Washington Update

APLU Submits General Services Administration System for Award Management Comment Letter 
APLU submitted a comment letter on March 23 in response to a new General Services Administration (GSA) proposal to change the System for Award Management. Under the proposal, federal funding recipients would need to respond to new questions as a condition of receiving federal grants, contracts, and cooperative agreements. In an issue update from Jenner & Block, the firm describes the new requirements related to antidiscrimination, immigration, and terrorism. 
 
The association’s comment letter outlines core concerns, including: 

• The proposed new questions violate the Paperwork Reduction Act; 
• The GSA’s approach sets a poor public policy standard that will likely result in extreme policy swings for future administrations; 
• The new proposed questions transition from settled law to unsettled administrative interpretation resulting in massive compliance uncertainty and costs; and 
• The GSA’s proposed time burdens are highly inaccurate for the anticipated burden of public and land-grant universities 
   

District Court Extends IPEDS Admissions Data Freeze but Limits Relief; AAU Granted Motion to Intervene 
On March 24, the District Court for Massachusetts extended a temporary restraining order (TRO) on the IPEDS Admissions and Consumer Transparency Supplement (ACTS) Data Collection until April 6, 2026. However, the scope of relief is limited to public institutions within the 17 plaintiff states, consistent with the request of the U.S. government. The court is expected to rule on a preliminary injunction as soon as April 2nd.  
 
Following the district court action, the Association of American Universities (AAU) filed a motion to intervene as a plaintiff and seeking relief to both stay the Department of Education’s policy and provide specific injunctive relief for its member institutions. The court granted the motion to intervene and extended the temporary restraining order to include the members of new plaintiffs, AAU and the Association of Independent Colleges and Universities in Massachusetts. 
 
The Big Picture: The ACTS reporting requirements, which were finalized by ED in December, require institutions to report detailed admissions and enrollment metrics—many of which are not currently collected through IPEDS. The limited scope of the new TRO essentially leaves non-plaintiff state public institutions with the March 31^st deadline under the first order or the option to petition the U.S. Department of Education directly for an extension until April 8^th. APLU previously requested an extension of the ACTS data collection reporting deadline from March 18 to June 18.  

The initial case in the district court was brought by a coalition of blue state attorneys general, led by Massachusetts and including California, Colorado, Connecticut, Delaware, Hawaiʻi, Illinois, Maryland, Nevada, New Jersey, New York, Oregon, Rhode Island, Vermont, Virginia, Wisconsin, and Washington. 

New Executive Order on Prohibiting DEI in Contracts and Contract-like Instruments 
On March 26, the White House issued a new executive order (EO), “Addressing DEI Discrimination by Federal Contractors.” 

The EO defines “radically discriminatory DEI activities” and requires federal agencies to within 30 days “ensure that contracts and contract-like instruments, including contractors’ subcontracts and subcontractors’ lower-tier subcontracts,” include clauses to prohibit such. The EO further specifies that contractors will need to agree to furnish certain information to the federal government by request in furtherance of ascertaining compliance. The EO does not specifically refer to grants. 

As a result of the EO, new actions will be taken by agencies to update contractual agreements consistent with the White House directive. 

USDA Grant Terms & Conditions Raise Concerns 
On December 31, 2025, USDA released the first set of USDA General Terms and Conditions (GT&Cs) for all future awards. Per the Secretarial Memorandum establishing this change, USDA agencies had 45 days to begin implementation of the new GT&Cs for all new awards and significant modifications to existing awards. On March 18, NIFA released NIFA-specific terms and conditions that, “will be applied to all awards supporting research, education, Extension or integrated activities which are issued or significantly modified on or after March 18, 2026.”  

Why it Matters: Concerns on the new GT&Cs include approaches and interpretations USDA is taking with research security and policy on international partnerships as they significantly differ from how similar policies are implemented at other agencies. APLU has heard from a number of member institutions concerned with the scope of compliance challenges. 

APLU’s Office of Food, Agriculture, & Natural Resources and Office of Governmental Affairs are coordinating internally and with other stakeholders to better understand impacts of the new GT&Cs. Numerous questions have arisen, and for the last several weeks APLU has engaged with USDA and Capitol Hill to share these questions and seek clarifications. A webinar on these new NIFA GT&Cs is scheduled for April 15. You can register for the webinar with this link. 
 
Separately, a coalition of 21 state attorneys general filed suit last week in the District Court for Massachusetts seeking to overturn USDA’s use of other grant terms and conditions. Of particular note, plaintiffs seek relief on “challenged conditions,” not all grant terms and conditions. Per the press release announcing the litigation, “The conditions require states to adopt the Trump administration’s policies on gender identity, diversity, immigration and fair athletic opportunities for girls and women.” 

White House National Policy Framework for Artificial Intelligence 
On March 20, the White House unveiled a national policy framework for artificial intelligence with legislative recommendations for Congress to establish “one consistent federal policy for AI.” The AI Framework emphasizes sustaining and enhancing U.S. global AI dominance, preventing state-level AI regulatory fragmentation, and creating a national standard governing AI proliferation. 

Of particular note, the framework’s ‘Educating Americans and Developing an AI-ready Workforce’ recommendation references the role of land-grant universities. APLU expressed gratitude for the recognition in an X post. 

Go Deeper: Following the release of the AI Framework, the U.S. National Science Foundation announced a new program “to enable all Americans to understand, apply and create with artificial intelligence,” the NSF TechAccess: AI-Ready America (NSF AI-Ready America) initiative. As a first step, NSF, and federal partners — the Department of Agriculture National Institute of Food and Agriculture (USDA NIFA), the Department of Labor, and the Small Business Administration — released a funding opportunity to establish AI-Ready Coordination Hubs in every U.S. state and territory. To learn more, register for an informational webinar on Tuesday, April 14, at 1 p.m. EDT. 

U.S. Department of Education to Vacate Current Headquarters, Department of Energy to Take its Place 
The U.S. Department of Education (ED) announced it will vacate its Lyndon B. Johnson headquarters in August, transferring the building to the Department of Energy. Education Secretary Linda McMahon said the move reflects “unprecedented progress in reducing the federal education footprint” and will allow the space to be used by an agency that will “benefit far more from its space.”  

Per the Department’s press release,  70 percent of the building is vacant. ED plans to relocate staff in phases to 500 D St. NW and estimates the transition will save more than $4 million annually in operating costs. 

U.S. Department of Labor Publishes NPRM on Prevailing Wage Methodology 
The Department of Labor (DOL) published a Notice of Proposed Rulemaking (NPRM) to revise prevailing wage methodology for employment-based visas tilted, “Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nationals in the United States.” The comment period will end on May 26, sixty days after publication in the federal register. 
 
For background, during the first Trump administration, DOL issued an interim final rule that would have significantly raised the prevailing wage across all four tiers for PERM labor certifications. The increased prevailing wage would have made it exceedingly difficult, and expensive, for employers, including universities, to hire international talent. The Biden administration ultimately withdrew the prior administration’s interim final rule (IFR). APLU is reviewing the NPRM and considering submitting comments. 
 
CUPA-HR also sent an alert to its members of college and university HR professionals. 

President Trump Appoints Members to the President’s Council of Advisors on Science and Technology 
Last week, President Trump appointed the first members to the President’s Council of Advisors on Science and Technology (PCAST). PCAST convenes eminent volunteer experts from outside the federal government to advise the White House on matters relating to science and technology policy. Almost all of the first 13 members are current or former CEOs from major tech companies.  

The White House press release noted that, “Under President Trump, PCAST will focus on topics related to the opportunities and challenges that emerging technologies present to the American workforce, and ensuring all Americans thrive in the Golden Age of Innovation.” The release also notes that additional members will be appointed to the council in the near future. 

CNSF Requests at Least $9.9 Billion for NSF in FY27 
Last week, APLU joined the Coalition for National Science Funding in sending a letter to the leaders of the House and Senate Commerce-Justice-Science Appropriations Subcommittees asking them to provide at least $9.9 billion for the National Science Foundation in FY27. Funding NSF at this level would restore the agency “back to the FY 2023 level and reverse cuts that occurred in FY 2024 and FY 2026 appropriation bills,” the letter noted. 

National Institute of Health Director Testifies on FY26 Spending 
Recent reporting indicates the National Institutes of Health (NIH) has awarded approximately 74 percent fewer grants in FY26 than the historical average at this point in previous years. In testimony before House Appropriations Labor, Health and Human Services and Education Subcommittee on March 17th, NIH Director Jay Bhattacharya stated that funding should be released soon and that the agency will spend its full $48.7 billion budget by the end of fiscal year 2026.  

During the hearing, it was revealed that the Office of Management and Budget approved NIH’s spending plan on March 16th. Director Bhattacharya reported that momentum is building in releasing funds, with 22 new grants already out the door, 150 additional awards in progress, and more than 1,000 existing grants soon to follow. Bhattacharya also addressed the agency’s leadership gaps, noting that 16 of 27 institute directors are currently serving in acting capacities and that permanent appointments will begin this month. 

APLU Joins Friends of IES Coalition Letter on FY27 Appropriations 
APLU joined the Friends of IES coalition’s letter in support of FY27 appropriations for the Institute of Education Sciences (IES) to “advance innovative research, develop the methodological skills of education researchers, and continue to support high-quality and trustworthy statistics and evidence-based resources.” 
 
The letter requests $900 million for IES in FY27 and urges the Labor, Health & Human Services, Education, & Related Agencies subcommittee to maintain provisions in bill text for individual lines items within IES. While the request level in the letter exceeds APLU’s FY27 request of $853.9 million, the association’s requests are “at a minimum.” 

APLU Endorses Bipartisan Bill to Codify Optional Practical Training 
APLU endorsed the Keep Innovators in America Act, a bipartisan bill introduced by Representatives Sam Liccardo (D-CA), Jay Obernolte (R-CA), and Raja Krishnamoorthi (D-IL) to codify the Optional Practical Training program. 
 
Optional Practical Training permits international students to receive training in their field of study for up to three years post-completion (12 months for all graduates with an additional 24-month extension available for STEM graduates). As described in an APLU talking points document developed during the first Trump administration, OPT is critical to U.S. competitiveness to attract international students and benefit from their immense contributions to the nation. The program remains under review by the Trump administration. 
 
A list of other endorsing organizations is available in Rep. Liccardo’s press release. 

APLU Thanks Congressional Leaders for Passing Small Business Innovation and Security Act Reauthorization 
APLU joined AAU, AUTM, ACE, and AAMC in sending a letter to congressional leaders from committees of jurisdiction thanking them for passing the Small Business Innovation and Security Act. The bill, which passed on a bipartisan basis in the House and Senate, extends authorization of the Small Business Innovation Research and Small Business Technology Transfer programs for five years. The bill has not yet been presented to President Trump given the President’s declaration to sign no laws until the SAVE Act passes Congress. 

APLU extends thanks to members who engaged in advocacy on this bill.