NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS (NACUBO)

Support for including Section 214, H.R. 3838, and Section 220C, S. 2296 Extension of limitation on availability of funds for fundamental research collaboration with certain academic institutions". Support for including Section 226, S. 2296 Prohibition on modification of indirect cost rates for institutions of higher education and nonprofit organizations. Oppose inclusion of Section 216, S. 2296, Prohibition on contracts between certain foreign entities and institutions of higher education conducting Department of Defense-funded research. Oppose inclusion of Subtitle D- SAFE Research Act, H.R. 3838. Oppose inclusion of Section 218, H.R. 3838, Post-employment restrictions for participants in certain defense research". Oppose inclusion of Section 1049, H.R. 3838, Prohibition on availability of funds for institutions of higher education that allow antisemitic demonstrations Strong opposition to the Department of Educations proposed Admissions and Consumer Transparency Supplement (ACTS) survey component to the IPEDS data system. Concern for (1) limited availability and accessibility of required data; (2) compressed timeline and resource constraints; (3) increased burden due to retrieval of historical data; (4) student privacy; (5) accuracy of new metrics; and (6) ambiguity in definitions and reporting guidance. Request for the Department to reconsider the approach, extend the implementation timeline, and ensure accurate, feasible reporting. Oppose the Compact for Academic Excellence in Higher Education. Concerns about federal overreach impacting institutional freedom and innovation. Requests the administration to withdraw the compact and protect core academic values. Requests the Department of Veterans Affairs to withdraw its proposed rule redefining distance learning and independent study". Concerns that the definitions misalign with Department of Education terms and could expand GI Bill eligibility to unaccredited programs, weakening quality protections. Requests VA to work with Congress and higher ed stakeholders to modernize definitions while preserving program integrity.

Support for including Section 214, H.R. 3838, and Section 220C, S. 2296 Extension of limitation on availability of funds for fundamental research collaboration with certain academic institutions". Support for including Section 226, S. 2296 Prohibition on modification of indirect cost rates for institutions of higher education and nonprofit organizations. Oppose inclusion of Section 216, S. 2296, Prohibition on contracts between certain foreign entities and institutions of higher education conducting Department of Defense-funded research. Oppose inclusion of Subtitle D- SAFE Research Act, H.R. 3838. Oppose inclusion of Section 218, H.R. 3838, Post-employment restrictions for participants in certain defense research". Oppose inclusion of Section 1049, H.R. 3838, Prohibition on availability of funds for institutions of higher education that allow antisemitic demonstrations Concerns over the FY 2025 funding cuts to Minority-Serving Institutions (MSIs) that was redirected to HBCUs and TCUs. Request for Congress to restore MSI funding and maintain or expand support for all programs in FY 2026.

Request for DHS to clarify and exempt colleges and universities from the new $100,000 H-1B visa application fee established by a Sept. 2025 Presidential Proclamation. Request for details on exemptions, processing, refunds, and fee implementation. oppose DHSs proposed weighted H-1B visa lottery rule. Concern that it would reduce access for international graduates and early-career professionals, harm U.S. universities ability to recruit and retain global talent, and contradict how Congress structured the H-1B program. Requests DHS to withdraw the rule and maintain the existing selection process.