Defending Ed Submits Public Comment Supporting Renewal of Foreign Gifts and Contracts Disclosures

On July 29, 2026, Defending Education (DE) submitted a comment to Federal Student Aid, U.S. Department of Education, supporting renewal of the Foreign Gifts and Contracts Disclosures information collection under Section 117 of the Higher Education Act. Section 117 requires colleges and universities to disclose foreign gifts and contracts of $250,000 or more from a single foreign source. This is one of the only tools the federal government has to bring foreign funding of American higher education into public view.

FSA is moving this collection to a new, more user-friendly portal at foreignfundinghighered.gov. DE supports this transition. The compliance burden on institutions is modest, and any changes to reporting requirements should preserve the scope Congress set in statute. DE’s comment also asks the Department to clarify how it will catch institutions that fail to file, file late, or file incomplete reports. Section 117’s enforcement mechanism is limited, which means the reporting collection itself does most of the work of keeping institutions accountable.

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