UC Comment Letters

This comment letter responds to the U.S. Department of Education's revised Information Collection Request (ICR) on Foreign Gifts and Contracts Disclosures under Section 117 of the Higher Education Act (HEA). The University of California (UC) strongly opposes the Department’s use of an emergency review process and argues that the revised reporting requirements exceed statutory requirements, impose substantial administrative burdens, and create significant privacy and confidentiality concerns. UC recommends that the Department withdraw the emergency review request, delay implementation, and limit reporting requirements to those expressly required by Section 117.