SCHEDULE E 

(Form 990 or 990-EZ)

Department of the Treasury 

Internal Revenue Service

Schools

▶ Complete if the organization answered “Yes” on Form 990, 

Part IV, line 13, or Form 990-EZ, Part VI, line 48.

▶ Attach to Form 990 or Form 990-EZ.

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

OMB No. 1545-0047

2019

Open to Public 

Inspection

Name of the organization Employer identification number

Part I

YES NO

1 Does the organization have a racially nondiscriminatory policy toward students by statement in its charter, 

bylaws, other governing instrument, or in a resolution of its governing body? . . . . . . . . . . 1

2 Does the organization include a statement of its racially nondiscriminatory policy toward students in all its 

brochures, catalogues, and other written communications with the public dealing with student admissions, 

programs, and scholarships? . . . . . . . . . . . . . . . . . . . . . . . . . . 2

3 Has the organization publicized its racially nondiscriminatory policy through newspaper or broadcast media 

during the period of solicitation for students, or during the registration period if it has no solicitation program, 

in a way that makes the policy known to all parts of the general community it serves? If “Yes,” please

describe. If “No,” please explain. If you need more space, use Part II . . . . . . . . . . . . . 3

4 Does the organization maintain the following?

a Records indicating the racial composition of the student body, faculty, and administrative staff? . . . . 4a

b Records documenting that scholarships and other financial assistance are awarded on a racially 

nondiscriminatory basis? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4b

c Copies of all catalogues, brochures, announcements, and other written communications to the public dealing 

with student admissions, programs, and scholarships? . . . . . . . . . . . . . . . . . . 4c

d Copies of all material used by the organization or on its behalf to solicit contributions? . . . . . . . 4d

If you answered “No” to any of the above, please explain. If you need more space, use Part II.

5 Does the organization discriminate by race in any way with respect to:

a Students’ rights or privileges? . . . . . . . . . . . . . . . . . . . . . . . . . . 5a

b Admissions policies? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5b

c Employment of faculty or administrative staff? . . . . . . . . . . . . . . . . . . . . . 5c

d Scholarships or other financial assistance? . . . . . . . . . . . . . . . . . . . . . . 5d

e Educational policies? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5e

f Use of facilities? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5f

g Athletic programs? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5g

h Other extracurricular activities? . . . . . . . . . . . . . . . . . . . . . . . . . 5h

If you answered “Yes” to any of the above, please explain. If you need more space, use Part II.

6a Does the organization receive any financial aid or assistance from a governmental agency? . . . . . . 6a

b Has the organization’s right to such aid ever been revoked or suspended? . . . . . . . . . . . 6b

If you answered “Yes” on either line 6a or line 6b, explain on Part II.

7 Does the organization certify that it has complied with the applicable requirements of sections 4.01 through

4.05 of Rev. Proc. 75-50, 1975-2 C.B. 587, covering racial nondiscrimination? If “No,” explain on Part II . . 7

For Paperwork Reduction Act Notice, see the Instructions for Form 990 or Form 990-EZ. Cat. No. 50085D Schedule E (Form 990 or 990-EZ) 2019
Schedule E (Form 990 or 990-EZ) 2019 Page 2

Part II Supplemental Information. Provide the explanations required by Part I, lines 3, 4d, 5h, 6b, and 7, as 

applicable. Also provide any other additional information. See instructions.

Schedule E (Form 990 or 990-EZ) 2019 
Schedule E (Form 990 or 990-EZ) 2019 Page 3

General Instructions

Future developments. For the latest information about developments 

related to Schedule E (Form 990 or 990-EZ), such as legislation enacted 

after the schedule and its instructions were published, go to 

www.irs.gov/Form990.

What’s New

Rev. Proc. 2019-22, 2019-22 I.R.B. 1260, modified Rev. Proc. 75-50 to 

provide a third method for a private school to satisfy the publicity 

requirement in Section 4.03. Accordingly, also answer “Yes” to line 3 if 

the organization has publicized its racially nondiscriminatory policy on 

its primary publicly accessible Internet homepage at all times during its 

tax year in a manner reasonably expected to be noticed by visitors to 

the homepage.

Purpose of Schedule

Schedule E (Form 990 or 990-EZ) is used by an organization that files 

Form 990 or Form 990-EZ to report information on private schools.

Who Must File

An organization that answered “Yes” on Form 990, Part IV, line 13, or 

Form 990-EZ, Part VI, line 48, must complete and attach Schedule E to 

Form 990 or Form 990-EZ, as applicable. This means the organization 

checked the box on Schedule A (Form 990 or 990-EZ), Public Charity 

Status and Public Support, Part I, line 2, because it’s a school.

If an organization isn’t required to file Form 990 or Form 990-EZ but 

chooses to do so, it must file a complete return and provide all of the 

information requested, including the required schedules.

For Form 990 and Form 990-EZ filers, use Part II if additional space is 

needed for explanations. 

Specific Instructions

Part I

Relevant parts of Rev. Proc. 75-50, 1975-2 C.B. 587, are given below. 

The revenue procedure gives guidelines and recordkeeping 

requirements for determining whether private schools that are 

recognized as exempt from tax have racially nondiscriminatory policies 

toward their students.

Rev. Proc. 2019-22, 2019-22 I.R.B. 1260, modified Rev. Proc. 75-50 

to provide a third method for a private school to satisfy the requirement 

in Section 4.03.

4.01 Organizational requirements. A school must include a statement 

in its charter, bylaws, or other governing instrument, or in a resolution of 

its governing body, that it has a racially nondiscriminatory policy as to 

students and therefore doesn’t discriminate against applicants and

students on the basis of race, color, and national or ethnic origin.

4.02 Statement of policy. Every school must include a statement of its 

racially nondiscriminatory policy as to students in all its brochures and 

catalogues dealing with student admissions, programs, and 

scholarships. A statement substantially similar to the Notice described 

in paragraph (a), subsection 1, section 4.03, below, will be acceptable 

for this purpose. Further, every school must include a reference to its 

racially nondiscriminatory policy in other written advertising that it uses 

as a means of informing prospective students of its programs. The 

following references will be acceptable.

The (name) school admits students of any race, color, and national or 

ethnic origin.

4.03 Publicity. The school must make its racially nondiscriminatory 

policy known to all segments of the general community served by the 

school.

1. The school must use one of the following three methods to satisfy 

this requirement.

a. The school may publish a notice of its racially nondiscriminatory 

policy in a newspaper of general circulation that serves all racial 

segments of the community. This publication must be repeated at least 

once annually during the period of the school’s solicitation for students 

or, in the absence of a solicitation program, during the school’s 

registration period. Where more than one community is served by a 

school, the school may publish its notice in those newspapers that are 

reasonably likely to be read by all racial segments of the communities

that it serves. The notice must appear in a section of the newspaper 

likely to be read by prospective students and their families and it must 

occupy at least three column inches. It must be captioned in at least 12-

point boldface type as a notice of nondiscriminatory policy as to 

students, and its text must be printed in at least 8-point type. The 

following notice will be acceptable.

Notice of Nondiscriminatory Policy as to Students

The (name) school admits students of any race, color, national and 

ethnic origin to all the rights, privileges, programs, and activities 

generally accorded or made available to students at the school. It 

does not discriminate on the basis of race, color, national and ethnic 

origin in administration of its educational policies, admissions policies, 

scholarship and loan programs, and athletic and other schooladministered programs.

b. The school may use the broadcast media to publicize its racially 

nondiscriminatory policy if this use makes such nondiscriminatory policy 

known to all segments of the general community the school serves. If 

this method is chosen, the school must provide documentation that the 

means by which this policy was communicated to all segments of the 

general community was reasonably expected to be effective. In this 

case, appropriate documentation would include copies of the tapes or 

script used and records showing that there was an adequate number of 

announcements, that they were made during hours when the 

announcements were likely to be communicated to all segments of the 

general community, that they were of sufficient duration to convey the 

message clearly, and that they were broadcast on radio or television 

stations likely to be listened to by substantial numbers of members of all 

racial segments of the general community. Announcements must be 

made during the period of the school’s solicitation for students or, in the 

absence of a solicitation program, during the school’s registration 

period.

c. The school may display a notice of its racially nondiscriminatory 

policy on its primary publicly accessible Internet homepage at all times 

during its tax year (excluding temporary outages due to website 

maintenance or technical problems) in a manner reasonably expected to 

be noticed by visitors to the homepage. The notice used to satisfy the 

publicity requirement under 1(a), above, is acceptable. A publicly 

accessible homepage is one that does not require a visitor to input 

information, such as an email address or a username and password, to 

access the homepage. Factors to be considered in determining whether 

a notice is reasonably expected to be noticed by visitors to the 

homepage include the size, color, and graphic treatment of the notice in 

relation to other parts of the homepage, whether the notice is 

unavoidable, whether other parts of the homepage distract attention 

from the notice, and whether the notice is visible without a visitor having 

to do anything other than simple scrolling on the homepage. A link on 

the homepage to another page where the notice appears, or a notice 

that appears in a carousel or only by selecting a dropdown or by hover 

(mouseover) is not acceptable. If a school does not have its own 

website, but it has webpages contained in a website, the school must 

display a notice of its racially nondiscriminatory policy on its primary 

landing page within the website in a manner that satisfies all other 

requirements of this subsection 1(c) to use this publication method.

Communication of a racially nondiscriminatory policy as to students 

by a school to leaders of racial groups as the sole means of publicity 

generally won’t be considered effective to make the policy known to all 

segments of the community.

2. The requirements of subsection 1, section 4.03, won’t apply when 

one of the following paragraphs applies.

a. If, for the preceding 3 years, the enrollment of a parochial or other 

church-related school consists of students at least 75% of whom are 

members of the sponsoring religious denomination or unit, the school 

may make known its racially nondiscriminatory policy in whatever 

newspapers or circulars the religious denomination or unit utilizes in the 

communities from which the students are drawn. These newspapers 

and circulars may be those distributed by a particular religious 

denomination or unit or by an association that represents a number of 

religious organizations of the same denomination. If, however, the 

school advertises in newspapers of general circulation in the community 

or communities from which its students are drawn and paragraphs (b) 

and (c) of this subsection aren’t applicable to it, then it must comply 

with paragraph (a), subsection 1, section 4.03.
Schedule E (Form 990 or 990-EZ) 2019 Page 4

 b. If a school customarily draws a substantial percentage of its 

students nationwide, worldwide, or from a large geographic section or 

sections of the United States and follows a racially nondiscriminatory 

policy as to students, the publicity requirement may be satisfied by 

complying with section 4.02, earlier. Such a school may demonstrate 

that it follows a racially nondiscriminatory policy within the meaning of 

the preceding sentence either by showing that it currently enrolls 

students of racial minority groups in meaningful numbers or, when 

minority students are not enrolled in meaningful numbers, that its 

promotional activities and recruiting efforts in each geographic area 

were reasonably designed to inform students of all racial segments in 

the general communities within the area of the availability of the school. 

The question whether a school satisfies the preceding sentence will be 

determined on the basis of the facts and circumstances of each case.

c. If a school customarily draws its students from local communities 

and follows a racially nondiscriminatory policy as to students, the 

publicity requirement may be satisfied by complying with section 4.02,

earlier. Such a school may demonstrate that it follows a racially 

nondiscriminatory policy within the meaning of the preceding sentence 

by showing that it currently enrolls students of racial minority groups in 

meaningful numbers. The question whether a school satisfies the 

preceding sentence will be determined on the basis of the facts and 

circumstances of each case. One of the facts and circumstances that 

the IRS will consider is whether the school’s promotional activities and 

recruiting efforts in each area were reasonably designed to inform 

students of all racial segments in the general communities within the 

area of the availability of the school. The IRS recognizes that the failure 

by a school drawing its students from local communities to enroll racial 

minority group students may not necessarily indicate the absence of a 

racially nondiscriminatory policy as to students when there are relatively 

few or no such students in these communities. Actual enrollment is, 

however, a meaningful indication of a racially nondiscriminatory policy in 

a community in which a public school or schools became subject to a 

desegregation order of a federal court or otherwise expressly became 

obligated to implement a desegregation plan under the terms of any 

written contract or other commitment to which any federal agency was a 

party.

The IRS encourages schools to satisfy the publicity requirement by 

the methods described in subsection 1, section 4.03, regardless of 

whether a school considers itself within subsection 2, because it 

believes these methods to be the most effective to make known a 

school’s racially nondiscriminatory policy. It’s each school’s 

responsibility to determine whether paragraph (a), (b), or (c), subsection 

2, applies to it. On audit, a school must be prepared to demonstrate that 

the failure to publish its racially nondiscriminatory policy in accordance 

with subsection 1, section 4.03, was justified by the application to it of 

paragraph (a), (b), or (c), subsection 2. Further, a school must be 

prepared to demonstrate that it has publicly disavowed or repudiated 

any statements purported to have been made on its behalf (after 

November 6, 1975) that are contrary to its publicity of a racially 

nondiscriminatory policy as to students, to the extent that the school or 

its principal official were aware of such statements.

4.04 Facilities and programs. A school must be able to show that all of 

its programs and facilities are operated in a racially nondiscriminatory 

manner.

4.05 Scholarship and loan programs. As a general rule, all scholarship 

or other comparable benefits available for use at any school must be 

offered on a racially nondiscriminatory basis. Their availability on this 

basis must be known throughout the general community being served 

by the school and should be referred to in the publicity required by this 

section in order for that school to be considered racially 

nondiscriminatory as to students. Scholarships and loans that are made 

pursuant to financial assistance programs favoring members of one or 

more racial minority groups that are designed to promote a school’s 

racially nondiscriminatory policy won’t adversely affect the school’s 

exempt status.

Financial assistance programs favoring members of one or more 

racial groups that don’t significantly derogate from the school’s racially 

nondiscriminatory policy similarly won’t adversely affect the school’s 

exempt status.

4.06 Certification. An individual authorized to take official action on 

behalf of a school that claims to be racially nondiscriminatory as to 

students is required to certify annually, under penalties of perjury, that to 

the best of his or her knowledge and belief the school has satisfied the

applicable requirements of sections 4.01 through 4.05, Rev. Proc. 

75-50. This certification is line 7, Schedule E.

4.07 Faculty and staff. The existence of a racially discriminatory policy 

for employment of faculty and administrative staff is indicative of a 

racially discriminatory policy as to students. On the other hand, the 

absence of racial discrimination in employment of faculty and

administrative staff is indicative of a racially nondiscriminatory policy as 

to students.

7.01 Specific records. Except as provided in section 7.03, each exempt 

private school must maintain for a minimum period of 3 years, beginning 

with the year after the year of compilation or acquisition, the following 

records for the use of the IRS on proper request.

1. Records indicating the racial composition of the student body, 

faculty, and administrative staff for each academic year.

2. Records sufficient to document that scholarship and other financial 

assistance is awarded on a racially nondiscriminatory basis.

3. Copies of all brochures, catalogues, and advertising dealing with 

student admissions, programs, and scholarships. Schools advertising 

nationally or in a large geographic segment or segments of the United 

States need only maintain a record sufficient to indicate when and in 

which publications their advertisements were placed.

4. Copies of all materials used by or on behalf of the school to solicit 

contributions.

7.02 Limitation.

1. For purposes of section 7.01, the racial composition of the student 

body, faculty, and administrative staff may be an estimate based on the 

best information readily available to the school, without requiring 

student applicants, students, faculty, or administrative staff to submit 

information to the school that the school otherwise doesn’t require. For 

each academic year, however, a record of the method by which racial 

composition is determined must be maintained.

2. The IRS doesn’t require that a school release personally identifiable 

records or personal information contained therein except in accordance 

with the requirements of the Family Educational Rights and Privacy Act 

of 1974, 20 U.S.C. section 1232(g) (1974). Similarly, the IRS doesn’t 

require a school to keep records the maintenance of which is prohibited 

under state or federal law.

7.03 Exceptions. The records described in section 7.01 need not be 

independently maintained for IRS use if:

1. Substantially the same information that each of these records 

would provide has been included in a report or reports filed in 

accordance with law with an agency or agencies of federal, state, or 

local government, and this information is current within 1 year; and

2. The school maintains copies of these reports from which this 

information is readily obtainable. Records described in section 7.01 

providing information not included in reports filed with an agency or 

agencies must be maintained by the school for IRS use.

7.04 Failure to maintain records. Failure to maintain or to produce, 

upon the proper request, the required records and information will 

create a presumption that the organization has failed to comply with 

these guidelines.

Part II. Supplemental Information

Use Part II to provide the narrative explanations required, if applicable, 

to supplement responses to Part I, lines 3, 4d, 5h, 6b, and 7. Part II may 

also be used to supplement other responses to questions on Schedule 

E (Form 990 or 990-EZ). In Part II, identify the specific line number that 

each response supports, in the order in which those lines appear on 

Schedule E (Form 990 or 990-EZ). Part II can be duplicated if more 

space is needed.