AAU submitted comments to the Education Department about how it’s HEA Section 117 foreign gift and contract reporting requirements ICR. The comments highlight the multiple good faith efforts the higher education community has tried to engage with the department to seek guidance and to clarify Section 117 reporting requirements. The letter notes that “unlike other federal agencies and Congress,” the Education Department “has adopted a seemingly antagonistic rather than collaborative approach to addressing these concerns,” to the detriment of the government-university partnership that has made our nation prosper and positioned the United States as a global leader in science. The comments go on to call on the department to work with our members and lawmakers to “ensure that Section 117 and other mechanisms for disclosing foreign transactions are strengthened in a way that serves our shared national security goals without compromising the ability of universities to carry out service to our nation.”