000 plus 5% of the excess over $1,500,000.
	Over $17,000,000$1,000,000.

g	Grassroots nontaxable amount (enter 25% of line 1f) .................................................	250,000
h	Subtract line 1g from line 1a. If zero or less, enter -0-. ................................................	0
i	Subtract line 1f from line 1c. If zero or less, enter -0-. ................................................	0
j	If there is an amount other than zero on either line 1h or line 1i, did the organization file Form 4720 reporting section 4911 tax for this year? ...................................................................................................................		Yes No

4-Year Averaging Period Under Section 501(h) (Some organizations that made a section 501(h) election do not have to complete all of the five columns below. See the separate instructions for lines 2a through 2f.)
Lobbying Expenditures During 4-Year Averaging Period
	Calendar year (or fiscal year beginning in)	(a) 2021	(b) 2022	(c) 2023	(d) 2024	(e) Total

2a	Lobbying nontaxable amount	1,000,000	1,000,000	1,000,000	1,000,000	4,000,000

b	Lobbying ceiling amount (150% of line 2a, column(e))					6,000,000

c	Total lobbying expenditures	322,912	201,701	276,287	248,474	1,049,374

d	Grassroots nontaxable amount	250,000	250,000	250,000	250,000	1,000,000

e	Grassroots ceiling amount (150% of line 2d, column (e))					1,500,000

f	Grassroots lobbying expenditures

Schedule C (Form 990) 2024

Page 3

Part II-B

Complete if the organization is exempt under section 501(c)(3) and has NOT filed Form 5768 (election under section 501(h)).

For each "Yes" response on lines 1a through 1i below, provide in Part IV a detailed description of the lobbying activity.

(a)

Yes

(b)

Amount

During the year, did the filing organization attempt to influence foreign, national, state or local legislation, including any attempt to influence public opinion on a legislative matter or referendum, through the use of:

Volunteers? ...........................................................................................................

Paid staff or management (include compensation in expenses reported on lines 1c through 1i)? ........

Media advertisements? ...................................................................................................

Mailings to members, legislators, or the public? .............................................................................

Publications, or published or broadcast statements? ...........................................................

Grants to other organizations for lobbying purposes? ..........................................................

Direct contact with legislators, their staffs, government officials, or a legislative body? .......................

Rallies, demonstrations, seminars, conventions, speeches, lectures, or any similar means? ..................

Other activities? ...................................................................................................................

Total. Add lines 1c through 1i ....................................................................................................

Did the activities in line 1 cause the organization to be not described in section 501(c)(3)? .....

If "Yes," enter the amount of any tax incurred under section 4912 ...........................................

If "Yes," enter the amount of any tax incurred by organization managers under section 4912 ...................

If the filing organization incurred a section 4912 tax, did it file Form 4720 for this year? ........................

Part III-A

Complete if the organization is exempt under section 501(c)(4), section 501(c)(5), or section 501(c)(6).

Yes

Were substantially all (90% or more) dues received nondeductible by members? ...............................................

Did the organization make only in-house lobbying expenditures of $2,000 or less? ............................................

Did the organization agree to carry over lobbying and political expenditures from the prior year? .................................

Part III-B

Complete if the organization is exempt under section 501(c)(4), section 501(c)(5), or section 501(c)(6) and if either (a) BOTH Part III-A, lines 1 and 2, are answered "No" OR (b) Part III-A, line 3, is answered “Yes."

Dues, assessments and similar amounts from members ......................................................................

Section 162(e) nondeductible lobbying and political expenditures (do not include amounts of political expenses for which the section 527(f) tax was paid).

Current year .............................................................................................................................

Carryover from last year ............................................................................................................

Total ...........................................................................................................................................

Aggregate amount reported in section 6033(e)(1)(A) notices of nondeductible section 162(e) dues .

If notices were sent and the amount on line 2c exceeds the amount on line 3, what portion of the excess does the organization agree to carryover to the reasonable estimate of nondeductible lobbying and political expenditure next year? ......................................................................................................................

Taxable amount of lobbying and political expenditures. See Instructions .........................................

Part IV

Supplemental Information

Provide the descriptions required for Part l-A, line 1; Part l-B, line 4; Part l-C, line 5; Part II-A (affiliated group list); Part II-A, lines 1 and 2 (see instructions), and Part ll-B, line 1. Also, complete this part for any additional information.

Return Reference	Explanation

Schedule C (Form 990) 2024

Additional Data

Software ID:
Software Version:

- TIN:

SCHEDULE D
(Form 990)

Department of the Treasury
Internal Revenue Service

Supplemental Financial Statements

Complete if the organization answered "Yes," on Form 990,
Part IV, line 6, 7, 8, 9, 10, 11a, 11b, 11c, 11d, 11e, 11f, 12a, or 12b.
right arrow

Attach to Form 990.
right arrow

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

Open to Public Inspection

Name of the organization

AMERICAN COUNCIL ON EDUCATION

Employer identification number

53-0196573

Part I

Organizations Maintaining Donor Advised Funds or Other Similar Funds or Accounts. Complete if the organization answered "Yes" on Form 990, Part IV, line 6.

		(a) Donor advised funds	(b) Funds and other accounts
1	Total number at end of year .........
2	Aggregate value of contributions to (during year)
3	Aggregate value of grants from (during year)
4	Aggregate value at end of year ........

Did the organization inform all donors and donor advisors in writing that the assets held in donor advised funds are the organization’s property, subject to the organization’s exclusive legal control? ............

Yes No

Did the organization inform all grantees, donors, and donor advisors in writing that grant funds can be used only for charitable purposes and not for the benefit of the donor or donor advisor, or for any other purpose conferring impermissible private benefit? ...................................

Yes No

Part II

Conservation Easements.
Complete if the organization answered "Yes" on Form 990, Part IV, line 7.

Purpose(s) of conservation easements held by the organization (check all that apply).

Preservation of land for public use (e.g., recreation or education) Preservation of an historically important land area

Protection of natural habitat Preservation of a certified historic structure

Preservation of open space

Complete lines 2a through 2d if the organization held a qualified conservation contribution in the form of a conservation easement on the last day of the tax year.


a	Total number of conservation easements ......................	2a
b	Total acreage restricted by conservation easements ....................	2b
c	Number of conservation easements on a certified historic structure included in (a) .....	2c
d	Number of conservation easements included in (c) acquired after July 25, 2006, and not on a historic structure listed in the National Register ...	2d

Number of conservation easements modified, transferred, released, extinguished, or terminated by the organization during the
tax year right arrow

Number of states where property subject to conservation easement is located right arrow

Does the organization have a written policy regarding the periodic monitoring, inspection, handling of violations, and enforcement of the conservation easements it holds? ............

Yes No

Staff and volunteer hours devoted to monitoring, inspecting, handling of violations, and enforcing conservation easements during the year
right arrow

Amount of expenses incurred in monitoring, inspecting, handling of violations, and enforcing conservation easements during the year
right arrow

Does each conservation easement reported on line 2(d) above satisfy the requirements of section 170(h)(4)(B)(i) and section 170(h)(4)(B)(ii)? .............................

Yes No

In Part XIII, describe how the organization reports conservation easements in its revenue and expense statement, and
balance sheet, and include, if applicable, the text of the footnote to the organization’s financial statements that describes
the organization’s accounting for conservation easements.

Part III

Organizations Maintaining Collections of Art, Historical Treasures, or Other Similar Assets.
Complete if the organization answered "Yes" on Form 990, Part IV, line 8.

If the organization elected, as permitted under FASB ASC 958, not to report in its revenue statement and balance sheet works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of public service, provide, in Part XIII, the text of the footnote to its financial statements that describes these items.

If the organization elected, as permitted under FASB ASC 958, to report in its revenue statement and balance sheet works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of public service, provide the following amounts relating to these items:

(i)

Revenue included on Form 990, Part VIII, line 1 ......................... right arrow

(ii)

Assets included in Form 990, Part X ............................... right arrow

If the organization received or held works of art, historical treasures, or other similar assets for financial gain, provide the
following amounts required to be reported under FASB ASC 958 relating to these items:

Revenue included on Form 990, Part VIII, line 1 .......................... right arrow

Assets included in Form 990, Part X ............................... right arrow

For Paperwork Reduction Act Notice, see the Instructions for Form 990.

Cat. No. 52283D

Schedule D (Form 990) (Rev. 1-2025)

Page 2

Part III

Organizations Maintaining Collections of Art, Historical Treasures, or Other Similar Assets (continued)

Using the organization’s acquisition, accession, and other records, check any of the following that are a significant use of its collection items (check all that apply):

Public exhibition

Loan or exchange programs

Scholarly research

Other

Preservation for future generations

Provide a description of the organization’s collections and explain how they further the organization’s exempt purpose in
Part XIII.

During the year, did the organization solicit or receive donations of art, historical treasures or other similar
assets to be sold to raise funds rather than to be maintained as part of the organization’s collection?...

Yes No

Part IV

Escrow and Custodial Arrangements. Complete if the organization answered "Yes" on Form 990, Part IV, line 9, or reported an amount on Form 990, Part X, line 21.

Is the organization an agent, trustee, custodian or other intermediary for contributions or other assets not
included on Form 990, Part X? ....................................

Yes No


b	If "Yes," explain the arrangement in Part XIII and complete the following table:		Amount
c	Beginning balance .............................	1c
d	Additions during the year ............................	1d
e	Distributions during the year ..........................	1e
f	Ending balance ................................	1f

Did the organization include an amount on Form 990, Part X, line 21, for escrow or custodial account liability? ...

Yes No

If "Yes," explain the arrangement in Part XIII. Check here if the explanation has been provided in Part XIII ....

Part V

Endowment Funds.
Complete if the organization answered "Yes" on Form 990, Part IV, line 10.

		(a) Current year	(b) Prior year	(c) Two years back	(d) Three years back	(e) Four years back

1a	Beginning of year balance ....
b	Contributions ...
c	Net investment earnings, gains, and losses
d	Grants or scholarships ...
e	Other expenditures for facilities and programs ...
f	Administrative expenses ....
g	End of year balance ......

Provide the estimated percentage of the current year end balance (line 1g, column (a)) held as:

Board designated or quasi-endowment right arrow

Permanent endowment right arrow

Term endowment right arrow

The percentages on lines 2a, 2b, and 2c should equal 100%.

Are there endowment funds not in the possession of the organization that are held and administered for the
organization by:

Yes

(i) Unrelated organizations .................

3a(i)

(ii) Related organizations .................

3a(ii)

If "Yes" on 3a(ii), are the related organizations listed as required on Schedule R? .........

Describe in Part XIII the intended uses of the organization's endowment funds.

Part VI

Land, Buildings, and Equipment.
Complete if the organization answered "Yes" on Form 990, Part IV, line 11a. See Form 990, Part X, line 10.

Description of property		(a) Cost or other basis (investment)	(b) Cost or other basis (other)	(c) Accumulated depreciation	(d) Book value

1a	Land .....	2,678,042		2,678,042
b	Buildings ....	26,725,626	19,945,690	6,779,936
c	Leasehold improvements
d	Equipment ....	7,228,008	5,771,218	1,456,790
e	Other .....	17,163,171	14,291,143	2,872,028
Total. Add lines 1a through 1e. (Column (d) must equal Form 990, Part X, column (B), line 10(c).)..				13,786,796

Schedule D (Form 990) (Rev. 1-2025)

Page 3

Part VII

Investments - Other Securities.
Complete if the organization answered "Yes" on Form 990, Part IV, line 11b. See Form 990, Part X, line 12.

(a) Description of security or category (including name of security)	(b) Book value	(c) Method of valuation: Cost or end-of-year market value
(1) Financial derivatives.........
(2) Closely-held equity interests........
(3)Other
(A)
(B)
(C)
(D)
(E)
(F)
(G)
(H)
Total. (Column (b) must equal Form 990, Part X, col. (B) line 12.)

Part VIII

Investments - Program Related. Complete if the organization answered 'Yes' on Form 990, Part IV, line 11c. See Form 990, Part X, line 13.

(a) Description of investment	(b) Book value	(c) Method of valuation: Cost or end-of-year market value

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
Total. (Column (b) must equal Form 990, Part X, col.(B) line 13.)

Part IX

Other Assets.
Complete if the organization answered 'Yes' on Form 990, Part IV, line 11d. See Form 990, Part X, line 15.

(a) Description				(b) Book value

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
Total. (Column (b) must equal Form 990, Part X, col.(B) line 15.)...........

Part X

Other Liabilities.
Complete if the organization answered 'Yes' on Form 990, Part IV, line 11e or 11f. See Form 990, Part X, line 25.

1.(a) Description of liability	(b) Book value
(1) Federal income taxes
RETIREE MEDICAL BEN. OBLIGATION	2,097,331
OTHER LIABILITIES	3,172,069







Total. (Column (b) must equal Form 990, Part X, col.(B) line 25.)	5,269,400
2. Liability for uncertain tax positions. In Part XIII, provide the text of the footnote to the organization's financial statements that reports the organization's liability for uncertain tax positions under FIN 48 (ASC 740). Check here if the text of the footnote has been provided in Part XIII

Schedule D (Form 990) (Rev. 1-2025)

Page 4

Part XI Reconciliation of Revenue per Audited Financial Statements With Revenue per Return. Complete if the organization answered 'Yes' on Form 990, Part IV, line 12a.
1	Total revenue, gains, and other support per audited financial statements .......			1	37,177,948
2	Amounts included on line 1 but not on Form 990, Part VIII, line 12:
a	Net unrealized gains (losses) on investments ....	2a	2,949,558
b	Donated services and use of facilities .........	2b
c	Recoveries of prior year grants ...........	2c
d	Other (Describe in Part XIII.) ...........	2d
e	Add lines 2a through 2d .....................			2e	2,949,558
3	Subtract line 2e from line 1..................			3	34,228,390
4	Amounts included on Form 990, Part VIII, line 12, but not on line 1:
a	Investment expenses not included on Form 990, Part VIII, line 7b .	4a	85,038
b	Other (Describe in Part XIII.) ...........	4b	-28,269
c	Add lines 4a and 4b....................			4c	56,769
5	Total revenue. Add lines 3 and 4c. (This must equal Form 990, Part I, line 12.) ......			5	34,285,159

Part XII Reconciliation of Expenses per Audited Financial Statements With Expenses per Return. Complete if the organization answered 'Yes' on Form 990, Part IV, line 12a.
1	Total expenses and losses per audited financial statements ...........			1	41,310,346
2	Amounts included on line 1 but not on Form 990, Part IX, line 25:
a	Donated services and use of facilities .........	2a
b	Prior year adjustments ............	2b
c	Other losses ................	2c
d	Other (Describe in Part XIII.) ...........	2d	61,477
e	Add lines 2a through 2d....................			2e	61,477
3	Subtract line 2e from line 1...................			3	41,248,869
4	Amounts included on Form 990, Part IX, line 25, but not on line 1:
a	Investment expenses not included on Form 990, Part VIII, line 7b ..	4a	85,038
b	Other (Describe in Part XIII.) ...........	4b
c	Add lines 4a and 4b.....................			4c	85,038
5	Total expenses. Add lines 3 and 4c. (This must equal Form 990, Part I, line 18.) ......			5	41,333,907

Part XIII

Supplemental Information

Provide the descriptions required for Part II, lines 3, 5, and 9; Part III, lines 1a and 4; Part lV, lines 1b and 2b; Part V, line 4; Part X, line 2; Part XI, lines 2d and 4b; and Part XII, lines 2d and 4b. Also complete this part to provide any additional information.

Return Reference	Explanation
PART X, LINE 2:	ACE EVALUATED ITS UNCERTAINTY IN INCOME TAXES AND DETERMINED THAT THERE WERE NO MATTERS THAT WOULD REQUIRE RECOGNITION IN THE FINANCIAL STATEMENTS OR THAT MAY HAVE ANY EFFECT ON ITS TAX-EXEMPT STATUS. AS OF SEPTEMBER 30, 2025 AND 2024, THERE WERE NO AUDITS FOR ANY TAX PERIODS PENDING OR IN PROGRESS.
PART XI, LINE 4B - OTHER ADJUSTMENTS:	COST OF GOODS SOLD -28,269.
PART XII, LINE 2D - OTHER ADJUSTMENTS:	COST OF GOODS SOLD 28,269. POSTRETIREMENT CHANGE OTHER THAN NET PERIODIC BENEFIT COST 33,208.

Schedule D (Form 990) (Rev. 1-2025)

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Schedule I
(Form 990)
(Rev. January 2025)

Department of the Treasury
Internal Revenue Service

Grants and Other Assistance to Organizations,
Governments and Individuals in the United States

Complete if the organization answered "Yes," on Form 990, Part IV, line 21 or 22.
lBullet

Attach to Form 990.
lBullet

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

Open to Public
Inspection

Name of the organization
AMERICAN COUNCIL ON EDUCATION

Employer identification number
53-0196573

Part I

General Information on Grants and Assistance

Does the organization maintain records to substantiate the amount of the grants or assistance, the grantees' eligibility for the grants or assistance, and
the selection criteria used to award the grants or assistance? ........................

Yes No

Describe in Part IV the organization's procedures for monitoring the use of grant funds in the United States.

Part II

Grants and Other Assistance to Domestic Organizations and Domestic Governments. Complete if the organization answered "Yes" on Form 990, Part IV, line 21, for any recipient

that received more than $5,000. Part II can be duplicated if additional space is needed.

(a) Name and address of organization or government	(b) EIN	(c) IRC section (if applicable)	(d) Amount of cash grant	(e) Amount of non-cash assistance	(f) Method of valuation (book, FMV, appraisal, other)	(g) Description of noncash assistance	(h) Purpose of grant or assistance
(1) MARICOPA COMMUNITY COLLEGE DISTRICT 2411 WEST 14TH STREET TEMPE,AZ85281	86-0185552	GOVT ENTITY	10,000	0			AWARD FOR INSTITUTIONAL TRANSFORMATION
(2) UNIVERSITY OF HAWAII FOUNDATION 1314 SOUTH KING STREET SUITE B HONOLULU,HI96814	99-0085260	501(C)(3)	10,000	0			AWARD FOR INSTITUTIONAL TRANSFORMATION

Enter total number of section 501(c)(3) and government organizations listed in the line 1 table ................. Bullet Image

Enter total number of other organizations listed in the line 1 table ........................ . Bullet Image

For Paperwork Reduction Act Notice, see the Instructions for Form 990.

Cat. No. 50055P

Schedule I (Form 990) Rev. 1-2025

Page 2

Part III

Grants and Other Assistance to Domestic Individuals. Complete if the organization answered "Yes" on Form 990, Part IV, line 22.
Part III can be duplicated if additional space is needed.

(a) Type of grant or assistance	(b) Number of recipients	(c) Amount of cash grant	(d) Amount of noncash assistance	(e) Method of valuation (book, FMV, appraisal, other)	(f) Description of noncash assistance

(1)
(2)
(3)
(4)
(5)
(6)
(7)

Part IV

Supplemental Information. Provide the information required in Part I, line 2; Part III, column (b); and any other additional information.

Return Reference

Explanation

PART I, LINE 2:

ACE IS REQUIRED TO PERFORM SUBRECIPIENT MONITORING OF THE FUNDS IT RECEIVES FROM FEDERAL SOURCES IN ORDER TO ENSURE THAT THE FUNDS ARE BEING USED FOR THEIR INTENDED PURPOSE AND THAT THERE ARE NO UNIFORM GUIDANCE 2 CFR 200 AUDIT FINDINGS THAT MAY ADVERSELY AFFECT THE USE OF THE SUBRECIPIENTS' FEDERAL FUNDS. SUBRECIPIENT MONITORING EFFORTS ARE A JOINT EFFORT OF PROGRAM STAFF AND THE FINANCE & BUDGET STAFF. ALL OTHER GRANT FUNDS PROVIDED TO ENTITIES ARE SIMILARLY MONITORED THROUGH THE USE OF SUBAWARD AGREEMENTS OR CONTRACTS & PERIODIC REPORTING PROVIDED BY GRANTEES TO ACE.

Schedule I (Form 990) Rev. 1-2025

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Schedule J
(Form 990)
(Rev. January 2025)

Department of the Treasury
Internal Revenue Service

Compensation Information

For certain Officers, Directors, Trustees, Key Employees, and Highest
Compensated Employees
medium right arrow graphic

Complete if the organization answered "Yes" on Form 990, Part IV, line 23.
medium right arrow graphic

Attach to Form 990.
medium right arrow graphic

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

Open to Public Inspection

Name of the organization

AMERICAN COUNCIL ON EDUCATION

Employer identification number

53-0196573

Part I

Questions Regarding Compensation

Yes

Check the appropiate box(es) if the organization provided any of the following to or for a person listed on Form
990, Part VII, Section A, line 1a. Complete Part III to provide any relevant information regarding these items.

First-class or charter travel Housing allowance or residence for personal use

Travel for companions Payments for business use of personal residence

Tax idemnification and gross-up payments Health or social club dues or initiation fees

Discretionary spending account Personal services (e.g., maid, chauffeur, chef)

If any of the boxes on Line 1a are checked, did the organization follow a written policy regarding payment or reimbursement or provision of all of the expenses described above? If "No," complete Part III to explain .....

Yes

Did the organization require substantiation prior to reimbursing or allowing expenses incurred by all
directors, trustees, officers, including the CEO/Executive Director, regarding the items checked on Line 1a? ....

Yes

Indicate which, if any, of the following the filing organization used to establish the compensation of the
organization's CEO/Executive Director. Check all that apply. Do not check any boxes for methods
used by a related organization to establish compensation of the CEO/Executive Director, but explain in Part III.

Compensation committee Written employment contract

Independent compensation consultant Compensation survey or study

Form 990 of other organizations Approval by the board or compensation committee

During the year, did any person listed on Form 990, Part VII, Section A, line 1a, with respect to the filing organization or a related organization:

Receive a severance payment or change-of-control payment? .............

Yes

Participate in, or receive payment from, a supplemental nonqualified retirement plan? .........

Yes

Participate in, or receive payment from, an equity-based compensation arrangement? .........

If "Yes" to any of lines 4a-c, list the persons and provide the applicable amounts for each item in Part III.

Only 501(c)(3), 501(c)(4), and 501(c)(29) organizations must complete lines 5-9.

For persons listed on Form 990, Part VII, Section A, line 1a, did the organization pay or accrue any
compensation contingent on the revenues of:

The organization? ....................

Any related organization? .......................

If "Yes," on line 5a or 5b, describe in Part III.

For persons listed on Form 990, Part VII, Section A, line 1a, did the organization pay or accrue any
compensation contingent on the net earnings of:

The organization? ..................

Any related organization? ......................

If "Yes," on line 6a or 6b, describe in Part III.

For persons listed on Form 990, Part VII, Section A, line 1a, did the organization provide any nonfixed
payments not described in lines 5 and 6? If "Yes," describe in Part III ............

Were any amounts reported on Form 990, Part VII, paid or accured pursuant to a contract that was
subject to the initial contract exception described in Regulations section 53.4958-4(a)(3)? If "Yes," describe
in Part III ..........................

If "Yes" on line 8, did the organization also follow the rebuttable presumption procedure described in Regulations section 53.4958-6(c)? .........................

For Paperwork Reduction Act Notice, see the Instructions for Form 990.

Cat. No. 50053T

Schedule J (Form 990) (Rev. 1-2025)

Page 2

Part II

Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees. Use duplicate copies if additional space is needed.

For each individual whose compensation must be reported on Schedule J, report compensation from the organization on row (i) and from related organizations, described in the
instructions, on row (ii). Do not list any individuals that are not listed on Form 990, Part VII.
Note. The sum of columns (B)(i)-(iii) for each listed individual must equal the total amount of Form 990, Part VII, Section A, line 1a, applicable column (D) and (E) amounts for that individual.

(A) Name and Title		(B) Breakdown of W-2, 1099-MISC compensation, and/or 1099-NEC			(C) Retirement and other deferred compensation	(D) Nontaxable benefits	(E) Total of columns (B)(i)-(D)	(F) Compensation in column (B) reported as deferred on prior Form 990
(A) Name and Title		(i) Base compensation	(ii) Bonus & incentive compensation	(iii) Other reportable compensation	(C) Retirement and other deferred compensation	(D) Nontaxable benefits	(E) Total of columns (B)(i)-(D)
1THEODORE MITCHELL PRESIDENT, EX OFFICIO	(i) (ii)	716,771 ------------- 0	0 ------------- 0	164,389 ------------- 0	134,500 ------------- 0	15,429 ------------- 0	1,031,089 ------------- 0	0 ------------- 0
2ANNE MEEHAN ASST VP, GOVT RELATIONS (TO 8/2024)	(i) (ii)	144,746 ------------- 0	0 ------------- 0	375,092 ------------- 0	13,290 ------------- 0	23,431 ------------- 0	556,559 ------------- 0	0 ------------- 0
3PETER MCDONOUGH GENERAL COUNSEL	(i) (ii)	357,018 ------------- 0	0 ------------- 0	1,070 ------------- 0	57,500 ------------- 0	24,926 ------------- 0	440,514 ------------- 0	0 ------------- 0
4DERRICK ANDERSON SVP, ED FUTURES (TO 5/2025)	(i) (ii)	342,985 ------------- 0	0 ------------- 0	507 ------------- 0	27,431 ------------- 0	25,767 ------------- 0	396,690 ------------- 0	0 ------------- 0
5JESSIE BROWN EXECUTIVE VICE PRESIDENT	(i) (ii)	297,404 ------------- 0	0 ------------- 0	560 ------------- 0	54,595 ------------- 0	40,069 ------------- 0	392,628 ------------- 0	0 ------------- 0
6MUSHTAQ GUNJA EXEC. DIR., CCS	(i) (ii)	308,185 ------------- 0	0 ------------- 0	90 ------------- 0	31,951 ------------- 0	32,209 ------------- 0	372,435 ------------- 0	0 ------------- 0
7ZENITTA ANDERSON SVP, CAO	(i) (ii)	294,339 ------------- 0	0 ------------- 0	138 ------------- 0	30,521 ------------- 0	32,526 ------------- 0	357,524 ------------- 0	0 ------------- 0
8JON FANSMITH SVP, GOVERNMENT RELATIONS	(i) (ii)	327,619 ------------- 0	0 ------------- 0	551 ------------- 0	26,493 ------------- 0	1,933 ------------- 0	356,596 ------------- 0	0 ------------- 0
9MARLON SUKAL CHIEF PEOPLE AND CULTURE OFFICER	(i) (ii)	267,651 ------------- 0	0 ------------- 0	447 ------------- 0	50,389 ------------- 0	16,371 ------------- 0	334,858 ------------- 0	0 ------------- 0
10JESSE O'CONNELL CHIEF ADVANCEMENT OFFICER	(i) (ii)	268,734 ------------- 0	0 ------------- 0	560 ------------- 0	27,927 ------------- 0	31,403 ------------- 0	328,624 ------------- 0	0 ------------- 0
11JANICE LAMBERT VP FINANCE, CFO	(i) (ii)	268,928 ------------- 0	0 ------------- 0	0 ------------- 0	20,275 ------------- 0	1,550 ------------- 0	290,753 ------------- 0	0 ------------- 0

Schedule J (Form 990) (Rev. 1-2025)

Page 3

Part III

Supplemental Information

Provide the information, explanation, or descriptions required for Part I, lines 1a, 1b, 3, 4a, 4b, 4c, 5a, 5b, 6a, 6b, 7, and 8, and for Part II. Also complete this part for any additional information.

Return Reference

Explanation

PART I, LINE 1A

THEODORE MITCHELL'S W-2 COMPENSATION INCLUDES IMPUTED OCCUPANCY INCOME FOR RESIDENCE FOR PERSONAL USE IN THE AMOUNT OF $161,132. THIS AMOUNT IS INCLUDED IN TAXABLE COMPENSATION AS OTHER REPORTABLE COMPENSATION. PER THE PRESIDENT'S EMPLOYMENT CONTRACT, COMPENSATION INCLUDES AN AMOUNT TO REASONABLY APPROXIMATE "GROSSED UP" PERSONAL INCOME TAXES INCURRED BY THE PRESIDENT AS A RESULT OF IMPUTED OCCUPANCY INCOME.

PART I, LINES 4A-B

LINE 4A, ANNE MEEHAN: $375,000 LINE 4B, THEODORE MITCHELL: $0 DISTRIBUTION AND $100,000 CONTRIBUTION

Schedule J (Form 990) (Rev. 1-2025)

Additional Data

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SCHEDULE O
(Form 990)
(Rev. January 2025)
Department of the Treasury
Internal Revenue Service

Supplemental Information to Form 990 or 990-EZ

Complete to provide information for responses to specific questions on
Form 990 or 990-EZ or to provide any additional information.
Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

Open to Public
Inspection

Name of the organization

AMERICAN COUNCIL ON EDUCATION

Employer identification number

53-0196573

Return Reference	Explanation
FORM 990, HEADER, BOX L	ACE WAS FORMED IN 1918 AS AN UNINCORPORATED ASSOCIATION IN THE DISTRICT OF COLUMBIA AND EXECUTED A CERTIFICATE OF INCORPORATION IN THE DISTRICT OF COLUMBIA IN 1931.
FORM 990, PART VI, SECTION A, LINE 1A	ACE'S EXECUTIVE COMMITTEE IS MADE UP OF THE BOARD CHAIR, VICE CHAIR, SECRETARY, IMMEDIATE PAST CHAIR, ACE PRESIDENT, AND AT LEAST TWO ADDITIONAL MEMBERS OF THE BOARD OF DIRECTORS. THE EXECUTIVE COMMITTEE IS EMPOWERED TO ACT ON BEHALF OF THE FULL BOARD AS NECESSARY. THE PRESIDENT IS AN EX-OFFICIO NON-VOTING MEMBER OF THE BOARD.
FORM 990, PART VI, SECTION A, LINE 6	THE COUNCIL HAS FIVE CLASSES OF MEMBERS: NATIONAL ASSOCIATION MEMBERS, INSTITUTIONAL MEMBERS, ORGANIZATION MEMBERS, PROBATIONARY MEMBERS, AND ASSOCIATE MEMBERS. -NATIONAL ASSOCIATION MEMBERS ARE NON-PROFIT ORGANIZATIONS PRIMARILY CONCERNED WITH HIGHER EDUCATION. -INSTITUTIONAL MEMBERS CONSIST OF COLLEGES AND UNIVERSITIES, LEGALLY AUTHORIZED TO GRANT DEGREES, ACCREDITED BY AN AGENCY RECOGNIZED BY THE COUNCIL FOR HIGHER EDUCATION ACCREDITATION OR BY AN AGENCY RECOGNIZED BY THE DEPARTMENT OF EDUCATION, OR A MULTI-CAMPUS INSTITUTION OR STATE SYSTEM. -ORGANIZATION MEMBERS ARE NON-PROFIT ORGANIZATIONS PRIMARILY CONCERNED WITH HIGHER EDUCATION AND WHOSE MEMBERSHIP IS RESTRICTED BY LOCAL, STATE, OR REGIONAL BOUNDARIES OR OTHER CONSIDERATIONS; OR NON-PROFIT ORGANIZATIONS PRINCIPALLY ENGAGED IN ELEMENTARY OR SECONDARY EDUCATION AND WHICH ARE LOCAL, STATE, REGIONAL, OR NATIONAL IN SCOPE. -PROBATIONARY MEMBERS CONSIST OF COLLEGES, UNIVERSITIES, AND OTHER POST-SECONDARY INSTITUTIONS THAT OFFER DEGREES AND ARE CANDIDATES FOR ACCREDITATION BY AN AGENCY RECOGNIZED BY THE COUNCIL FOR HIGHER EDUCATION ACCREDITATION OR BY THE DEPARTMENT OF EDUCATION. -ASSOCIATE MEMBERS ARE NON-VOTING MEMBERS OF WHOSE INCLUSION IN THE COUNCIL MAY ADVANCE THE INTERESTS OF HIGHER EDUCATION, ACE OR ITS MEMBERSHIP, AND ARE IN THE FOLLOWING CATEGORIES: -BRANCH OR REGIONAL SUBSCRIBERS, SUCH AS CAMPUSES THAT ARE NOT SEPARATELY ACCREDITED, BUT UNDER THE AUSPICES OF A MEMBER-ELIGIBLE INSTITUTION OR SYSTEM. -INTERNATIONAL MEMBERS, SUCH AS HIGHER EDUCATION ASSOCIATIONS OR INSTITUTIONS OUTSIDE THE UNITED STATES AND ITS TERRITORIES THAT ARE RECOGNIZED BY THE APPROPRIATE AUTHORITY IN THE COUNTRY. -LEARNED SOCIETY MEMBERS, SUCH AS ACADEMIC AND SCHOLARLY SOCIETIES THAT EXIST TO PROMOTE AN ACADEMIC DISCIPLINE OR PROFESSION, OR A GROUP OF RELATED DISCIPLINES OR PROFESSIONS. -AFFILIATE MEMBERS, SUCH AS CORPORATIONS, FOUNDATIONS, AND OTHER ORGANIZATIONS THAT ARE CONCERNED WITH HIGHER EDUCATION. INDIVIDUAL MEMBERS, SUCH AS INDIVIDUALS CONCERNED WITH HIGHER EDUCATION. -INDIVIDUAL MEMBERS, SUCH AS INDIVIDUALS CONCERNED WITH HIGHER EDUCATION.
FORM 990, PART VI, SECTION A, LINE 7A	A MAJORITY OF THE BOARD OF DIRECTORS ARE ELECTED BY NATIONAL ASSOCIATION MEMBERS, INSTITUTIONAL MEMBERS, ORGANIZATION MEMBERS, AND PROBATIONARY MEMBERS. VOTING IS LIMITED TO MEMBERS THAT ARE NON-PROFIT, TAX-EXEMPT ENTITIES.
FORM 990, PART VI, SECTION B, LINE 11B	A DRAFT VERSION OF IRS FORMS 990 AND 990-T ARE INITIALLY CIRCULATED AMONG ACE'S ENTIRE BOARD PRIOR TO FILING. THE PURPOSE OF MAKING THE FORMS AVAILABLE TO THE ENTIRE BOARD MEMBERSHIP IS TO SOLICIT QUESTIONS AND/OR SUGGESTIONS FOR IMPROVEMENTS TO THE DRAFT. ACE'S CHIEF FINANCIAL OFFICER (CFO) COMPILES ALL COMMENTS RECEIVED FROM THE BOARD AND RESOLVES THOSE MATTERS PRIOR TO FILING OF FORMS 990 AND 990-T. ACE'S AUDIT, FINANCE AND COMPLIANCE COMMITTEE OF THE BOARD OF DIRECTORS IS CHARGED WITH COMPLIANCE OVERSIGHT, INCLUDING THE ACCURATE AND TIMELY FILING OF FORMS 990 AND 990-T. THE AUDIT, FINANCE AND COMPLIANCE COMMITTEE ALSO PERIODICALLY RECEIVES UPDATES CONCERNING CHANGES TO THE FORMS PROMULGATED BY THE IRS.
FORM 990, PART VI, SECTION B, LINE 12C	ACE HAS A CONFLICT-OF-INTEREST POLICY. THE COUNCIL'S GENERAL COUNSEL IS RESPONSIBLE FOR MANAGING AN ANNUAL PROCESS BY WHICH EACH COVERED PERSON, AND EVERY OTHER ACE EMPLOYEE, IS ASKED TO COMPLETE A CONFLICT-OF-INTEREST QUESTIONNAIRE AND CERTIFY THAT THE PERSON HAS READ, COMPLIED WITH AND AGREES TO COMPLY WITH THAT POLICY.
FORM 990, PART VI, SECTION B, LINE 15	ACE'S BOARD OF DIRECTORS DELEGATES AUTHORITY TO ACE'S COMPENSATION COMMITTEE COMPOSED OF MEMBERS OF ITS EXECUTIVE COMMITTEE TO PROVIDE INDEPENDENT OVERSIGHT AND, AS APPROPRIATE, APPROVAL OF SALARY AND OTHER COMPENSATION ARRANGEMENTS FOR ACE'S PRESIDENT AND OTHER OFFICERS AND EMPLOYEES WHO ARE IN A POSTION TO EXERT SUBSTANTIAL INFLUENCE OVER ACE'S AFFAIRS AND THUS LIKELY TO BE CONSIDERED "DISQUALIFIED PERSONS" WITHIN THE MEANING OF SECTION 4958 OF THE IRC. THE POSITIONS, IN ADDITION TO THE PRESIDENT, FOR WHICH THE COMPENSATION COMMITTEE PROVIDES OVERSIGHT AND APPROVAL INCLUDE ALL SENIOR VICE PRESIDENTS AND ACE'S CHIEF FINANCIAL OFFICER. THE COMPENSATION COMMITTEE IS ATTENTIVE TO THE POLICIES RELATED TO THE COUNCIL'S COMPENSATION STRUCTURE FOR THESE POSITIONS AND ENSURES THAT SUCH COMPENSATION IS REASONABLY INFORMED BY COMPENSATION OFFERED FOR SIMILAR SERVICES BY COMPARABLE ASSOCIATIONS OR ORGANIZATIONS, TAKING INTO ACCOUNT THEIR COMPARABLE CIRCUMSTANCES. REGARDING THE PRESIDENT POSITION SPECIFICALLY, THE COMPENSATION COMMITTEE HAS A PRACTICE OF RECEIVING COMPARABLE COMPENSATION DATA, INFORMED BY INDEPENDENT COMPENSATION CONSULTANTS, FOR A PEER GROUP OF ORGANIZATIONS WHICH INCLUDES THE PRIMARY RECRUITING SOURCES FOR THE ACE PRESIDENT POSITION.
FORM 990, PART VI, SECTION C, LINE 19	THESE DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC TO THE EXTENT THE FINANCIAL STATEMENTS ARE INCLUDED IN AN ANNUAL REPORT, IF PUBLISHED, ON THE PUBLICLY AVAILABLE ACE WEBSITE. GOVERNING DOCUMENTS AND THE CONFLICT-OF-INTEREST POLICY ARE PROVIDED TO THE PUBLIC UPON REQUEST.
FORM 990, PART IX, LINE 11G	CONSULTANTS: PROGRAM SERVICE EXPENSES 2,702,619. MANAGEMENT AND GENERAL EXPENSES 1,313,767. FUNDRAISING EXPENSES 69,193. TOTAL EXPENSES 4,085,579. CONTRACTED PERSONNEL: PROGRAM SERVICE EXPENSES 50,231. MANAGEMENT AND GENERAL EXPENSES 24,418. FUNDRAISING EXPENSES 1,286. TOTAL EXPENSES 75,935. HONORARIUM: PROGRAM SERVICE EXPENSES 47,739. MANAGEMENT AND GENERAL EXPENSES 23,206. FUNDRAISING EXPENSES 1,222. TOTAL EXPENSES 72,167. RECRUITMENT: PROGRAM SERVICE EXPENSES 28,931. MANAGEMENT AND GENERAL EXPENSES 14,064. FUNDRAISING EXPENSES 741. TOTAL EXPENSES 43,736. SPEAKER FEES: PROGRAM SERVICE EXPENSES 37,250. MANAGEMENT AND GENERAL EXPENSES 0. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 37,250. SUB-AWARDS: PROGRAM SERVICE EXPENSES 2,491,103. MANAGEMENT AND GENERAL EXPENSES 0. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 2,491,103. BUSINESS & SERVICE FEES: PROGRAM SERVICE EXPENSES 16,168. MANAGEMENT AND GENERAL EXPENSES 7,859. FUNDRAISING EXPENSES 414. TOTAL EXPENSES 24,441. OTHER SERVICE FEES: PROGRAM SERVICE EXPENSES 7,939. MANAGEMENT AND GENERAL EXPENSES 3,859. FUNDRAISING EXPENSES 203. TOTAL EXPENSES 12,001.
FORM 990, PART XI, LINE 9:	POSTRETIREMENT CHANGE OTHER THAN NET PERIODIC BENEFIT COST -33,208.

For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.

Cat. No. 51056K

Schedule O (Form 990) (Rev. 1-2025)

Additional Data

Software ID:
Software Version:

		Prior Year	Current Year
8	Contributions and grants (Part VIII, line 1h) .........	4,510,606	6,029,504
9	Program service revenue (Part VIII, line 2g) .........	22,765,558	18,539,259
10	Investment income (Part VIII, column (A), lines 3, 4, and 7d ) ....	3,100,507	4,097,532
11	Other revenue (Part VIII, column (A), lines 5, 6d, 8c, 9c, 10c, and 11e)	5,885,326	5,618,864
12	Total revenue—add lines 8 through 11 (must equal Part VIII, column (A), line 12)	36,261,997	34,285,159
13	Grants and similar amounts paid (Part IX, column (A), lines 1–3 )...	22,000	24,150
14	Benefits paid to or for members (Part IX, column (A), line 4).....	0	0
15	Salaries, other compensation, employee benefits (Part IX, column (A), lines 5–10)	22,083,906	23,916,168
16a	Professional fundraising fees (Part IX, column (A), line 11e) .....	0	0
b	Total fundraising expenses (Part IX, column (D), line 25) 1,241,150
17	Other expenses (Part IX, column (A), lines 11a–11d, 11f–24e)....	16,674,223	17,393,589
18	Total expenses. Add lines 13–17 (must equal Part IX, column (A), line 25)	38,780,129	41,333,907
19	Revenue less expenses. Subtract line 18 from line 12.......	-2,518,132	-7,048,748
		Beginning of Current Year	End of Year
20	Total assets (Part X, line 16).............	94,252,664	93,542,895
21	Total liabilities (Part X, line 26).............	18,915,361	22,337,990
22	Net assets or fund balances. Subtract line 21 from line 20.....	75,337,303	71,204,905

Sign Here

	Signature of officer	Date

	Type or print name and title


4a	(Code: ) (Expenses $ 7,503,862 including grants of $ ) (Revenue $ 6,900,445 )
	ADULT LEARNING AND EDUCATIONAL CREDENTIALSTHE AMERICAN COUNCIL ON EDUCATION (ACE) ADMINISTERS A NATIONAL PROGRAM THAT EVALUATES, VALIDATES, AND DOCUMENTS COLLEGE-LEVEL LEARNING GAINED THROUGH MILITARY TRAINING, OCCUPATIONAL EXPERIENCE, EMPLOYER-BASED INSTRUCTION, AND OTHER NONTRADITIONAL LEARNING ENVIRONMENTS. THROUGH FACULTY-LED REVIEW PROCESSES, ACE DEVELOPS ACADEMICALLY SOUND CREDIT RECOMMENDATIONS AND BENCHMARKS INDUSTRY COMPETENCIES THAT ASSIST LEARNERS IN APPLYING VERIFIED LEARNING TOWARD ACCREDITED POSTSECONDARY CREDENTIALS. THE PROGRAM MAINTAINS PUBLICLY ACCESSIBLE RESOURCES THAT HELP LEARNERS, INSTITUTIONS, AND EMPLOYERS UNDERSTAND DOCUMENTED LEARNING OUTCOMES AND MAKE INFORMED DECISIONS ABOUT THE APPLICABILITY OF PRIOR LEARNING.ACE ALSO ADVANCES RESEARCH, CROSS-SECTOR PARTNERSHIPS, AND TECHNICAL INITIATIVES AIMED AT IMPROVING INSTITUTIONAL RECOGNITION OF LEARNING, CREDENTIAL TRANSPARENCY, AND THE INTEROPERABILITY OF EDUCATION AND WORKFORCE SYSTEMS. THESE ACTIVITIES SUPPORTED STATE SYSTEMS, HIGHER EDUCATION INSTITUTIONS, FEDERAL AGENCIES, AND EMPLOYERS IN IMPLEMENTING POLICIES AND PRACTICES THAT EXPAND LEARNER MOBILITY AND STRENGTHEN ALIGNMENT BETWEEN EDUCATION AND WORKFORCE PATHWAYS.ACE CONTINUES ITS LONGSTANDING SUPPORT OF THE DEPARTMENT OF DEFENSE BY EVALUATING MILITARY TRAINING AND OCCUPATIONAL EXPERIENCES AND BY ENHANCING THE SYSTEMS THAT COMMUNICATE VALIDATED LEARNING TO SERVICE MEMBERS, VETERANS, AND ACADEMIC INSTITUTIONS. THESE EFFORTS CONTRIBUTE TO IMPROVED READINESS, PROFESSIONAL DEVELOPMENT, AND TRANSITION OUTCOMES BY ENSURING THAT LEARNING GAINED DURING MILITARY SERVICE IS RECOGNIZED THROUGH TRUSTED AND CONSISTENT ACADEMIC CREDIT RECOMMENDATIONS.THE COMBINED PORTFOLIO ADVANCES ACE'S MISSION TO PROMOTE HIGH-QUALITY RECOGNITION OF LEARNING, REDUCE BARRIERS TO DEGREE COMPLETION, AND SUPPORT THE SUCCESS OF MILITARY LEARNERS, ADULT LEARNERS, AND CAREER-FOCUSED STUDENTS ACROSS THE NATION. ANNUALLY, OVER 400,000 TRANSCRIPTS REFLECTING ACE CREDIT RECOMMENDATIONS ARE SUBMITTED BY LEARNERS TO INSTITUTIONS.

4b	(Code: ) (Expenses $ 4,737,476 including grants of $ ) (Revenue $ 19,300 )
	CARNEGIE CLASSIFICATIONFOR THE LAST 50 YEARS, THE CARNEGIE CLASSIFICATIONS OF INSTITUTIONS OF HIGHER EDUCATION HAVE BEEN THE GOLD STANDARD FOR ORGANIZING COLLEGES AND UNIVERSITIES BY A VARIETY OF CHARACTERISTICS, AND THEY ARE USED BY RESEARCHERS AROUND THE WORLD TO STUDY THE HIGHER EDUCATION SECTOR IN AMERICA. ACE BEGAN A COLLABORATION WITH THE CARNEGIE FOUNDATION IN FEBRUARY 2022 TO REDESIGN THE CARNEGIE CLASSIFICATIONS SO THEY BETTER REFLECT THE DIVERSE SET OF INSTITUTIONS AND MISSIONS IN HIGHER EDUCATION TODAY AND TO ESTABLISH NEW CLASSIFICATIONS, INCLUDING ONES THAT ARE CENTERED ON STUDENTS' SOCIAL AND ECONOMIC MOBILITY. IN FY25, ACE CONTINUED ENGAGEMENT WITH A LARGE, DIVERSE SET OF STAKEHOLDERS, ULTIMATELY REACHING MORE THAN 15,000 PEOPLE IN TOTAL SINCE THE PROJECT BEGAN, INCLUDING 600 UNIQUE INSTITUTIONS. ACE RELEASED THE REVISED 2025 RESEARCH ACTIVITY DESIGNATIONS IN FEBRUARY 2025 AND THE FULL 2025 CARNEGIE CLASSIFICATIONS IN APRIL 2025, INCLUDING THE NEW STUDENT ACCESS AND EARNINGS CLASSIFICATION, AND THE RELEASES WERE AMPLIFIED BY MORE THAN 300 NEWS STORIES AND INSTITUTIONAL PRESS RELEASES. BY THE END OF FY25, THE CARNEGIE CLASSIFICATIONS WEBSITE HAD MORE THAN 900,000 VIEWS FROM MORE THAN 150,000 VISITORS SINCE THE RELEASE DATE. ADDITIONALLY, ACE FURTHERED WORK ON THE ELECTIVE CLASSIFICATIONS, INCLUDING LAUNCHING A PILOT FOR A NEW CARNEGIE ELECTIVE CLASSIFICATION FOR SUSTAINABILITY, AND THE TEAM RECEIVED 270 APPLICATIONS FOR INSTITUTIONS TO BE CLASSIFIED OR RECLASSIFIED UNDER THE COMMUNITY ENGAGEMENT ELECTIVE CLASSIFICATION.

4c	(Code: ) (Expenses $ 4,647,113 including grants of $ ) (Revenue $ 13,000 )
	GOVERNMENT RELATIONS & PUBLIC AFFAIRSACE'S DIVISION OF GOVERNMENT RELATIONS AND NATIONAL ENGAGEMENT (GRNE) COORDINATES THE EFFORTS OF THE HIGHER EDUCATION COMMUNITY IN REPRESENTING ITS CONCERNS TO THE FEDERAL GOVERNMENT. STAFF MEMBERS, ENGAGE WITH FEDERAL POLICY MAKERS ON PROPOSED FEDERAL LEGISLATION AND REGULATIONS, PREPARE TESTIMONY FOR CONGRESSIONAL HEARINGS AND FILE AMICUS CURIAE BRIEFS ON COURT CASES WITH IMPORTANT IMPLICATIONS FOR HIGHER EDUCATION, AND CREATE SHARED ADVOCACY MATERIALS AMONG OTHER ACTIVITIES. FOR FEDERAL GOVERNMENT POLICY MAKERS, THE DIVISION ACTS AS THE CENTRAL SOURCE OF INFORMATION AND COUNSEL ON ISSUES IMPORTANT TO THE HIGHER EDUCATION COMMUNITY. DIVISION STAFF MEMBERS ALSO COMMUNICATE INFORMATION ON RELEVANT FEDERAL AND STATE EDUCATIONAL CONCERNS AND ACE POLICY POSITIONS TO THE MEDIA, COLLEGE AND UNIVERSITY OFFICIALS, AND THE GENERAL PUBLIC. ANOTHER MEANS OF DISSEMINATION OF THIS INFORMATION IS THE ACE ANNUAL MEETING, WHICH IS AN IDEAL SETTING FOR NETWORKING WITH COLLEAGUES AND ADDRESSING FUTURE CHALLENGES OF HIGHER EDUCATION, INCLUDING IN THE PUBLIC POLICY ARENA.THE OFFICE OF PUBLIC AFFAIRS WORKS TO MAINTAIN THE COUNCIL'S PRESENCE AS A TOP SOURCE FOR MEDIA ON HIGHER EDUCATION ISSUES AND POLICY, ENHANCE PUBLIC UNDERSTANDING OF A WIDE RANGE OF HIGHER EDUCATION TOPICS, ADVOCATE ON BEHALF OF ACE MEMBERSHIP ON KEY ISSUES, AND PROMOTE THE IMPORTANT WORK OF ACE PROGRAMS.

	(Code: ) (Expenses $ 3,705,079 including grants of $ 24,150 ) (Revenue $ 485,378 )
	PROFESSIONAL DEVELOPMENT PROGRAMSACE CONNECT SERVES AS ACE'S CENTRAL HUB FOR COMMUNITY STRATEGY AND ENGAGEMENT, BUILDING PARTNERSHIPS AND FOSTERING COLLABORATION ACROSS THE HIGHER EDUCATION ECOSYSTEM. THROUGH SIGNATURE NETWORKS, STRATEGIC CONVENINGS, AND DIGITAL ENGAGEMENT TOOLS, ACE CONNECT CREATES SPACES FOR LEADERS TO SHARE EXPERTISE, STRENGTHEN RELATIONSHIPS, AND ADVANCE SOLUTIONS TO THE SECTOR'S MOST PRESSING CHALLENGES.AS THE UNIT RESPONSIBLE FOR ACE'S MAJOR CONVENINGS, ACE CONNECT LEADS THE PLANNING AND EXECUTION OF THE ACE EXPERIENCE, ACE'S FLAGSHIP EVENT SERIES WITH ITS ANNUAL MEETING AS THE FEATURED CENTERPIECE OF ENGAGEMENT. THE ACE EXPERIENCE CONVENES NEARLY 700 HIGHER EDUCATION LEADERS FOR DIALOGUE ON CRITICAL ISSUES SHAPING THE FUTURE OF THE SECTOR AND, BEYOND THE ANNUAL MEETING, FEATURES COMPONENTS SUCH AS ACE ON THE HILL, THE UNIVERSITY NETWORK SUMMIT AS A PARTNER CONFERENCE, THE ACE WOMEN'S NETWORK LEADERSHIP CONFERENCE, AND THE COUNCIL OF FELLOWS GATHERING. ALL THESE COMBINE TO ELEVATE THE ACE EXPERIENCE AS A CATALYST FOR COLLABORATION, ADVOCACY, AND INNOVATION.ACE CONNECT ALSO MANAGES THREE CORNERSTONE COMMUNITIES: -THE ACE COUNCIL OF FELLOWS (COF), REPRESENTING ALUMNI OF THE ACE FELLOWS PROGRAM, A LEADERSHIP DEVELOPMENT INITIATIVE WITH MORE THAN 2,000 GRADUATES SINCE 1965. THE COF CONVENES FELLOWS ANNUALLY AND PROVIDES ONGOING OPPORTUNITIES FOR PEER LEARNING AND ENGAGEMENT, INCLUDING A SPECIAL GATHERING DURING THE ACE EXPERIENCE 2026. -ESTABLISHED IN 1977 THE ACE WOMEN'S NETWORK, A SYSTEM OF STATE-BASED NETWORKS REACHING THOUSANDS OF WOMEN AND ALLIES ANNUALLY, DEDICATED TO DIVERSIFYING THE LEADERSHIP PIPELINE. THE WOMEN'S NETWORK LEADERSHIP CONFERENCEHELD DURING THE ACE EXPERIENCERECENTLY SURPASSED ITS REGISTRATION GOAL, UNDERSCORING THE CONTINUED DEMAND FOR GENDER-FOCUSED LEADERSHIP DEVELOPMENT. -THE COMMISSION ON FAITH-BASED COLLEGES AND UNIVERSITIES, WHICH CONVENES LEADERS FROM FAITH-BASED INSTITUTIONS TO ADDRESS SHARED CHALLENGES AND OPPORTUNITIES. IN 2025, THE COMMISSION CONVENED OVER 130 PRESIDENTS AND LEADERS. ITS THIRD ANNUAL MEETING, SCHEDULED FOR JUNE 8, 2026, WILL INTRODUCE A NEW FORUM FOR GENERAL COUNSELS TO EXPLORE LEGAL ISSUES UNIQUE TO FAITH-BASED CAMPUSES, STRENGTHENING INSTITUTIONAL RESILIENCE AND COMPLIANCE STRATEGIES.TO EXTEND THE REACH OF THESE EFFORTS, ACE CONNECT LEVERAGES ACE ENGAGE, ACE'S DIGITAL PLATFORM FOR VIRTUAL NETWORKING AND LEARNING. THROUGH WEBINARS, WORKSHOPS, AND A ROBUST RESOURCE LIBRARY, ACE ENGAGE COMPLEMENTS IN-PERSON CONVENINGS AND PUBLICATIONS SUCH AS THE RECENT WHITE PAPER, DUAL MISSION INSTITUTIONS: BRIDGING TRADITIONAL AND WORKFORCE LEARNING FOR REGIONAL IMPACT, WHICH GENERATED SIGNIFICANT ENGAGEMENT WITHIN WEEKS OF RELEASE.

	(Code: ) (Expenses $ 3,354,874 including grants of $ ) (Revenue $ 11,123,877 )
	ANNUAL MEETING AND OTHER PROGRAMS: ACE'S ANNUAL MEETING BRINGS TOGETHER HIGHER EDUCATION LEADERS FROM ALL SECTORS. THE ANNUAL MEETING IS AN EVENT TO NETWORK WITH COLLEAGUES, HEAR ABOUT EMERGING TRENDS FROM NATIONAL THOUGHT LEADERS, AND LEARN ABOUT NEW APPROACHES TO CAMPUS CHALLENGES.

	(Code: ) (Expenses $ 2,016,302 including grants of $ ) (Revenue $ )
	POLICY ANALYSIS AND RESEARCHTHE RESEARCH UNIT IS RESPONSIBLE FOR CREATING, AGGREGATING, AND DISSEMINATING KNOWLEDGE, INSIGHTS, AND DATA THAT HELP THE COUNCIL AND SECTOR IT REPRESENTS MEASURE AND ARTICULATE THEIR RESPECTIVE IMPACT. THE UNIT SERVES THESE FUNCTIONS THROUGH CONDUCTING RESEARCH THAT ESTABLISHES BENCHMARKS AND MEASURES COLLECTIVE IMPACT OF THE POSTSECONDARY SECTOR; AND THROUGH PROVIDING TIMELY ANALYSIS OF PUBLIC POLICY ISSUES. THE UNIT IS ALSO TASKED TO CONDUCT SUMMATIVE AND FORMATIVE ASSESSMENT OF THE COUNCIL'S ACTIVITIES THAT WILL INFORM ITS STRATEGIC PRIORITIES AND CATALYZE ONGOING ORGANIZATIONAL IMPROVEMENT AND IMPACT.

4d	Other program services (Describe in Schedule O.)
	(Expenses $ 9,076,255 including grants of $ 24,150 ) (Revenue $ 11,609,255 )
4e	Total program service expenses25,964,706

1b	Sub-Total..............
c	Total from continuation sheets to Part VII, Section A..
d	Total (add lines 1b and 1c).........	4,137,784	0	720,486

		Business Code
2a	MEMBERSHIP DUES	900099	7,990,616	7,990,616
b	RENTAL INCOME	900099	5,463,264	4,016,847		1,446,417
c	FEDERAL CONTRACTS	900099	4,547,914	4,547,914
d	REVIEW AND REGISTRATION FEES	900099	3,480,023	3,480,023
e	INVESTMENT IN JV	900099	-760,882	-760,882
f	All other program service revenue.		-2,181,676	-2,256,076	74,400
g	Total. Add lines 2a–2f .....		18,539,259

1	Briefly describe the organization’s mission or most significant activities: CONSENSUS LEADER ON HIGHER EDUCATION ISSUES & COORDINATING BODY FOR UNITED STATES HIGHER ED.
2	Check this box
3	Number of voting members of the governing body (Part VI, line 1a) ........	3	29
4	Number of independent voting members of the governing body (Part VI, line 1b) .....	4	29
5	Total number of individuals employed in calendar year 2024 (Part V, line 2a) ......	5	163
6	Total number of volunteers (estimate if necessary) .............	6	40
7a	Total unrelated business revenue from Part VIII, column (C), line 12 ........	7a	74,400
b	Net unrelated business taxable income from Form 990-T, Part I, line 11 .........	7b	0

1a	Federated campaigns..		1a
b	Membership dues..		1b
c	Fundraising events..		1c
d	Related organizations		1d
e	Government grants (contributions)		1e	44,666

f	All other contributions, gifts, grants, and similar amounts not included above		1f	5,984,838

g	Noncash contributions included in lines 1a - 1f:$		1g

h Total. Add lines 1a-1f.......		6,029,504

3 Investment income (including dividends, interest, and othersimilar amounts) ......			2,005,626			2,005,626
4 Income from investment of tax-exempt bond proceeds
5 Royalties...........			5,516,031			5,516,031
			(i) Real	(ii) Personal
6a	Gross rents	6a
b	Less: rental expenses	6b
c	Rental income or (loss)	6c
d	Net rental income or (loss).......
			(i) Securities	(ii) Other
7a	Gross amount from sales of assets other than inventory	7a	12,887,914
b	Less: cost or other basis and sales expenses	7b	10,786,140	9,868
c	Gain or (loss)	7c	2,101,774	-9,868
d	Net gain or (loss).........			2,091,906			2,091,906
8a	Gross income from fundraising events (not including $ of contributions reported on line 1c). See Part IV, line 18 ....
			8a
b	Less: direct expenses ...		8b
c	Net income or (loss) from fundraising events..
9a	Gross income from gaming activities. See Part IV, line 19 ...
			9a
b	Less: direct expenses ...		9b
c	Net income or (loss) from gaming activities..
10a	Gross sales of inventory, less returns and allowances ..
			10a	31,010
b	Less: cost of goods sold ..		10b	28,269
c	Net income or (loss) from sales of inventory..			2,741	2,741

Business Code
11a	GARAGE PARKING		900099	109,758			109,758
b	MISCELLANEOUS INCOME		900099	-9,666			-9,666
c
d	All other revenue ....
e	Total. Add lines 11a–11d ......			100,092
12	Total revenue. See instructions.....			34,285,159	17,021,183	74,400	11,160,072

1	Grants and other assistance to domestic organizations and domestic governments. See Part IV, line 21 ....	20,000	20,000
2	Grants and other assistance to domestic individuals. See Part IV, line 22 ...........	4,150	4,150
3	Grants and other assistance to foreign organizations, foreign governments, and foreign individuals. See Part IV, lines 15 and 16. .............
4	Benefits paid to or for members .......
5	Compensation of current officers, directors, trustees, and key employees ...........	2,721,878	1,967,736	754,142
6	Compensation not included above, to disqualified persons (as defined under section 4958(f)(1)) and persons described in section 4958(c)(3)(B) .........
7	Other salaries and wages........	14,997,568	9,934,908	4,297,322	765,338
8	Pension plan accruals and contributions (include section 401(k) and 403(b) employer contributions) ....	1,336,838	897,193	372,404	67,241
9	Other employee benefits .......	3,628,805	2,383,044	1,073,814	171,947
10	Payroll taxes ...........	1,231,079	823,948	352,617	54,514
11	Fees for services (non-employees):
a	Management ......
b	Legal .........	942,957	440,870	475,438	26,649
c	Accounting ...........	69,279		69,279
d	Lobbying ...........	150,000	150,000
e	Professional fundraising services. See Part IV, line 17
f	Investment management fees ......	85,038		85,038
g	Other (If line 11g amount exceeds 10% of line 25, column (A) amount, list line 11g expenses on Schedule O)	6,842,212	5,381,980	1,387,173	73,059
12	Advertising and promotion ....	80,938	36,969	43,527	442
13	Office expenses .......	216,550	137,180	75,353	4,017
14	Information technology ......	1,661,912	583,847	1,053,662	24,403
15	Royalties ..
16	Occupancy ...........	698,603	166,777	521,745	10,081
17	Travel ............	527,374	495,607	29,891	1,876
18	Payments of travel or entertainment expenses for any federal, state, or local public officials .
19	Conferences, conventions, and meetings ....	1,680,714	1,632,922	36,304	11,488
20	Interest ...........	66,484	178	66,295	11
21	Payments to affiliates .......
22	Depreciation, depletion, and amortization ..	2,379,982	273,302	2,100,928	5,752
23	Insurance ...	279,008	19,863	257,944	1,201
24	Other expenses. Itemize expenses not covered above (List miscellaneous expenses in line 24e. If line 24e amount exceeds 10% of line 25, column (A) amount, list line 24e expenses on Schedule O.)
a	REPAIRS & MAINTENANCE	897,275	235,090	647,975	14,210
b	TAXES	329,815	72,328	253,115	4,372
c	OTHER EXPENSES	279,094	125,223	152,322	1,549
d	DUES & PUBLICATIONS	203,716	180,386	20,344	2,986
e	All other expenses	2,638	1,205	1,419	14
25	Total functional expenses. Add lines 1 through 24e	41,333,907	25,964,706	14,128,051	1,241,150
26	Joint costs. Complete this line only if the organization reported in column (B) joint costs from a combined educational campaign and fundraising solicitation. Check here if following SOP 98-2 (ASC 958-720).

1	Cash–non-interest-bearing ........			7,734,865	1	6,166,935
2	Savings and temporary cash investments .........			6,900,881	2	4,292,274
3	Pledges and grants receivable, net ......			1,130,717	3	746,063
4	Accounts receivable, net .............			1,031,893	4	1,081,119
5	Loans and other receivables from any current or former officer, director, trustee, key employee, creator or founder, substantial contributor, or 35% controlled entity or family member of any of these persons .......
					5
6	Loans and other receivables from other disqualified persons (as defined under section 4958(f)(1)), and persons described in section 4958(c)(3)(B) ...
					6
7	Notes and loans receivable, net ...........				7
8	Inventories for sale or use ............			13,779	8	1,630
9	Prepaid expenses and deferred charges ......			1,358,677	9	1,247,045
10a	Land, buildings, and equipment: cost or other basis. Complete Part VI of Schedule D	10a	53,794,847
b	Less: accumulated depreciation	10b	40,008,051	8,011,144	10c	13,786,796
11	Investments—publicly traded securities .			59,262,390	11	60,650,469
12	Investments—other securities. See Part IV, line 11 .....			179,622	12	154,925
13	Investments—program-related. See Part IV, line 11 ..			5,560,859	13	2,443,452
14	Intangible assets ...............				14
15	Other assets. See Part IV, line 11 ...........			3,067,837	15	2,972,187
16	Total assets. Add lines 1 through 15 (must equal line 33)...			94,252,664	16	93,542,895

17	Accounts payable and accrued expenses .....	3,843,529	17	4,044,458
18	Grants payable ...		18
19	Deferred revenue .........	10,245,493	19	9,410,484
20	Tax-exempt bond liabilities .........		20
21	Escrow or custodial account liability. Complete Part IV of Schedule D		21
22	Loans and other payables to any current or former officer, director, trustee, key employee, creator or founder, substantial contributor, or 35% controlled entity or family member of any of these persons .........
			22
23	Secured mortgages and notes payable to unrelated third parties ..		23
24	Unsecured notes and loans payable to unrelated third parties ..	0	24	3,613,648
25	Other liabilities (including federal income tax, payables to related third parties, and other liabilities not included on lines 17 - 24). Complete Part X of Schedule D	4,826,339	25	5,269,400
26	Total liabilities. Add lines 17 through 25..	18,915,361	26	22,337,990

	Organizations that follow FASB ASC 958, check here and complete lines 27, 28, 32, and 33.
27	Net assets without donor restrictions ..........	68,501,531	27	65,175,314
28	Net assets with donor restrictions ...........	6,835,772	28	6,029,591
	Organizations that do not follow FASB ASC 958, check here and complete lines 29 through 33.
29	Capital stock or trust principal, or current funds .....		29
30	Paid-in or capital surplus, or land, building or equipment fund ...		30
31	Retained earnings, endowment, accumulated income, or other funds		31
32	Total net assets or fund balances ...........	75,337,303	32	71,204,905
33	Total liabilities and net assets/fund balances ........	94,252,664	33	93,542,895