Postsecondary institutions receiving federal funding assistance, such as Harvard, are required to disclose the source of foreign gifts and contracts valued at $250,000 or more annually to the Education Department, according to Section 117 of the Higher Education Act of 1965.
In February 2020, the department notified Harvard about the agency’s Section 117 investigation of the university.
The Department of Education had determined that Harvard’s Section 117 reporting “may not include and/or fully capture all reportable gifts, contracts, and/or restricted and conditional gifts or contracts from or with foreign sources.”
In December 2024, the department notified Harvard of the results of the investigation. Harvard signed an agreement that it would submit amended disclosure reports for 2014–2019. The university also stated that it established written procedures and systems to ensure compliance with Section 117.
In the April 17 letter to Harvard, the department said a review of the recent Section 117 disclosures from the university found that “incomplete and inaccurate disclosures have once again been provided” to the department, in violation of the December 2024 agreement.
The department asked the university to submit relevant records again to verify the “accuracy and completeness” of the institution’s compliance with those requirements.
Harvard must submit a list of all foreign gifts, contracts, and grants, as well as the identities of parties involved in each of these transactions. The university is required to provide full names, addresses, contact information, and other details on the foreign sources.
The department instructed Harvard to provide a list of “all visiting or temporary researchers, scholars, students, and faculty at Harvard who are from or affiliated with foreign governments and foreign individuals.”
Secretary of Education Linda McMahon said the records request to Harvard is the Trump administration’s “first step” to ensure that the university is not being “manipulated by, or doing the bidding of, foreign entities, which include actors who are hostile to the interests of the United States and American students.”
“As a recipient of federal funding, Harvard University must be transparent about its relations with foreign sources and governments. Unfortunately, our review indicated that Harvard has not been fully transparent or complete in its disclosures, which is both unacceptable and unlawful,” she said.
Funding Standoff
The records request to Harvard follows simmering tensions between the Trump administration and the university in recent weeks over the issue of federal funding.On March 31, the General Services Administration, the Department of Education, and the Department of Health and Human Services launched a review of roughly $9 billion worth of federal funding provided to the university.
The three agencies then sent a letter to the university, giving an initial list of areas of reform “that the government views as necessary for Harvard University’s continued financial relationship with the United States government.”
These steps included the elimination of diversity, equity, and inclusion initiatives, reforming hiring and admission processes to prioritize merit over race or gender criteria, and banning the use of face coverings during campus protests.
On April 11, the agencies sent another letter to the university with more demands, including overhauling the international admissions process to screen out applicants deemed to be “supportive of terrorism or anti-Semitism” and “hostile to American values.”
“The United States has invested in Harvard University’s operations because of the value to the country of scholarly discovery and academic excellence. But an investment is not an entitlement,” the letter reads.
“It depends on Harvard upholding federal civil rights laws, and it only makes sense if Harvard fosters the kind of environment that produces intellectual creativity and scholarly rigor, both of which are antithetical to ideological capture.”
“The administration’s prescription goes beyond the power of the federal government. It violates Harvard’s First Amendment rights and exceeds the statutory limits of the government’s authority under Title VI. And it threatens our values as a private institution devoted to the pursuit, production, and dissemination of knowledge,” the message reads.
“No government—regardless of which party is in power—should dictate what private universities can teach, whom they can admit and hire, and which areas of study and inquiry they can pursue.”
Subsequently, the Education Department’s task force on anti-Semitism announced that it was freezing $2.2 billion in grants and $60 million in contracts to Harvard.
According to the department, Harvard has received more than $570 million in Title IV funding from the government. Roughly 20 percent of its 6,700 undergraduate students receive federal Pell Grants.
In fiscal year 2024, the university received $686 million in federal research funding, which was its “largest source of support for research.”
“Since Hamas’s October 7, 2023, attack on Israel, Harvard’s foreign visa-holding rioters and faculty have spewed antisemitic hate, targeting Jewish students,” the DHS stated.
