COGR Submits Comments to Dept. of Education on Section 117 Reporting

COGR, representing major research universities and affiliated institutions, submitted feedback on the Department of Education's proposed changes to foreign gift and contract disclosure requirements. While supporting the goals of transparency and avoiding undue foreign influence, COGR expresses concerns that the proposed information collection process—especially the posting of full contract documents—could expose proprietary and sensitive information, create significant administrative burdens, and potentially hinder research collaboration and tech transfer without enhancing national security. They urge the Department to clarify inconsistent guidance, reduce administrative burden through improved electronic systems, consult more widely with higher education stakeholders, and consider alternative compliance mechanisms, such as incorporating reporting reviews into existing audit processes.