April 21, 2025 - Last Friday, the U.S. Department of the Education released the following:

The U.S. Department of Education (ED) sent a records request to Harvard University after a review of the university’s foreign reports revealed incomplete and inaccurate disclosures. Pursuant to Section 117 of the Higher Education Act of 1965 (20 U.S.C. § 1011f), postsecondary institutions receiving federal financial assistance must disclose foreign source gifts and contracts with a value of $250,000 or more annually to ED. 

“As a recipient of federal funding, Harvard University must be transparent about its relations with foreign sources and governments. Unfortunately, our review indicated that Harvard has not been fully transparent or complete in its disclosures, which is both unacceptable and unlawful,” said U.S. Secretary of Education Linda McMahon. “This records request is the Trump Administration’s first step to ensure Harvard is not being manipulated by, or doing the bidding of, foreign entities, which include actors who are hostile to the interests of the United States and American students. We hope Harvard will respect its own motto and be truthful in its federal filings and foreign relationships.” 

To verify Harvard’s complete and accurate compliance with the law, and the conditions of Harvard’s December 2024 Agreement with the Department, ED requests that Harvard produce the following within thirty (30) calendar days: 

• A complete and accurate copy of Harvard's procedures to achieve compliance with Section 117;
• A list of all foreign gifts, grants, and contracts from or with foreign sources and Harvard; 
• The identities of all known parties involved in each of Harvard’s foreign source gifts; 
• All records regarding or referencing gifts and/or contracts between Harvard and foreign governments, without limitation; 
• All records relating to expelled foreign students or foreign students who have had their Harvard credentials canceled from January 1, 2016 through the present; 
• A list of any electronic mail usernames known by Harvard or its personnel to have been utilized by above listed foreign students; 
• A list of all Harvard personnel with responsibilities relating to the facilitation of the expulsion of foreign students or foreign students who have had their Harvard credentials canceled from January 1, 2016 through the present; 
• A list identifying all full or partial funding sources and amounts for any research conducted by foreign expelled students; 
• A list of all visiting or temporary researchers, scholars, students, and faculty at Harvard who are from or affiliated with foreign governments. 

Background 

Under Section 117 of the Higher Education Act of 1965 (20 U.S.C. §1011f), U.S. colleges and universities receiving federal financial aid must disclose gifts, contracts, or restricted agreements from foreign sources valued at $250,000 or more annually. This provision, added through amendments to the HEA in 1986, ensures transparency by requiring semiannual reports to the U.S. Department of Education, submitted by January 31 and July 31. Institutions subject to the provisions — those offering bachelor’s degrees or higher, or specific transfer programs — must also report any foreign ownership or substantial control. The law is intended to protect national security and academic integrity by monitoring foreign influence in higher education. Noncompliance risks Department of Justice enforcement, including civil actions, or loss of federal funding eligibility. 

The first Trump Administration discovered widespread reporting failures, which it documented in an October 2020 report which revealed that America’s universities “are technological treasure troves where leading and internationally competitive fields...are booming.” The report found that universities it had investigated, pursuant to Sec. 117’s statutory disclosure requirements, had “provided an unprecedented level of access to foreign governments and their instrumentalities” and, while doing so, had failed to report more than $6.5 billion in foreign gifts and contracts, as required by law.
Source: U.S. Dept.of ED.