AAU, along with ACE and 18 other higher education associations, submitted comments and a listing of twelve technical questions in response to a Department of Education Information Collection Request (ICR) on the Higher Education Act Section 117 foreign gifts and contracts reporting requirement. The comments identify several positive elements within the ICR, but also highlight a number of areas where the Department of Education appears to exceed its statutory authority or where confusion remains. The comments also identify continuing issues with the reporting portal and argue that the department has significantly underestimated the hour and cost burden from the information collection.