UC Comment Letters

This comment letter responds to the Education Department (ED)'s request for comments on the collection of information required under Section 117 of the Higher Education Act (HEA)(20 §U.S.C. 1011f), as published in the Federal Register on December 27, 2022. UC is concerned that ED significantly underestimates the burden of HEA Section 117 foreign gift and contract reporting, noting that the PEBC portal’s manual-entry process is cumbersome, repetitive, and far more time-consuming than the agency’s estimate. UC recommends allowing single-file uploads, reducing repetitive screens and manual data entry, auto-populating institutional fields, improving review and correction features, expanding institutional access to submitted data, and aligning login requirements with the six-month reporting cycle.