By Meredith Asbury and Kritika Agarwal
When the Education Department announced a partnership with the State Department earlier this year to track foreign gifts and contracts reported by colleges and universities, it accused “many large and well-resourced institutions of higher education” in the United States of aggressively pursuing and accepting foreign money while failing to comply with federal disclosure requirements.
Similarly, last year, when President Trump issued an executive order on “Transparency Regarding Foreign Influence at American Universities,” he asserted that legal requirements for universities to report foreign gifts and contracts have “not been robustly enforced” and that the “true amounts, sources, and purposes of foreign money flowing to American campuses are unknown.”
These characterizations, however, are at odds with how universities actually conduct themselves when it comes to accepting and reporting foreign gifts and contracts. In reality, institutions of higher education do not casually or indiscriminately take foreign money. Instead, they operate under a long-standing federal disclosure law – Section 117 of the Higher Education Act – that requires them to disclose foreign gifts and contracts to the federal government. Contrary to the administration’s characterizations, in recent years, universities have built robust internal systems to track and accurately report foreign funding to ensure that they comply with Section 117.
Indeed, the Department of Education recently took the Section 117 data that institutions have been reporting and used it to create an interactive dashboard that the public can use to examine foreign sources of university funding. Unfortunately, despite the agency’s laudable efforts to make the data more accessible and transparent, flaws in how the dashboard is set up risks misleading the public as well as lawmakers about the true nature and extent of university foreign funding.
What Is Section 117
Enacted in 1986, Section 117 of the Higher Education Act requires U.S. colleges and universities that participate in federal student aid programs to report foreign gifts and contracts from any foreign source that total at least $250,000 dollars in a calendar year. Institutions must file these reports twice a year, and the law directs the Department of Education to make the disclosures available for public inspection.
For many years, Section 117 compliance was uneven, both on campuses and at the Department of Education. Until federal concerns about foreign influence surged in 2018-19, many institutions struggled to interpret vague requirements, and some failed to disclose all of their reportable foreign gifts and contracts.
The department, for its part, offered only limited guidance in a pair of “Dear Colleague” letters (issued in 1995 and 2004) and did little to actively enforce the law or to make the data publicly accessible. (In fact, despite the enactment of Section 117 nearly 40 years ago, the Department of Education has yet to engage in a formal rulemaking process concerning the provision. Further, the department did not put into place a system to ensure that the “public has ready and meaningful access to this information” reported by institutions until 2020.)
In 2019, AAU and other higher education associations formally asked the department to clarify compliance requirements and institutions began overhauling their internal reporting procedures. Since then, the department has increased efforts to provide guidance to institutions, and universities have made significant strides to improve their reporting under Section 117 by building stronger systems to identify, review, and report their foreign funding.
Campuses now routinely coordinate among research, development, and alumni offices; various campus colleges and departments; their finance and administrative departments; and general counsels to identify, value, and report foreign gifts and contracts above the statutory threshold.
Why Do Universities Accept Foreign Gifts and Contracts
Universities accept foreign gifts and contracts for the same reasons they accept philanthropy and research funding from American sources: to support education, research, and international collaboration.
Among other things, universities may accept gifts from international alumni or engage in contracts that support joint international research projects, joint clinical trials with institutions in other nations (China surpassed the United States in holding the largest number of clinical trials in 2024), faculty and student exchange programs, endowed professorships, and international branch campuses.
These activities can advance scientific discovery, expand educational opportunities for American students, and strengthen America’s own research capacity by connecting U.S. scholars with leading scientists and institutions abroad. In many cases, foreign gifts help launch collaborations or programs that otherwise would not exist. Universities also operate under other federal rules – such as export controls and agency‑specific disclosure requirements – that further guard against improper foreign influence.
Where the New Section 117 Dashboard Misleads
The Department of Education’s new public dashboard is intended to make Section 117 data more accessible, and is based on a new reporting portal that makes it easier for universities to upload and correct data – something that associations and institutions had asked for many times over the years.
However, several design choices used in the dashboard still risk giving the public a distorted picture of current campus activity. (Users can download data going back to September 2020 and examine the spreadsheets directly; however, it is safe to assume that the vast majority of the public as well as lawmakers will only ever interact with the visual dashboard.) Specific problems that continue to persist even with recent improvements include:
The dashboard presents cumulative data that is not time-stamped – The dashboard cumulatively presents all data on foreign gifts and contracts ever reported by universities to the Department of Education, but does not allow users to filter the data by date or to see when universities actually received foreign funds.
In its press release, for example, the department noted that U.S. colleges and universities reported $5.2 billion in foreign gifts and contracts in 2025. This information from 2025, however, can be gleaned solely from the department’s press release and not from the dashboard itself.
Because the data is not time-stamped, there is no way for a casual user to distinguish between funding that ended years ago or funding that is ongoing.For example, the dashboard indicates that the Massachusetts Institute of Technology has received substantial funds from Russia. However, it is impossible to know from looking at the dashboard that these funds were for an 11-year partnership MIT had with the Russian Skolkovo Institute of Science and Technology and that MIT ended the partnership in February 2022 in response to Russia’s invasion of Ukraine.
- The dashboard does not allow users to examine individual gifts and contracts – As indicated in the MIT example above, since users cannot actually drill down to see the details of the individual gifts and contracts in the dashboard, there is no way for them to determine if the gifts and contracts are actually problematic.
In another example, the Department of Education announced that, in 2025, Carnegie Mellon University received the most foreign funds (almost $1 billion) and that its biggest source of funding was Qatar.
In a statement to Inside Higher Ed, however, Carnegie Mellon clarified that the funds are nearly entirely spent on its Qatar campus. “More than 90% of those funds are spent in Qatar to operate the campus there. Since CMU-Q opened its doors in 2004, more than 1,400 people from around the world have received a Carnegie Mellon education that would otherwise be inaccessible to them,” a university spokesperson noted. Again, this important contextual information cannot easily be obtained via the dashboard.
The dashboard misrepresents universities’ relationships with foreign entities of concern – One section of the dashboard allows users to see which foreign entities on U.S. government lists have engaged with U.S. universities. However, these government lists are not static – entities come on and off them all the time and universities frequently use these lists to stay in compliance.
However, again, because of lack of time stamps or contextualizing information, it is easy for users to look at the dashboard and assume that institutions are receiving ongoing funding from problematic entities even if institutions actually ended those relationships many years ago.
For example, the dashboard ranks China’s Huawei Technologies number four on its list of entities of concern from which universities received foreign funding. What the dashboard fails to convey is that Huawei was placed on the Department of Commerce Entity List in May 2019, thus greatly restricting U.S. university transactions with the company from that moment on.
In response to Huawei being added to this list, U.S. universities terminated existing research contracts with the company and declined renewals. Additionally, the FY19 National Defense Authorization Act prohibited the Department of Defense from contracting with entities that use Huawei equipment as a “substantial or essential component” of its systems, further weakening university incentives for collaboration with Huawei. The Section 117 dashboard fails to communicate these important details.
The Real Picture of Foreign Funding on University Campuses
It is easy to see how the dashboard can lead lawmakers and American taxpayers to inaccurately believe that universities have been quietly taking large sums of foreign money for improper purposes as it fails to provide critical context for certain data and charts related to the foreign gifts received by universities. Indeed, universities have greatly stepped up their efforts to comply with Section 117 – which previously lacked attention and enforcement from the Department of Education – and to mitigate concerns about foreign influence and associated risks more broadly.
The new dashboard, while a step toward greater transparency, still fails to provide the necessary context for the public and policymakers to accurately interpret the numbers and responsibly assess their meaning. Without that context, the dashboard can exaggerate risk, conflate past and present relationships, and reinforce the misconception that universities are taking foreign money casually or covertly when, in fact, the reality is that universities’ acceptance of foreign funds is structured, regulated, and subject to rigorous oversight.
Meredith Asbury is associate vice president for government relations and public policy; Kritika Agarwal is assistant vice president for communications at AAU.