Agency Information Collection Activities; Comment Request; Foreign Gifts and Contracts Disclosures

The Council for Advancement and Support of Education (CASE) opposes the proposed requirement for colleges and universities to disclose donor names and addresses in foreign gift reports. They argue that this requirement exceeds statutory authority, violates donor confidentiality, conflicts with Executive Order 14219, and poses significant safety risks to donors and their families.

The American Council on Education and 17 other higher education associations oppose the proposed information collection request because they argue it exceeds statutory authority by requiring the public disclosure of individual donor names and imposes unconstitutional risks to donor privacy. They also express concerns regarding the new certification process for individuals, the lack of clarity and context in the new foreign funding portal, and the significant administrative burden placed on institutions.

The Council for Christian Colleges & Universities (CCCU) opposes the proposed Information Collection Request because it requires the disclosure of names and addresses for natural-person donors, which they argue exceeds the requirements of Section 117 of the Higher Education Act. They contend that this disclosure poses significant safety risks to donors in countries where they face religious persecution and request that the Department limit collection to aggregate amounts or provide safety-based accommodations.