AAU submitted comments urging the Education Department to withdraw its recent notice of interpretation regarding its enforcement authority with respect to an institution’s failure to adequately report under Section 117 of the Higher Education Act and instead engage in a rulemaking process. In the notice, the Department asserts it has the power to discontinue a college or university’s access to Title IV federal student aid if it deems that the institution has not adequately reported foreign gifts and contracts in accordance with Section 117. This interpretation far exceeds the department’s authority as set forth in the Higher Education Act. The letter points out that the department has for years failed to provide adequate guidance about Section 117 to colleges and universities, and has instead launched expansive, burdensome, and costly investigations into several universities which has chilled university communication with the department.