To expand on previous comments on the Education Department’s notice of proposed rulemaking on “free inquiry,” AAU and ACE submitted a second set of comments regarding language in the proposed rule that would “create a nexus between private colleges’ and universities’ compliance with their institutional policies on free inquiry and expression, on one hand, and the False Claims Act, on the other.” The comments argue that by requiring private universities to certify compliance with their speech policies, the rule almost certainly would cause a dramatic increase in frivolous, disruptive, and costly False Claims Act lawsuits against private colleges and universities. The comments urge the department to remove the requirement that private institutions certify compliance with institution policies as a condition of an award and to de-link noncompliance and institutional policies on free inquiry from the False Claims Act.