By Eduardo Bacci, The Investigative Journal
For the better part of a decade, the largest single foreign source of money flowing into American higher education sat under the surface of the federal disclosure system. The dollars were public knowledge in fragmentary form — an annual report here, a Form 990 line there, an investigative news story every few years — but the federal records meant to capture them under Section 117 of the Higher Education Act were incomplete, late, or never filed at all. On January 2, 2026, that began to change. The U.S. Department of Education flipped the switch on a redesigned reporting portal at ForeignFundingHigherEd.gov, and over the following six weeks the public got its first comprehensive view of the foreign money funding American universities. The cumulative figure, going back to 1986, is $67.6 billion. The single largest national contributor is not China. It is Qatar.
According to the February 11, 2026 release from the Department of Education, the 2025 reporting cycle alone produced more than 8,300 transactions worth more than $5.2 billion in disclosed foreign gifts and contracts. Qatar led the country list at over $1.1 billion in 2025 disclosures, ahead of the United Kingdom ($633 million), China ($528 million), Switzerland ($451 million), Japan ($374 million), Germany ($292 million), and Saudi Arabia ($285 million). Carnegie Mellon University, the Massachusetts Institute of Technology, Stanford University, and Harvard University were the top recipient institutions, each pulling in between roughly $324 million and $1 billion in 2025. And buried in the same release was a smaller number with larger implications: between February 28, 2025 and December 16, 2025, more than $2 billion in reportable gifts and contracts were filed late, in direct violation of the statute’s reporting deadlines.
That $2 billion of late filings — roughly forty percent of the size of the entire 2025 cycle — is the part of the new disclosure regime that warrants the closest look. Records suggest that even after a presidential executive order, a redesigned portal, four open Section 117 investigations, and a pending bill in the Senate to tighten the reporting threshold, the federal government still does not have a real-time view of the money moving from foreign capitals into American university accounts. The gap between what universities receive and what the public knows is narrowing, but it is not closed.
The portal: what’s now public, and how it got there
Section 117 was added to the Higher Education Act in 1986. Its mechanics are straightforward: any institution of higher education receiving federal financial assistance must twice a year disclose to the Department of Education any gift from or contract with a foreign source that, alone or in combination with other transactions from the same source, totals $250,000 or more in a calendar year. The disclosures are required to be made available for “public inspection.” For most of the statute’s life, that public inspection happened through periodic spreadsheet drops on the Department’s website, with limited search capability and material gaps in compliance. A 2019 Senate Permanent Subcommittee on Investigations review documented that universities had failed to disclose more than half of reportable foreign gifts between 2010 and 2016.
The Trump administration moved on the issue early in its second term. Executive Order 14282, signed April 23, 2025, directed the Secretary of Education to reverse prior actions that had let universities obscure foreign-funding details and to coordinate with the Attorney General on enforcement. On December 1, 2025, the Department announced the new portal, beta-tested with nine institutions including the University of Texas at Austin, USC, Pepperdine, Purdue, Indiana, and the University of Arizona. The portal launched on January 2, 2026 with bulk-upload capability, executive-summary visualizations, and 11 additional data fields beyond the legacy system — a 61 percent increase in publicly available data points, according to the Department.
The portal also surfaced something the legacy system had not made easy: a side-by-side accounting of which institutions had received the most money from countries the federal government formally designates as posing security or strategic concerns. Under 42 U.S.C. § 19221(a)(1), the People’s Republic of China, the Russian Federation, the Islamic Republic of Iran, and the Democratic People’s Republic of Korea are statutorily designated as “foreign countries of concern,” with additional countries available for State Department designation. The Department’s February disclosure showed that, going back to 1986 and through December 16, 2025, Harvard University has reported the largest cumulative amount from those designated countries at more than $610 million, followed by MIT at over $490 million, NYU at over $462 million, Stanford at over $418 million, and Yale at over $400 million. Qatar is not on the statutory list. That is a meaningful distinction — Qatar is a major non-NATO ally and a long-running U.S. military partner — but the $8.8 billion in cumulative Qatari-attributed funding documented in the portal still represents the largest single-country relationship in the dataset.
Cornell and Qatar: the case study the portal makes legible
The single largest reported transaction in the portal is also the cleanest example of how the disclosure regime functions in practice. According to data displayed on ForeignFundingHigherEd.gov and summarized by The Cornell Daily Sun, Cornell University has disclosed more than $2.3 billion in cumulative Qatari-attributed funding, the bulk of which underwrites Weill Cornell Medicine–Qatar, the medical school the university opened in Doha in 2002. The largest individual contract recorded in the entire portal is a restricted Cornell–Qatar Foundation agreement valued at approximately $1.1 billion covering the award period of January 1, 2026 through June 30, 2032 — a six-and-a-half-year operating commitment with a single foreign counterparty.
Cornell’s relationship with the Qatar Foundation is not new, and its disclosure history is instructive. In an October 2020 university statement, Cornell acknowledged that an internal review prompted by a 2019 Department of Education inquiry had identified more than $1 billion in Weill Cornell Medicine–Qatar operating funds that had not been separately reported under Section 117 since 2012, in addition to roughly $150 million in other foreign gifts and contracts that the university determined were potentially required to have been reported. Cornell filed a corrected report in 2019 and added a central Chief Compliance Officer. The university told the Department that the Qatar funds had been included in its IRS Form 990 filings; they had simply not been reported through the separate Section 117 process. The episode is the clearest documented illustration of the structural problem the new portal is designed to address: universities can be in compliance with one federal disclosure regime and out of compliance with another, and the public has no easy way to reconcile the two.
Education City and the branch-campus model
To understand why one country accounts for nearly a seventh of the cumulative dataset, it helps to look at Doha. Beginning in the late 1990s, the Qatar Foundation — a non-profit chaired by members of the ruling Al Thani family — built out a research-and-education park called Education City, then recruited American universities to operate branch campuses there under long-term financial agreements. According to public records compiled by the Qatar Foundation and corroborated in Section 117 filings, the cumulative funding to U.S. branch institutions in Education City through fiscal year 2022 included roughly $1.79 billion to Cornell/Weill Cornell Medicine–Qatar, $760.6 million to Georgetown’s School of Foreign Service in Qatar, $740.9 million to Carnegie Mellon University–Qatar, $696.4 million to Texas A&M University at Qatar, $602.0 million to Northwestern University in Qatar, and $103.4 million to Virginia Commonwealth University’s VCUarts Qatar.
Each of those agreements is, by the universities’ own descriptions, an operating contract: Qatar funds the campus, the U.S. institution provides the curriculum, faculty, and degree-granting authority. That is a legitimate model, and several of the institutions have argued publicly that it expands American academic influence abroad. It is also a structurally different relationship from a research grant or a one-time donation, because the dollar amounts compound year after year and the counterparty is a foreign-government-aligned foundation. Section 117 does not distinguish between the two; both flow into the portal as “foreign source” transactions. But records suggest the branch-campus model is what produces the asymmetry between Qatar and other top funders: Qatar’s cumulative numbers reflect more than two decades of recurring contract obligations, not periodic gifts.
The late-filing problem
The most consequential single line in the Department’s February 11 release is also the easiest to overlook. Between February 28, 2025 and December 16, 2025 — the cutoff for migrating filings into the new portal — institutions reported “more than $2 billion in reportable gifts and contracts” late. That is not the cumulative late-filing total. That is the late-filing total for one ten-month window.
The Department has not, as of this writing, published a per-institution breakdown of which schools were responsible for the late filings or which countries were the source of the underlying funds. Filings indicate that the late-disclosure problem is broad enough to span multiple cycles. Since President Trump’s January 20, 2025 inauguration, the Department has opened four new Section 117 investigations — into Harvard University, the University of Pennsylvania, the University of California, Berkeley, and the University of Michigan — “amid reports of inaccurate and untimely foreign source gift and contract disclosures,” according to the Department. Those inquiries are ongoing, and no findings have been published; institutions have not been charged with violations.
Outside the executive branch, Congress has moved as well. On March 27, 2025, the House passed H.R. 1048, the DETERRENT Act, by a 241-169 vote. The bill, sponsored by Rep. Michael Baumgartner (R-WA-05), would lower the Section 117 reporting threshold from $250,000 to $50,000 for foreign sources outside designated countries of concern, set a $0 threshold for any gift or contract from a country of concern, prohibit U.S. universities from entering into contracts with country-of-concern entities absent a Department waiver, and require the largest research institutions to maintain a publicly searchable database of foreign gifts to individual faculty and staff. The bill, according to the sponsor’s press office, was prompted in part by an earlier congressional finding of nearly $40 million in unreported research contracts with Chinese-government-linked entities at two research universities. The DETERRENT Act now sits in the Senate, where its path is less clear.
Where the portal goes from here
The disclosure architecture that surfaced this week is, by any measure, the most comprehensive accounting of foreign money in American higher education the public has ever had. It is also incomplete. The $67.6 billion cumulative figure rests on self-reported data, with no independent audit mechanism in place; the $2 billion in late 2025 filings establishes that even universities with full-time compliance staffs are not consistently meeting the deadlines; and the portal does not currently capture sub-recipient grants, individual faculty consulting income below institutional-counterparty thresholds, or transfers routed through foreign affiliates of U.S. universities. The Department of Education and the Department of State announced a coordination agreement in February 2026 to share intelligence on foreign-funding flows, but that integration is in its earliest phase.
The Qatari case in particular illustrates the limits of pure disclosure. Cornell’s $1.1 billion six-year operating contract is a legal, longstanding commercial relationship between a U.S. private university and a foreign-government-aligned foundation. Whether it is also strategically advisable is a policy question that disclosure alone cannot resolve. What disclosure can do — and what the new portal is now beginning to do — is move the debate out of fragmentary press accounts and Form 990 footnotes and into a single, queryable federal record. For the first time, a member of Congress, a state attorney general, an academic researcher, or a constituent can pull the cumulative country-by-country and institution-by-institution numbers in one sitting, and verify them against the underlying contracts.
What to watch over the next several months: the next portal update, scheduled for after the January 31, 2026 reporting deadline, will indicate how compliance behavior shifts under the Trump executive order and the threat of DOJ referral. The four open Section 117 investigations will produce findings or settlements that, if consistent with the Cornell precedent, will likely add hundreds of millions to the cumulative totals. The DETERRENT Act will either pass the Senate and dramatically expand the universe of reportable transactions or stall, leaving the $250,000 threshold and current statutory countries-of-concern definitions in place. And Qatar, almost certainly, will remain the top single-country source on the portal — not because of any one transaction, but because the branch-campus operating model that produced the $8.8 billion compounds, year after year, into the federal record.
The portal’s existence is a modest reform with substantial downstream effects. It does not regulate the underlying contracts. It does not substitute for export-control review, FARA enforcement, or congressional oversight. What it does is end the practical opacity that allowed a $1 billion-plus operating commitment to a single American medical school to remain off the federal disclosure ledger for the better part of a decade. That, on its own, is the kind of accountability infrastructure the statute envisioned in 1986 — and that, four decades later, is finally being built.
Sources:
- U.S. Department of Education, “U.S. Department of Education Releases Latest Foreign Funding Disclosures from Federally-Funded American Universities,” February 11, 2026
- U.S. Department of Education, “U.S. Department of Education Announces New and Improved Portal for Universities to Report Foreign Funding,” December 1, 2025
- U.S. Department of Education, Section 117 Foreign Gift and Contract Data archive
- The White House, Executive Order 14282, “Transparency Regarding Foreign Influence at American Universities,” April 23, 2025
- 20 U.S.C. § 1011f — Section 117 of the Higher Education Act
- 42 U.S.C. § 19221(a)(1) — Foreign country of concern definition
- U.S. Congress, H.R. 1048 — DETERRENT Act, 119th Congress
- Office of Rep. Michael Baumgartner, “DETERRENT Act Passes the House,” March 27, 2025
- Cornell University, “Compliance with Section 117 of the Higher Education Act,” October 21, 2020
- The Cornell Daily Sun, “Cornell Receives Second Most Funds From Foreign Nations At Over $3 Billion,” January 2026
- Ropes & Gray LLP, “Department of Education Partners with Department of State on HEA Section 117 Foreign Gift and Contract Reporting,” February 2026
- Congressional Research Service, “Section 117 of the Higher Education Act: Reporting of Foreign Gifts and Contracts”