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CFR Update, June 18, 2026

 

New Resources on Uniform Guidance Revisions

Earlier this week, AAU hosted a virtual meeting for the CFR on the Office of Management and Budget’s proposed Uniform Guidance revisions. At the meeting, former Department of Defense Acting Deputy General Counsel (Acquisition & Logistics) Isaac Natter gave a presentation outlining his views on OMB’s proposal. Natter is currently serving as counsel for the Fluet law firm in their Government Contracts Practice; his slides are available here (login required).

Additionally, yesterday, EducationCounsel published a document providing an overview of the proposed revisions and answering some FAQs. The document delves into many of the same provisions that are of interest to AAU institutions.

AAU will soon circulate an outline of our comment letter to OMB. We urge members of the CFR to ask your congressional delegations to call for these revisions to be withdrawn, and to encourage local stakeholders who will also be affected by these revisions to submit comments and contact Congress. AAU has developed a set of talking points to help guide those conversations on the Hill; they are available on our members-only Uniform Guidance resources page (login required).

 

SASC Approves FY27 NDAA

Last Thursday, the Senate Armed Services Committee voted 18-9 to advance the FY27 National Defense Authorization Act (S. 4784). The bill – like the House markup – provides $1.1 trillion for the Department of Defense and $41.1 billion for Department of Energy nuclear weapons programs.

An executive summary of the bill is available here; the committee report is available here; and the bill text is available here.

Section 220 of the bill, “Codification of Department of Defense Research Security Program,” would repeal and replace older, overlapping NDAA provisions on academic research security to enshrine a permanent program in United States code. It updates prior language on information sharing and training, screening and secure collaboration, high-risk foreign entities and talent programs, and would require designation of an academic liaison at DOD as well as a chief research security officer at universities receiving more than $50 million per year in total federal research funding. AAU staff are still evaluating the potential benefits or drawbacks of Section 220 and will share further analysis with the CFR as the bill moved forward.

The Senate version of the NDAA would also prohibit DOD from implementing a blanket policy preventing service members from attending programs at eligible universities except in very narrow situations. It also includes increases for basic research and it would restore funding for University Research Initiatives. 

The Rules Committee deadline for submitting amendments to the House version of the NDAA is today at 5:00 p.m. ET. AAU will continue to analyze and closely monitor the legislation as the NDAA cycle progresses and welcomes hearing from CFR members regarding any specific concerns you might have. Please send any comments to Hanan Saab.

 

FY27 Appropriations Update

Last week, the House Rules Committee began accepting amendments to the House version of the FY27 Energy-Water bill, setting up potential floor consideration next week.

Meanwhile, CQ reported (subscription required) that appropriations markups in the Senate are in jeopardy as “Senate GOP appropriators are considering forgoing their fiscal 2027 markups and releasing partisan bills in the absence of any bipartisan agreement on spending limits.”

Sen. Mike Rounds (R-SD) told CQ that releasing the bills “could at least get information out for everybody to see what we’re thinking about.” The outlet reported that “Democratic negotiators have accused Republicans of pushing for a ‘lopsided’ arrangement that would allow for a significant boost to defense funding with inadequate funding for nondefense programs.” Meanwhile, according to CQ, Republicans “say Democrats are proposing unserious offers that insist on parity in increases for defense and nondefense programs, or higher for domestic funding.”

 

ED Announces Four New Interagency Partnerships

On Monday, the Department of Education announced four new interagency agreements, including three with the Department of Justice and one with the Department of Health and Human Services. As part of these agreements, ED will partner with DOJ on civil rights enforcement, student privacy protection, and training and advisory services, and with HHS on special education and rehabilitative services. These agreements bring the total number of interagency partnerships up to 14.

According to Politico, as part of the agreement, ED’s Office for Civil Rights “will use DOJ’s Civil Rights Division to evaluate, investigate and resolve complaints.” ED noted in its fact sheet that students and their families can continue filing civil rights complaints with ED OCR and that “ED-OCR enforcement staff remain available to answer questions regarding the status of any filed complaints.” In 2025, ED OCR – which has closed several of its regional offices as well as cut staff – resolved only 1% of pending cases; meanwhile, the DOJ’s Civil Rights Division has also experienced personnel loss.

 

Government Files Appeals in Immigration Cases

On Thursday, the government appealed a district court ruling that vacated and declared unlawful the $100,000 payment for certain H-1B visa petitions. The government also requested a stay of the district court’s order, and, in response, on Friday, Judge Leo T. Sorokin agreed to temporarily pause the effect of his order to allow the government to request an emergency stay with the 1st U.S. Circuit Court of Appeals. Please note that this suit was originally brought by a group of state attorneys general and is separate from AAU’s case, which is still awaiting a ruling by the U.S. Circuit Court of Appeals for the District of Columbia.

The government also appealed a separate federal district court ruling that had deemed unlawful four USCIS policies, including an indefinite pause on the adjudication of immigration benefits filed by individuals from 39 countries subject to the president’s travel ban. USCIS has indicated that it intends to adhere to the district court ruling pending further judicial action. It is unclear if the government will request a stay of the order in this case. 

 

State Attorneys General Challenge Executive Order on Federal Contractors and DEI

Last week, Maryland Attorney General Anthony G. Brown co-led 20 state attorneys general in filing a lawsuit challenging the FAR Council’s and federal agencies’ implementation of an executive order prohibiting federal contractors from engaging in “racially discriminatory DEI activities,” as defined in the order.

According to a press release issued by Brown’s office, “The coalition alleges that the federal agencies implementing the executive order violated the Administrative Procedure Act (APA) by failing to provide notice to the public or accept comments (as required by federal procurement law), exceeding their legal authority, and neglected to adequately explain or justify the new requirements.”  

The suit filed by the attorneys general is separate from another lawsuit challenging the EO brought by a coalition led by the National Association of Diversity Officers in Higher Education. The associations’ complaint argues that the EO violates the First Amendment and the Fifth Amendment. It also alleges that “the administration exceeded its authority by using federal contracting power to impose conditions that Congress did not authorize.”

 

AAU Advocacy Messages to Amplify

AAU encourages the CFR to amplify the following AAU messages by sharing, liking, or reposting them on personal or official social media channels or by sharing them with policymakers and staff directly:

  • Op-edin RealClearEducation by Toby Smith and Meredith Asbury clarifying AAU’s position on the DETERRENT Act and arguing that passing the bill would harm American competitiveness. Share AAU’s Twitter and LinkedIn posts to push back against misleading arguments in support of the DETERRENT Act.
  • Leading Research Universities Report article highlighting the outsized impact of international students as successful startup founders. Share AAU’s Twitter and LinkedIn posts to illustrate the value of international students and their contributions to the United States.

 

Job Announcements

Submit job announcements for inclusion in the CFR Update using this form.

 

Upcoming Events

JUNE 30 AAU & APLU MEMBER UNIVERSITY INTERN PIZZA LUNCH AND NETWORKING OPPORTUNITY; 11:30 a.m. – 1:00 p.m. ET at AAU headquarters (1200 New York Ave NW, Suite 500). This event provides an opportunity for interns working with CFR and CGA members to network with AAU and APLU staff. We encourage members to forward information about the event to students interning in their offices this summer. CFR and CGA members are also welcome to join. Interns and members should RSVP by Friday, June 26. Please contact Justin Ryan or Amanda Shaffer with any questions.

JULY 14 CFR IN-PERSON MONTHLY MEETING 1:00 p.m. - 5:00 p.m. ET; additional information will be available here.

CFR EVENT CALENDAR: Information about CFR events, including task force meetings and monthly meeting dates, can be found here.

 

ICYMI

AAU President’s Report, June 16, 2026 (login required)

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How University Research Is Contributing to the World Cup, On and Off the Pitch

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America's STEM Talent Pipelines are Under Strain, AAU President Warns Energy Researchers