AAU joined ACE, APLU, and eleven other higher education organizations to submit comments to OIRA and the Education Department about the Department’s revised proposed Information Collection Request on foreign gifts and contracts disclosure under HEA Section 117. In the letter, the organizations express concerns that the ICR “continues to clearly exceed the specific statutory authority set out in Sec. 117 by significantly expanding the disclosure reporting required under the statute.” The letter goes on to recommend that the Department adhere to the statute’s requirements for foreign gift and contract information reporting and recommends, among other things, the Department remove the requirement that “institutions produce true copies of gift, contract, and restricted or conditional gift agreements.”