AAU joined ACE and 35 other higher education organizations to submit extensive comments to the Education Department about how it’s HEA Section 117 foreign gift and contract reporting requirements ICR “continues to exceed the disclosure reporting required under the statutory authority set out in Sec. 117.” The comments recommend that the Education Department “make changes to the proposed revised ICR to limit disclosure reporting to the requirements” under the statutory authority set out in HEA Section 117.