Executive Summary

Section 117 of the Higher Education Act requires U.S. universities that receive federal funds to disclose any foreign gifts or contracts valued at $250,000 or more in a calendar year. These disclosures are meant to provide transparency into foreign financial ties, but reporting practices vary widely, and descriptions of how funds are used are often missing.

China’s financial ties to U.S. higher education are deepening rapidly, with Section 117 disclosures showing dramatic surges in gifts and contracts from 2022–2024. New York University alone reported nearly $200 million, including $80 million in 2024, while Stanford, Yale, and Duke each saw multi-hundred-percent year-over-year increases. Even regional institutions such as Rochester Institute of Technology ($30M in 2023) and Drake University ($12.6M in 2024) emerged as major recipients.

Yet the transparency gap is stark. The largest recipients — New York University (NYU), Stanford University, Yale University, Duke University, and University of California Davis, disclosed little to no information about how these funds were used. NYU reported only $360,000 of $198 million with descriptions, and Duke just $1.6 million of $37 million. In contrast, at Rochester Institute of Technology (RIT), Drake University, University of Michigan, Columbia University, and Brown University included detailed descriptions, covering endowed professorships, scholarships, medical partnerships, and China-focused academic programs. University of Michigan, for example, disclosed $8.2 million of its $9.8 million (83%) with descriptions.

This imbalance underscores a systemic weakness in Section 117: while the law requires reporting of foreign funds, it does not compel universities to specify their use. Only about 13% of Chinese-related reports include descriptions, leaving the overwhelming majority opaque. The correlation is clear: the largest inflows are the least transparent, while the limited visibility we have comes from universities with smaller totals.

Without stronger disclosure requirements, policymakers and the public are “flying blind” — able to see the scale of Chinese money but not its influence. The selective transparency skews the narrative, risks masking strategic vulnerabilities, and undermines accountability at precisely the universities where Chinese funding is most concentrated. This analysis demonstrates that Section 117, as currently structured, provides only a partial picture of foreign influence in U.S. higher education. Without reforms requiring donor-level identification, detailed descriptions of funding purposes, and independent verification of reports, the U.S. will remain vulnerable to hidden channels of influence that can shape research priorities, talent pipelines, and institutional governance in ways that serve Beijing’s strategic interests rather than American.