The agency requests details such as the name, address and contact information of foreign funding sources.
According to Section 117 of the Higher Education Act of 1965, federally funded secondary education institutions such as Harvard University must disclose the source of contracts of more than $250,000 per year to the education sector.
In February 2020, the department notified Harvard University of the Agency’s Section 117 investigation into the university.
The Education Department has determined that Harvard University’s Section 117 reports that “all reportable gifts, contracts, and/or limited conditional gifts or contracts or contracts cannot be included from foreign sources.”
In December 2024, the department notified Harvard University of the results of the investigation. Harvard has signed an agreement to submit disclosure reports revised between 2014 and 2019. The university also stated that it has established written procedures and systems to ensure compliance with Section 117.
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In a April 17 letter to Harvard, the department said in a recent review of Section 117 disclosures from the university it discovered that the department “incomplete and inaccurate disclosures have been provided again” in violation of its December 2024 contract.
The department asked the university to re-submit relevant records to verify the “accuracy and completeness” of compliance with the disclosure requirements of Section 117.
Harvard was asked to submit a complete and accurate copy of the written procedure and system aimed at achieving Section 117 compliance.
You must submit a list of all foreign gifts, contracts and grants, as well as the identity of the parties involved in each of these transactions. The university must provide full name, address, contact information and other details regarding the foreign source.
Additionally, the department directed Harvard University to provide a list of “all visitors or temporary researchers, scholars, students and faculty members of Harvard University who are from or affiliated with foreign governments and foreigners.”
U.S. Education Secretary Linda McMahon said the record-breaking request for Harvard is the Trump administration’s “first step” to ensure that universities are not manipulated or bidded by foreign organizations that include actors who are hostile to the interests of US and American students.
“Because Harvard receives federal funding, it must be transparent about its foreign sources and its relationship with governments. Unfortunately, our review shows that Harvard is not completely transparent or complete in its disclosure.
Funding Standoff
Requests for records to Harvard have followed prime tensions in recent weeks between the Trump administration and universities over federal funding issues.
A few weeks ago, the Department of General Services, the Department of Education and the Department of Health and Human Services began reviewing the approximately $9 billion worth of federal funds offered to universities.
The three institutions then wrote letters to the university, stating the first list of reforms. “The government believes it is necessary for Harvard University’s ongoing economic relationship with the US government,” he said.
These procedures included eliminating diversity, equity and inclusion initiatives, reforming the employment and admissions process to prioritize merits over race and gender standards, and banning the use of face coverings during campus protests.
On April 11, the agency sent another letter to the university, with more requests, including screening applicants deemed “in favor of terrorism or anti-Semitism” and those deemed “hostile to American values.”
“The United States invests in Harvard University’s operations because it is valuable to a nation of academic discovery and academic excellence. But investment is not a qualification,” the letter states.
“It only makes sense if Harvard University relies on supporting federal civil rights laws and promotes the kind of environment that creates intellectual creativity and academic rigor.
“The administration’s prescriptions go beyond the power of the federal government, which violates Harvard’s initial right to amend and exceeds the statutory limits on government powers under Title VI.
“A government in power does not determine what private universities can teach, whom they can recognize and hire, and which areas of learning and research can be pursued.”
The Education Task Force on Anti-Semitism has since announced that it will freeze a $2.2 billion grant and a $60 million contract with Harvard.
According to the department, Harvard has received more than $570 million in Title IV funds from the government. Approximately 20% of the 6,700 undergraduate students received federal grants.
In 2024, the university received $686 million in federal research funding. This was “the greatest source of support for research.”
“Since the attack on Israel on October 7, 2023, Harvard’s foreign visa mob and teachers have targeted Jewish students and spew anti-Semitic hatred,” DHS said.
