Education Department Requests Harvard to Provide List of Foreign Funders Following Submission of Inaccurate Records

Postsecondary institutions such as Harvard that receive federal funding must disclose any foreign gifts and contracts exceeding $250,000 annually to the Education Department, as mandated by Section 117 of the Higher Education Act of 1965.

In February 2020, the department informed Harvard about an ongoing Section 117 investigation concerning the university.

The Education Department had concluded that Harvard’s reports under Section 117 “may not include and/or adequately reflect all reportable gifts, contracts, and/or restricted and conditional gifts or contracts from or with foreign sources.”

In December 2024, the department communicated the findings from the investigation to Harvard. The university agreed to submit revised disclosure reports covering the years 2014–2019 and implemented written procedures to ensure compliance with Section 117.

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In the letter dated April 17, the department indicated that a review of Harvard’s recent disclosures under Section 117 found that “incomplete and inaccurate disclosures have once again been provided” to the department, constituting a breach of the December 2024 agreement.

The department has emphasized that the university should resend relevant records to confirm the “accuracy and completeness” of its compliance with Section 117 disclosure mandates.

Harvard has been directed to furnish a comprehensive and accurate version of its written procedures and systems aimed at ensuring adherence to Section 117.

The university must also provide a complete list of all foreign gifts, contracts, and grants, detailing the identities of all parties involved in these transactions, including their full names, addresses, and contact information.

Additionally, the department has instructed Harvard to compile a list of “all visiting or temporary researchers, scholars, students, and faculty at Harvard who are affiliated with or represent foreign governments and individuals.”

U.S. Secretary of Education Linda McMahon remarked that the records request directed at Harvard represents the Trump administration’s “first step” towards ensuring that the institution is not being “influenced by, or acting on behalf of, foreign entities, including those that are opposed to the interests of the United States and American students.”

“As a recipient of federal funding, Harvard University is obliged to maintain transparency regarding its relationships with foreign sources and governments. Unfortunately, our review indicated that Harvard has not been entirely transparent or thorough in its disclosures, which is unacceptable and unlawful,” she stated.

Recent weeks have seen the General Services Administration, the Department of Education, and the Department of Health and Human Services initiating a review of approximately $9 billion in federal funding allocated to the university.

The three agencies subsequently issued a letter to Harvard, outlining initial areas of reform deemed necessary for the continuation of the university’s financial relationship with the U.S. government.

Proposed reforms included abolishing diversity, equity, and inclusion initiatives, amending hiring and admissions processes to focus on merit rather than race or gender, and prohibiting face coverings during campus protests.

On April 11, the agencies sent an additional letter to the university, presenting further demands, including revising the international admissions process to filter out applicants perceived as “supportive of terrorism or anti-Semitism” and those “hostile to American values.”

“The United States has invested substantial resources in Harvard University’s operations because of the importance of scholarly discovery and academic excellence to the nation. However, such investment is not guaranteed,” stated the letter.

“It relies on Harvard adhering to federal civil rights laws and is contingent upon the university fostering an environment that promotes intellectual creativity and academic rigor, both of which are undermined by ideological capture.”

“The administration’s requests go beyond what is within the authority of the federal government. They infringe upon Harvard’s First Amendment rights and surpass the legal limits of the government’s power under Title VI. This threatens our values as a private institution committed to the pursuit, generation, and dissemination of knowledge,” he expressed.

“No government—regardless of political affiliation—should dictate what private universities can teach, whom they can accept and hire, or what fields of study they may explore.”

In response, the Education Department’s task force on anti-Semitism revealed it was freezing $2.2 billion in grants and $60 million in contracts pertaining to Harvard.

According to the department, Harvard has received over $570 million in Title IV funding from the government, with approximately 20 percent of its 6,700 undergraduate students benefiting from federal Pell Grants.

In fiscal year 2024, the university garnered $686 million in federal research funding, its “largest source of support for research.”

“Since Hamas’s October 7, 2023, assault on Israel, Harvard’s foreign visa-holding protesters and faculty have propagated antisemitic rhetoric, targeting Jewish students,” the DHS asserted.