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.
This comment letter responds to the U.S. Department of Education’s proposed information collection requirements for reporting foreign gifts and contracts under Section 117 of the Higher Education Act. UC supports transparency regarding foreign relationships but argues that the proposed requirements exceed the statute, impose substantial administrative burdens, and raise privacy and confidentiality concerns, particularly regarding submission of complete agreements, information about individual donors, and reporting of foreign-affiliated entities.
This comment letter responds to the Department of Education’s proposed rule conditioning certain federal funding on public universities’ compliance with First Amendment requirements and their treatment of religious student organizations. UC argues that the rule could unfairly jeopardize federal funding based on unrelated litigation, increase legal and administrative burdens, and conflict with Supreme Court precedent and institutional and state nondiscrimination requirements.
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.
This comment letter responds to the U.S. Department of Education's proposed information collection requirements for implementing Section 117 of the Higher Education Act (HEA) regarding disclosure of foreign gifts and contracts. The University of California (UC) supports transparency in foreign relationships but expresses concern that the proposed requirements substantially exceed the statutory requirements of Section 117, impose significant administrative and compliance burdens, raise privacy and confidentiality concerns, and introduce unclear reporting obligations. UC recommends scaling back the proposal, clarifying key definitions, protecting confidential information, maintaining the existing reporting threshold, and pursuing implementation through a more robust rulemaking and stakeholder engagement process.
