Higher Education — Year in Review for 2025

The higher education sector experienced an unprecedented convergence of regulatory, enforcement, and litigation pressures in 2025, which reshaped the legal and operational environment for colleges and universities. Institutions of higher education (IHEs) came under increased scrutiny from the White House, federal enforcement and regulatory agencies, and Congress, as well as private plaintiffs—on athletics; admissions; diversity, equity, and inclusion (DEI) initiatives; and many other areas. This scrutiny was often accompanied by significant financial consequences. This 2025 Year in Review provides perspective on key events impacting the current landscape of higher education and helps anticipate the trends and developments that will shape 2026 and the years ahead. This review examines the most significant legal developments affecting higher education in 2025, including transformative changes in collegiate athletics and name, image, and likeness (NIL) governance; sweeping executive and congressional actions targeting diversity, accreditation, research funding, and foreign influence; evolving antitrust and civil rights enforcement; and an intensifying landscape of criminal, civil, and administrative investigations that together have radically reshaped institutional risks and compliance obligations.

Nowhere was the pace of change more visible than in collegiate athletics. The final approval of the House v. NCAA settlement marked a historic shift toward direct athlete compensation, formalized revenue sharing, and centralized NIL oversight through the newly created College Sports Commission (CSC). Additionally, aggressive enforcement against gambling-related misconduct, recruiting violations, and oversight failures demonstrated that regulatory discipline has not eased in the post‑NCAA-amateurism era. Meanwhile, the emergence of private equity financing in athletics—and congressional efforts to restrict it—introduced new capital structures alongside novel governance and compliance risks.

Beyond athletics, institutions of higher education were subject to a transformative federal policy agenda driven by executive action. A series of executive orders targeting DEI programs, accreditation standards, and foreign influence fundamentally altered compliance expectations, particularly for IHEs reliant on federal funding. Widespread funding freezes, civil rights investigations, and the use of settlement agreements to mandate structural policy reforms reinforced these directives and placed senior administrators and governing boards under increasing legal and financial pressure.

Moreover, civil and criminal enforcement activity expanded across multiple fronts, with the Department of Justice (DOJ) signaling a willingness to apply the False Claims Act (FCA) to alleged civil rights violations and to aggressively pursue whistleblower‑driven litigation. Additionally, heightened scrutiny of foreign gifts, research partnerships, and national security risks—particularly involving the People's Republic of China—forced institutions to reassess the long‑standing academic and financial relationships upon which they had become reliant.

Although somewhat overshadowed by the civil and criminal enforcement activity, institutions continued to conduct internal investigations into traditional issues like plagiarism, harassment, and leadership misconduct. In 2025, institutions of higher education also had to confront the problems caused by generative artificial intelligence and deal with questions regarding the scope of academic expression in today's political climate.

Antitrust law also remained a central theme in legacy financial-aid cases moving toward resolution, while new legal challenges targeted early-decision admissions practices and tuition pricing.

Congressional committees amplified their enforcement efforts through targeted investigations focused on antisemitism, DEI initiatives, foreign influence, and the perceived politicization of academic programs.

Taken together, 2025 marked a decisive shift toward centralized federal oversight, aggressive enforcement, and the use of financial leverage to reshape the behaviors of US colleges and universities. As these institutions enter 2026, they must navigate an environment where legal risk, reputational exposure, and operational decision‑making are increasingly intertwined—and where proactive compliance, governance discipline, and strategic legal planning are essential.

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II. Executive Orders Targeting DEI, Research Funding, the Compact, and the Big Beautiful Bill

A. Executive Orders Targeting DEI

1. Executive Order: Ending Illegal Discrimination and Restoring Merit-Based Opportunity

The risks associated with DEI programs shifted significantly when President Donald J. Trump, on his first full day in office, issued an Executive Order entitled Ending Illegal Discrimination and Restoring Merit-Based Opportunity (the DEI Order).¹ It characterized DEI initiatives as vehicles for "illegal" and "dangerous, demeaning, and immoral race- and sex-based preferences."²

The DEI Order directed the Department of Justice and other federal agencies to:

investigate organizations for "illegal" DEI practices;
develop litigation strategies against those organizations; and
require federal contractors to certify—under penalty of the False Claims Act—that they do not operate DEI programs violating federal anti-discrimination laws.³

It also rescinded prior executive orders requiring federal contractors to implement race- and gender-based affirmative action plans (AAPs), and gave contractors 90 days to wind down those plans, while retaining AAP requirements for veterans and individuals with disabilities.⁴ It further required contractors and grant recipients to certify that they did not operate DEI programs that would violate federal anti-discrimination laws and to acknowledge that compliance is "material" under the FCA.⁵

Notably, the DEI Order did not define "illegal DEI" or specify which practices were unlawful. Federal agencies, however, attempted to fill that gap by issuing guidance on the subject. For instance, Attorney General Pam Bondi issued a memorandum, titled Ending Illegal DEI and DEIA Discrimination Preferences, illustrating the types of DEI practices that the DOJ will target.⁶ The EEOC and DOJ released two technical assistance documents—What to Do If You Experience Discrimination Related to DEI at Work⁷ and What You Should Know About DEI-Related Discrimination at Work.⁸ This guidance defined "illegal DEI" as any initiative, policy, program, or practice that involves an employer taking an employment action motivated—in whole or in part—by race, sex, or another protected characteristic.⁹

2. Executive Order: Reforming Accreditation to Strengthen Higher Education

On April 23, 2025, President Trump issued the Executive Order titled Reforming Accreditation to Strengthen Higher Education, a sweeping directive aimed at changing the accreditation system that governs higher education, including access to federal student aid (the Accreditation Order).¹⁰ The Accreditation Order asserts that accreditors have failed in their core mission of ensuring educational quality, contending that, instead of prioritizing student outcomes, accreditors have imposed ideological requirements, particularly those rooted in DEI.¹¹

Specifically, the Accreditation Order targets the American Bar Association's Council on Legal Education, the Liaison Committee on Medical Education, and the Accreditation Council for Graduate Medical Education for allegedly imposing standards that mandate diversity-based recruitment, purportedly at the expense of merit.¹² Characterizing these practices as unlawful discrimination, the Accreditation Order directs the Department of Education and DOJ to investigate and consider revoking the federal recognition of non-compliant accreditors.¹³

The Accreditation Order represents a fundamental shift in federal higher education policy. It seeks to dismantle accreditation practices that prioritize inclusive considerations and replace them with a framework centered on what the administration considers to be academic quality. For IHEs, the implications are profound: compliance will increasingly hinge on demonstrable student success rather than adherence to DEI mandates. For accreditors, the stakes are even higher, as failure to align with these new principles could result in loss of federal recognition and authority.

B. Research Funding

Throughout 2025, the administration implemented a series of federal funding freezes that disrupted the higher education research landscape.¹⁴ This began on January 27, 2025, when the Office of Management and Budget issued a memorandum ordering a temporary pause on the obligation and disbursement of federal financial assistance to ensure conformity with administration priorities, specifically targeting areas such as DEI and gender ideology.¹⁵ Although a few federal courts issued temporary restraining orders to suspend these freezes, the administration effectively maintained the pause by using internal agency procedures.¹⁶ For instance, the National Institutes of Health effectively halted grant funding by indefinitely banning the public communications and Federal Register notices required to convene the peer review meetings necessary for awarding new grants.¹⁷

As the year progressed, the administration transitioned from broad mandates to targeted enforcement against specific IHEs, often citing concerns over antisemitism or ideological non-compliance.¹⁸ The administration specifically targeted Harvard University, the University of Pennsylvania, Brown University, Columbia University, Cornell University, the University of Virginia, and Northwestern University. In March and April 2025, the administration announced massive funding freezes at several elite universities, including $400 million at Columbia University, $510 million at Brown University, and a record $2.2 billion at Harvard University.¹⁹ While some freezes were framed as investigations into Title VI violations, others were tied to specific policy disagreements, such as the $175 million freeze at the University of Pennsylvania due to its policies on transgender athletes.²⁰ In many cases, these actions were preceded by stop-work orders on existing federal grants, which immediately stalled critical research in fields ranging from robotics and nanotechnology to cancer research and propulsion systems.²¹

The impact of these freezes was both immediate and systemic, creating an environment of intense legal and financial instability for research institutions. For example, some universities with the ability to do so, like Northwestern, have self-funded vital research projects to allow them to continue.²²

The targeted universities initially announced contingency plans, but by the summer and fall of 2025, several institutions negotiated deals with the government to restore access to frozen federal research funds. The institutions agreed to multimillion-dollar settlements and significant administration-aligned policy changes. Columbia's agreement was the most costly, requiring $200 million to the US Treasury and an additional $21 million for an Equal Employment Opportunity Commission (EEOC) claims fund, while Northwestern and Cornell committed $75 and $60 million, respectively.²³ Meanwhile, Brown pledged $50 million toward Rhode Island workforce development, whereas Penn and UVA avoided financial penalties but agreed to make various policy revisions and take other steps to comply with the administration's demands.²⁴

Looking beyond payments, the settlements imposed significant compliance obligations. Universities agreed to adopt antisemitism training and reporting requirements, roll back DEI programs, and enforce Title IX interpretations based on sex assigned at birth by, inter alia, restricting transgender women from participating in women's sports and facilities.²⁵ Columbia and Northwestern also face new oversight of foreign funding and international student enrollment.²⁶

The outlier in this group was Harvard, which opted to litigate. In September 2025, a Massachusetts federal court granted partial summary judgment for the university, ordering the release of $2.2 billion in frozen grants.²⁷ While the order signaled an early win for Harvard, negotiations over the administration's $500 million settlement proposal remain ongoing as of early 2026.

Read more on Steptoe's analysis of the early settlements and Harvard's suit.

C. The Compact for Higher Education

On October 1, 2025, the White House introduced the Compact for Academic Excellence in Higher Education (the Compact), a policy initiative that conditions preferential federal funding on institutions adhering to a specific reform agenda.²⁸ Authored by Secretary of Education Linda McMahon and other senior administration officials, the Compact was initially sent to nine large research universities—including Massachusetts Institute of Technology, the University of Pennsylvania, and University of Virginia—before being extended to all colleges and universities via a Truth Social post by President Trump.²⁹ Signatories of the Compact would be required to commit to a range of mandates across eight categories, including banning the consideration of protected characteristics in admissions and hiring, freezing tuition for five years, adopting strict gender definitions, and "abolishing institutional units" deemed hostile to conservative ideas.³⁰ In exchange for compliance, the administration promised multiple benefits, including substantial federal grants and increased overhead payments.³¹

The Compact has been marked by resistance from the higher education sector and legal uncertainty for institutional leadership.³² By November 2025, the majority of the original nine recipients formally rejected the proposal, noting that the proposal compromises academic freedom, institutional autonomy, and the principle of merit-based research funding.³³ Conversely, some institutions like Valley Forge Military College, New College of Florida, and Saint Augustine University have indicated interest, viewing the initiative as a step toward preserving American educational leadership.³⁴

The impact of the Compact would be particularly significant because it requires administrators to certify annual compliance with these commitments, potentially exposing them to liability under the FCA.³⁵ Institutions must also navigate conflicting state pressures, such as in California, for example, where state funding has been conditioned on universities not signing the Compact. Furthermore, the lack of specific statutory authority for these funding conditions suggests that the Compact may face legal challenges.

D. One Big Beautiful Bill Act

On July 4, 2025, President Trump signed into law the 2025 Budget Reconciliation Act—also known as the "One Big Beautiful Bill Act" or "BBB"—which is a comprehensive budget package that includes multiple provisions, some of which relate to higher education.³⁶ As discussed more in Section 5 below, the BBB impacts colleges and universities in a variety of ways, including restructuring federal student loans, redefining institutional accountability through federal student aid awards, and adjusting Pell Grant eligibility.³⁷ Furthermore, the BBB revises the excise tax imposed on certain private college and university endowments, marking a significant shift in how the government regulates the financial and academic performance of higher education institutions.³⁸

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III. Collegiate Athletics

A. House Settlement and the CSC

The 2025 settlement in House v. NCAA (the House Settlement) was a seminal moment in higher education sports law.³⁹As we have previously discussed, the House Settlement resolved lawsuits brought by current and former collegiate student-athletes against the NCAA and provided $2.8 billion in damages to former student-athletes. It also authorized schools to share approximately $20 million a year in revenue with their student-athletes. The House Settlement also created the College Sports Commission (CSC), which in turn created a clearinghouse to review and approve NIL contracts to ensure that they are for valid business purposes. In October 2025, the NCAA expanded NIL reporting obligations for both student-athletes and institutions and introduced consequences for noncompliance. Please see our other articles for additional information about last year's important NIL developments.

B. Gambling

The NCAA continued to open investigations into improper gambling by collegiate athletes and coaches.⁴⁰ This was particularly true for "prop bets," which are wagers on specific events occurring in a game. In November 2025, the NCAA announced that six players at three universities (Arizona State, Mississippi Valley, and New Orleans) had underperformed or "thrown" games for betting purposes.⁴¹ The NCAA permanently revoked all the students' eligibility. Another notable case involved a Temple basketball guard who the NCAA deemed permanently ineligible after he placed dozens of bets, including 23 that involved his own team (three of which were against Temple).⁴² And in December 2025, the NCAA announced that a former men's basketball player at the University of San Francisco had provided inside information to a friend for betting purposes.⁴³ The NCAA explained that the player would have been deemed permanently ineligible because of his violations, but he had already exhausted his eligibility.

In October, the NCAA announced that it had investigated potential gambling violations by three student-athletes at Eastern Michigan.⁴⁴ The three men refused to be interviewed and were found to have destroyed images on their phones. The NCAA, which can revoke eligibility without finding clear evidence of gambling violations, concluded that the student-athletes' behavior justified a permanent sports ban; however, the three student-athletes had already exhausted their eligibility.

The NCAA and its members also continued to wrestle with the appropriateness of gambling on professional sports. In October 2025, the NCAA issued a new rule allowing athletes to bet on professional sports.⁴⁵ However, before it was implemented, the rule was overridden in November 2025 when two-thirds of the Division 1 schools voted against it.⁴⁶

Because of how easy it is to participate in sports gambling from one's smartphone, coupled with new enforcement tools and collaboration between the NCAA and sportsbooks, we expect to see many more investigations into collegiate sports gambling. The examples above also illustrate that outgoing seniors who are in their final season of eligibility, as well as athletes unhappy with their current NIL take, are particularly vulnerable to the pressure to participate in gambling activities.

C. NIL and Financial Bills in Congress

Several federal legislators have introduced bills that would impact how college athletics and NIL may be funded. Notable ones include the Student Compensation and Opportunity through Rights and Endorsements Act (SCORE Act),⁴⁷ the Student Athlete Fairness & Enforcement Act (SAFE Act),⁴⁸ the College Athletics Reform Act (CARA Act),⁴⁹ and the Protect College Sports from Private Equity and Foreign Influence Act (PROTECT Act).⁵⁰

The SCORE Act would prohibit the NCAA or schools from restricting NIL deals. It would also authorize the NCAA and conferences to establish eligibility, transfer, recruitment, and NIL rules while being shielded from antitrust liability; and clarify that student-athletes are not employees. And in an attempt to protect non-revenue generating Olympic sports, the SCORE Act would require schools that generate more than $20 million in annual athletics revenue to have at least 16 varsity teams (subject to Title IX regulations).

The SAFE Act would establish student athletes' NIL rights and require NIL contracts to include certain safeguards. It would also cap agent fees at 5%. The SAFE Act would set new transfer rules and require NIL deals to be for a "valid business purpose."⁵¹ It also would allow colleges and universities to collectively negotiate media rights without violating antitrust laws, and would require schools to use portions of their media rights revenue to fund women's sports teams and Olympic sports.

The CARA Act would prohibit restrictions on NIL compensation and require NIL agreements to include various safeguards. The bill would also cap agent fees at 4%, bar mandatory disclosure of NIL terms, and allow foreign athletes to earn NIL money without violating their visa. The CARA Act would also expand institutional athletics disclosure requirements and establishes a commission to study athletic governance matters.

The PROTECT Act would prohibit schools from entering into agreements with private equity groups or sovereign wealth funds that would convey the rights to any revenue generated by a school's athletic program or grant control over athletic decisions. The prohibition would also apply to a school's NIL collective. These prohibitions would not apply to paying for services, gifts, financing, or sponsorships.

D. Private Equity

Private equity became part of the college athletics landscape in 2025. In December 2025, the University of Utah announced a joint venture with a private equity firm.⁵² They created a for-profit company in which, in exchange for a share of future athletics-related revenue, Utah received $500 million in up-front capital. The new company will house revenue streams such as "ticketing, concessions, media rights, event operations, licensing, and sponsorships."⁵³ Certain donors are also allowed to invest in the company. Under the reported terms, Utah will retain "majority ownership and full control over coaches, scheduling, compliance, and player decisions."⁵⁴

Beyond Utah, the Big 10 Conference stepped away from its own private equity deal that had been in the works for almost two years.⁵⁵ The University of Michigan and the University of Southern California were the most vocal critics of the deal, with one regent referring to it as a "payday loan."⁵⁶ The Big 12, on the other hand, is reportedly negotiating a deal with a private equity firm that would function as a credit facility instead of a partnership.⁵⁷

E. Recruiting Violations

The NCAA continues to enforce several recruiting rules. In November 2025, the NCAA and Michigan State University reached a negotiated resolution under which Michigan State agreed that its football program committed several recruiting violations, particularly paying for airfare and hotel lodging for prospects and their traveling party.⁵⁸ Michigan State also agreed that former head coach Mel Tucker failed to conduct sufficient oversight of his program, in large part because he over-relied on his general manager to handle all off-field activities. In addition to an almost million-dollar fine, probation, show cause orders for individuals, and recruiting restrictions, Michigan State agreed to vacate 14 wins from the past three seasons.⁵⁹

Other schools were penalized for behavior that did not involve financial inducements. The NCAA found that the University of California – Berkeley (Cal) committed recruiting violations when Cal staffers facilitated a Zoom call between three former Cal players (who were considered boosters) with prospects and family members during a recruiting event.⁶⁰ Those staffers had disregarded a specific directive from Cal's compliance office to not hold the call, and one of the staffers provided false information during the NCAA investigation. This violation, and the aggravating factors, resulted in a year-long probation, a fine of $25,000, and several recruiting restrictions. The NCAA also placed Oklahoma State University's women's tennis program on probation for three years after the NCAA found that the head coach impermissibly contacted athletes before they were in the transfer portal and then refused to cooperate with the NCAA investigation.⁶¹

F. For Cause Firings

As discussed in further detail below, schools are increasingly labeling their firings of coaches as "for cause" rather than as a mutual separation or a not-for-cause firing. Louisiana State University (LSU) fired coach Brian Kelly just eight games into the 2025 season after a blowout loss. Kelly subsequently sued LSU, alleging that LSU was claiming that (1) he had not been formally terminated and (2) there were grounds for termination without cause.⁶² Soon thereafter, LSU officially fired Kelly without cause.⁶³ Contrast that to Kansas State, who explicitly fired Coach Jerome Tang "for cause," claiming that his pointed critique of his players in post-game comments violated Tang's contract, which forbids behavior that "subject Coach, Kansas State Athletics or the University to public disrepute, embarrassment, ridicule or scandal."⁶⁴

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IV. Antitrust

In 2025, several key higher education antitrust lawsuits were resolved both in and out of court. In January 2025, Johns Hopkins University and California Institute of Technology (Caltech) became the latest defendant universities to reach settlements in a class action antitrust case accusing 17 schools of violating antitrust law.⁶⁵ The schools were accused of colluding on financial-aid policies while failing to maintain a fully need-blind admissions process as required under a statutory antitrust exemption, and in doing so, gave unfair advantages to wealthier applicants.⁶⁶ Despite the settlement, all of the schools have maintained that there was no wrongdoing. The Johns Hopkins and Caltech settlements amount to $35 million of the $320 million total in settlements agreed to thus far by schools named in the case.⁶⁷ There are five schools left in the litigation, which is still ongoing after the court denied the schools' Motion for Summary Judgment in January.

As discussed in Section III, in June 2025, the final settlement agreement in House v. NCAA was approved.

In September 2025, a federal judge granted a motion to dismiss by the defendants in another antitrust lawsuit filed against 40 colleges and universities accusing the schools of engaging in price-fixing.⁶⁸ The lawsuit alleged that by agreeing to require students to submit the financial information of non-custodial parents for use in potential financial-aid award calculations, the schools were violating Section 1 of the Sherman Act. In dismissing the complaint, the court ruled that the plaintiffs failed to show that the defendants plausibly entered into an agreement as a part of the alleged violation.⁶⁹

In 2025, the higher education sector also saw the initiation of new antitrust litigation. In August 2025, a group of students filed a lawsuit against 32 colleges and universities, the Common Application, Scoir, and the Consortium on Financing Higher Education alleging that the schools' early decision procedures are disadvantageous to less wealthy applicants who are forced to commit to a college without knowing what their full cost of attendance will be.⁷⁰ The complaint describes Early Decision as "a classic per se violation of the antitrust laws" where would-be competitors agree to not compete for potential admits and in doing so create an "unfair and harmful" system.⁷¹ In October 2025, the defendants filed motions to dismiss, which are pending.

Also in August 2025, a class-action antitrust lawsuit was filed against the Law School Admission Council, Inc. (LSAC).⁷² The complaint alleges that LSAC colludes with member schools in order to overcharge students through law-school application fees and that it uses profits from these fees to pay kickbacks to member schools to incentivize their participation and quash competition.⁷³ The plaintiff in the lawsuit argues that this behavior amounts to violations of Section 1 and Section 2 of the Sherman Act.⁷⁴ LSAC filed a motion to dismiss in October 2025, which is awaiting a ruling.

Antitrust enforcement in higher education included new developments from Capitol Hill last year. In April 2025, the Senate and House Judiciary Committees opened an antitrust investigation into the eight Ivy League schools over tuition pricing practices.⁷⁵ The committees requested communications and documents regarding tuition prices and claimed that the schools were "engaging in price discrimination by offering selective financial aid packages to maximize profit."⁷⁶ In June 2025, the House committee issued a subpoena to Harvard University,⁷⁷ citing an "inadequate" response to the investigation and in July, they issued similar subpoenas to Brown University and the University of Pennsylvania.⁷⁸

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V. Criminal and Civil Enforcement Developments

A. Shifting Civil Rights Enforcement Increases Compliance Risks for Institutions as Investigations Grow

In 2025, the administration signaled a major shift in civil rights enforcement across higher education, launching large-scale investigations under Titles VI and IX, while also reshaping Title VII policy. The policies are framed by the administration as refocusing decision-making on merit and dismantling race- and identity-based preferences. Universities now face higher compliance risks, including potential loss of federal funding.

Title VI – In 2025, the US Department of Education's Office for Civil Rights (OCR) spearheaded expansive Title VI investigations ranging from alleged preferential treatment to antisemitism, spanning undergraduate institutions, graduate programs, and law schools.
- Race-based scholarships: OCR targeted six institutions for impermissible race-based scholarships and one, New England College of Optometry, for allegedly operating a racially segregated program.⁷⁹ Additionally, one of the largest swaths of higher education investigations in 2025 involved institutions' partnerships with the PhD Project.⁸⁰
  OCR claimed that 45 schools engaged in "race-exclusionary practices" by partnering with the PhD Project, which helps students from underrepresented backgrounds—including, in large part, Black and Latino students—earn doctoral degrees.
- Deferred Action for Childhood Arrivals (DACA): Additionally, the government launched probes of five universities regarding DACA scholarships, emphasizing potential national origin discrimination concerns.⁸¹
- Antisemitism: Meanwhile, antisemitism enforcement intensified as OCR initiated investigations at 60 universities for allegedly failing to protect Jewish students.⁸² Five institutions—Columbia University, Northwestern University, Portland State University, University of California – Berkeley, and the University of Minnesota Twin Cities—were the subject of targeted probes. In addition, the bipartisan US Commission on Civil Rights (USCCR) launched a review of federal responses to campus antisemitism under both Presidents Biden and Trump, with a focus on adequacy and potential overreach.⁸³ The USCCR held public hearings in November 2025, and its report is expected by the end of 2026.⁸⁴
- Law Schools: OCR also launched an investigation into Duke University and the Duke Law Journal following reports that the journal used a points-based system to prefer applicants based on race or affinity group membership.⁸⁵ A similar investigation was also opened against Harvard University and the Harvard Law Review.⁸⁶ (And separately, private parties filed a lawsuit with similar allegations against Northwestern University's law school and its law review.⁸⁷)
Title VII – In September 2025, the Equal Employment Opportunity Commission (EEOC) announced it would close all pending charges based solely on claims of unintentional discrimination and would issue right‑to‑sue letters by October 31, 2025.⁸⁸ This marks a departure from prior priorities, which allowed for enforcement actions based on policies or practices that had a disproportionate adverse effect on members of a protected class under Title VII, even without evidence of intentional discrimination.
Title IX – Recent actions focus on the interpretation of "sex" in Title IX as referring to biological sex, particularly in the context of women's sports.
- Return of Trump-era Rules: The DOJ and the Department of Education also formed a Special Investigations Team to scrutinize policies allowing transgender women in female sports and facilities, warning that non-compliance could trigger funding cuts.⁸⁹ At the policy level, following a Kentucky federal court's ruling vacating Biden-era rules governing campus assault proceedings, institutions returned to Trump-era 2020 regulations, reinstating live hearings, cross-examination rights, and a narrower definition of sexual harassment.⁹⁰
- Investigations of State and Private Policies: Investigations occurred in Minnesota, where the Department of Education and the Department of Health and Human Services jointly concluded that the State of Minnesota (specifically, its Department of Education and State High School League) violated Title IX by allowing biological males to compete in female sports categories, citing specific instances in softball and skiing.⁹¹ Another investigation led to Wagner College in New York entering into a resolution agreement requiring it to adopt biology-based definitions of "male" and "female" after a female fencer forfeited a match against a biological male opponent.⁹² These investigations clarify that universities cannot delegate compliance to external athletic associations (i.e., the NCAA or conferences) if the association's rules conflict with the Department of Education's Title IX interpretation.

Within Congress, members have proposed bipartisan legislation to reinforce these executive actions, reflecting concern over discrimination and campus safety.⁹³ For universities, these developments create a need for comprehensive review of admissions, scholarship, and athletic policies to mitigate federal enforcement risk.

These investigations follow years of rhetoric from President Trump challenging race-conscious policies in higher education and, as Steptoe has previously written about, the Supreme Court's 2023 decision holding university race-based affirmative action programs as unconstitutional.

B. Heightened Federal Scrutiny of Campus Safety Under the Clery Act

The Department of Education initiated several reviews under the Clery Act and other safety-related mandates to ensure universities are accurately reporting crimes and maintaining safety protocols. The Act requires institutions to implement safety protocols, log and publish annual crime statistics, issue timely warnings and emergency notifications, and disclose campus safety policies to students and employees.⁹⁴As such, the Department launched a review of the University of California – Berkeley to investigate potential safety failures after it allegedly "allowed a protest of a Turning Point USA event on its grounds to turn unruly and violent."⁹⁵ Additionally, the Department announced a review of Brown University following a campus shooting, focusing on allegations of delayed emergency notifications and insufficient surveillance systems.⁹⁶

C. DOJ Launches "Civil Rights Fraud Initiative" to Apply False Claims Act to Higher Education

In May 2025, Deputy Attorney General Todd Blanche announced the launch of the "Civil Rights Fraud Initiative," announcing that DOJ would use the False Claims Act "against those who defraud the United States by taking its money while knowingly violating civil rights laws."⁹⁷ In line with other administration actions, Blanche highlighted antisemitism and transgender issues as the types of civil rights violations the initiative would target. Thus, universities accepting federal funds could face liability if they falsely certify compliance with statutes such as Title VI and Title IX while engaging in discriminatory practices.⁹⁸

The May 2025 announcement also "strongly encouraged" whistleblower lawsuits under 31 U.S.C. § 3730, which can yield treble damages and penalties.⁹⁹
It remains to be seen the extent to which potential whistleblowers—which, in the higher education context, could include students with firsthand knowledge of Title IV and Title IX violations on campus—have heeded the initiative's call.

D. Scrutinizing Relationships with China: Executive Order Intensifies Section 117 Enforcement and Foreign Gift Disclosure Requirements

In April 2025, the administration issued Executive Order 14282, "Transparency Regarding Foreign Influence at American Universities," mandating aggressive enforcement of Section 117 of the Higher Education Act¹⁰⁰ to deter Chinese influence in American academia.¹⁰¹ The order requires institutions to provide more detailed disclosures of foreign gifts and contracts.¹⁰² The order specifically emphasizes the repeal of prior policies that permitted secrecy, requiring universities to report such funding—"including the true source and purpose of the funds"—regardless of whether it comes directly from a foreign country or is routed through an intermediary. During the first Trump administration, institutions reported $6.5 billion in gifts and contracts.¹⁰³ Executive Order 14282 also emphasizes interagency coordination and warns that noncompliance could lead to liability under the FCA, exposing institutions to treble damages.¹⁰⁴

In furtherance of its policy objectives, the Department of Education issued new guidance to help colleges identify and mitigate foreign threats to research, such as espionage and intellectual property theft.¹⁰⁵ To facilitate enforcement, the Department of Education launched a new reporting portal designed to streamline compliance and improve transparency.¹⁰⁶

At the same time, the Department initiated investigations into four universities, Harvard University, the University of Pennsylvania, University of Michigan, and the University of California – Berkeley, for alleged Section 117 violations.¹⁰⁷ The investigations include requests for communications and records related to foreign governments, information on expelled foreign students or personnel, email accounts, and research funding information.¹⁰⁸ Similarly, the Department began investigating the University of Michigan regarding inaccurate foreign funding disclosures.¹⁰⁹ The government alleged Michigan failed to disclose certain foreign contracts and partnerships, alluding to potential sabotage and "agroterrorism" by "Chinese nationals affiliated" with the university.¹¹⁰

As seen elsewhere, Congress has signaled support for detecting and deterring foreign influence in higher education through proposed legislation aimed at reinforcing disclosure requirements for institutions that receive gifts from foreign countries, particularly China.¹¹¹ The DETERRENT Act and the Disclose GIFT Act would require particular faculty and staff to report foreign gifts and contracts, and require institutions to maintain searchable public databases. The DETERRENT Act also includes broader institution-level reporting requirements, lower reporting thresholds, and a prohibition of contracts from foreign countries or entities of concern entirely. Further, both bills authorize DOJ enforcement and impose significant fines for repeat noncompliance, including a two-year revocation of Title IV status. The DETERRENT Act passed the House and awaits Senate action, while the Disclose GIFT Act remains in the House Education and Workforce Committee.

While the administration has yet to take much action surrounding exports and sanctions involving higher education, its 2025 Mandate for Leadership outlines a plan to enact legislation to strengthen export controls, including "tightening the definition of ‘fundamental research' to prevent exploitation of the open US university system by authoritarian governments through funding, students and researchers, and recruitment."¹¹²

See more from Steptoe here and here.

E. Criminal Indictments Highlight Federal Scrutiny of Educational Research and Medical Facilities

Former Harvard Medical School morgue manager Cedric Lodge was sentenced to eight years in prison in December 2025 for stealing and selling human remains, a scheme prosecutors said spanned multiple states. His wife, Denise Lodge, received a sentence of one year and one day for transporting stolen remains across state lines.¹¹³

We also saw a new enforcement trend emerge in 2025 against academics bringing certain biological specimens into the US illegally. Harvard Medical School researcher Kseniia Petrova, a Russian citizen, was indicted on charges of smuggling biological materials (frog embryos) into the US, concealing material facts, and making false statements to federal authorities. Petrova faces potential prison sentences of up to 20 years if convicted.¹¹⁴ Additionally, three research scholars at the University of Michigan who are Chinese nationals were charged with conspiring to smuggle biological materials related to roundworms into the US and making false statements to Customs and Border Protection.¹¹⁵

Although the specimens at issue in these actions do not pose any overt public health threat, it is clear that through these charges, the DOJ is trying to send the message that attempts to bring any biological or bacterial specimens that could pose a public health threat will be detected and met with aggressive charging and high penalties. The DOJ's focus on non-citizen researchers from China and Russia may also suggest that the indictments in this area tie into the administration's immigration and national security agendas.

F. Potential Expansion of IRS Authority to Challenge Tax-Exempt Status Over Institutional DEI Policies

In January 2025, President Trump issued an executive order directing agencies to eliminate "illegal" DEI practices and ensure compliance, particularly in schools and universities, entitled "Ending Illegal Discrimination and Restoring Merit-Based Opportunity."¹¹⁶ In addition to the "no illegal" certifications sought by agencies from colleges and universities performing work under federal contracts or grants, we expect there to be audits sought and opened against institutions as 501(c)(3) entities based on allegations that their policies violate public policy under the rationale articulated in Bob Jones University v. United States, 461 U.S. 574 (1983).

After Harvard publicly criticized the administration, President Trump publicly scrutinized its 501(c)(3) status, as well as that of Princeton University and Columbia University.¹¹⁷ Revocation at Harvard alone would jeopardize billions annually in savings from untaxed endowment earnings, donor tax deductions, and state and local tax exemptions, thereby reducing funds for research, financial aid, services, and hiring. But while no official revocation has occurred, universities face heightened risk of IRS audits, lengthy review procedures, and multi-tiered appeals, including internal IRS review processes and potential litigation before any loss of exemption becomes final.¹¹⁸ Institutions should therefore proactively assess DEI-related policies to mitigate exposure.

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VI. Internal Investigations

Publicly reported internal investigations conducted by IHEs in 2025 touched on a broad range of topics, including plagiarism, AI, and harassment. While changes to the student-athlete landscape, antitrust litigation, and governmental investigations may have occupied the headlines, internal investigations remain an important part of university governance.

A. Plagiarism

In January 2025, Michigan State University cleared the Dean of the College of Education, Jerlando Jackson, of the plagiarism charges leveled against him after conducting an internal investigation.¹¹⁹In April 2025, the director of the Center for Antiracism Research for Health Equity at the University of Minnesota stepped down after her colleague accused the director of plagiarism in a grant application to the National Institutes of Health.¹²⁰

In December 2025, the University System of Maryland concluded a year-long internal investigation into President Darryll Pines, president of University of Maryland, College Park.¹²¹ After President Pines was accused of plagiarism, the university system hired a law firm to review his publications and determine if he had engaged in misconduct. The firm concluded he had not. Two of his works "contained select portions of text previously published by another author in the introductory sections," but this was merely "a discrepancy in assignment of authorship."¹²²

B. Artificial Intelligence

Artificial intelligence continues to be a hot topic for IHE internal investigations, especially related to academic integrity. The University of Georgia reported that over half of the academic honesty violations in the 2024-25 school year were alleged to be related to the improper use of AI.¹²³

C. Alleged Misconduct and Harassment

In February 2025, University of Virginia (UVA) Health CEO Dr. Craig Kent resigned following a months-long independent investigation into allegations of misconduct and leadership failures.¹²⁴ The probe was prompted by a September 2024 "no confidence" letter signed by 128 faculty physicians, alleging Kent's leadership had fostered a culture of fear and retaliation while compromising patient safety.

In early 2025, an internal investigation conducted by an outside law firm concluded that while some conduct within a University of Washington research lab was inappropriate, it was not serious enough to be considered harassment.¹²⁵ The probe was launched after women in the lab alleged that the lab was a hostile work environment because of gender-based harassment, discrimination, and sexual harassment. A few men in the lab had counterclaimed that they were being retaliated against.

In May 2025, reports surfaced regarding an internal investigation into Squadron 17 of the Corps of Cadets at Texas A&M University.¹²⁶ And in September, the university also suspended its chapter of the Kappa Sigma fraternity following severe hazing allegations involving forced physical exertion.¹²⁷

D. Academic Expression

In 2025, Indiana University sanctioned Professor Marcus Croom after an investigation "found he violated the university's discrimination policy by fostering a hostile environment for white students."¹²⁸ The probe stemmed from a 2024 complaint by a former student who alleged that Croom made numerous discriminatory comments during course instruction. As a result, Croom received a "level one" sanction requiring professional development training and a permanent letter in his personnel file. Indiana University also sanctioned Germanic Studies Professor Ben Robinson for violating Senate Enrolled Act 202, which forbids professors from engaging in political discussions unrelated to their academic discipline and failing to provide a range of political viewpoints.¹²⁹ The complaint that initiated the investigation alleged Robinson had improperly discussed his views that the university was restricting free speech rights, his experiences being arrested while protesting, and his opinions on Israel.¹³⁰

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VII. Congressional Investigations

Congressional inquiries and investigations into IHEs continued in the aftermath of the widely reported hearings that led to the termination of the Presidents of Harvard and University of Pennsylvania in 2025. Congress focused on institutional responses to antisemitism, institutional collaboration with China and the Chinese Communist Party (CCP), IHE's promotion of DEI policies, and whether university programs were being used as vehicles for political advocacy. Colleges and universities are likely to remain a key focus of Congress.

A. Continued Investigations into Institutional Responses to Antisemitism

In 2025, House Republicans continued to launch wide-ranging investigations into whether IHEs were meeting their Title IV obligations to protect Jewish students against antisemitism. A theme throughout these investigations was whether universities should receive federal funds if they are unable to meet Title IV obligations. The Republican-led House Education and Workforce Committee, led by Chairman Tim Walberg (R-MI), launched investigations into colleges and universities, including medical schools, for failure to respond to incidents of alleged antisemitism and requested incident response records for such incidents.¹³¹ The University of Illinois Chicago and the University of California — San Francisco received identical letters and both issued statements condemning antisemitism and representing cooperation with the Committee's requests.¹³²

On March 27, 2025, the House Committee on Education and the Workforce also requested that universities provide detailed disciplinary records for students and faculty involved in incidents of alleged antisemitism. Chairman Walberg (R-MI) challenged the adequacy of the universities' responses, calling them "lackluster."¹³³ Bowdoin University, which was investigated for its handling of student encampments, refused to provide individual student data, citing the Family Educational Rights and Privacy Act, and instead provided overarching disciplinary data to the Committee.¹³⁴ The Committee also investigated a legal clinic at Northwestern University because it provided free legal representation to pro-Palestine protesters.¹³⁵ The Committee requested copies of the clinic's written policies and funding sources. The investigation was ultimately dropped after the clinic director sued the Committee, alleging the investigation violated their clients' constitutional rights.¹³⁶

B. Collaboration with China and the Chinese Communist Party

The House Committee on Oversight and Government Reform, led by Chairman James Comer (R-KY), inquired into foreign funding of higher education institutions, particularly the Department of Education's handling of transparency reporting under Section 117, which requires colleges and universities to disclose gifts and contracts from foreign sources. Concern over Section 117 enforcement has persisted from 2024 and the first Trump administration before that. On February 19, 2025, Chairman Comer (R-KY) and Congresswoman Virginia Foxx (R-NC) requested the then Acting Secretary of the Department of Education, Denise Carter, to provide documents and information regarding the Department's enforcement of disclosures under Section 117, stating that enforcement has been lax since the Biden administration.¹³⁷

Relationships with China and the CCP also received congressional scrutiny in 2025. The House Select Committee on the Strategic Partnership Between the United States and the CCP (House Select Committee), led by Chairman John Moolenaar (R-MI), investigated the enrollment of Chinese international students at American universities, their involvement with federally funded research, and the security of sensitive technologies developed on campus. The investigation culminated in two reports published by the House Select Committee, which found that these partnerships pose national security risks.¹³⁸

The House Committee on Education and the Workforce, alongside the House Select Committee, asked universities to end joint programs with Chinese organizations and universities. In response, eight universities, including Georgia Tech, University of California – Berkeley, University of Michigan, University of Pittsburgh, Oakland University, University of Detroit Mercy, Eastern Michigan University, and University of Illinois, ended their partnerships with Chinese programs and universities.¹³⁹ The Committees called out thirteen other universities that "failed to act."¹⁴⁰

C. DEI Initiatives on College Campuses

DEI policies, programs, and initiatives at colleges and universities remained a key issue for Congress throughout 2025. The House Committee on the Judiciary, led by Chairman Jim Jordan (R-OH); the House Committee on Oversight and Government Reform, led by Chairman James Comer (R-KY); and the House Committee on Education and Workforce, led by Chairman Tim Walberg (R-MI), all launched investigations into higher education institutions' compliance with civil rights laws regarding their DEI policies in admissions and hiring and employment practices.

The House Judiciary Committee scrutinized "illegal DEI" practices at George Mason University (GMU) and published a 50-page report alleging that the university "likely violated federal civil rights laws" by utilizing racially discriminatory hiring practices to advance DEI initiatives led by GMU's president.¹⁴¹

The House Committee on Oversight and Government Reform and the House Committee on Education and the Workforce both probed Harvard University for its alleged violations of civil rights laws. The Committee on Education and the Workforce took issue with Harvard's alleged noncompliance with the Supreme Court's decision in Students for Fair Admissions,¹⁴² which held that race-conscious affirmative action in college admissions is unconstitutional. The Committee on Education and Workforce argued that Harvard continued to unlawfully consider race in its hiring practices.¹⁴³ Meanwhile, the House Oversight Committee scrutinized Harvard's use of federal funds to advocate for "illegal discrimination" and violate civil rights laws.¹⁴⁴

D. University Programs as a Vehicle for Political Advocacy

Congress also took issue with university programs acting as a vehicle for political advocacy. The House Oversight Committee investigated New York University School of Law's State Energy and Environmental Impact Center (State Impact Center) for its ties with offices of Democratic state attorneys general. Chairman James Comer (R-KY) alleged that the State Impact Center, which was established by Bloomberg Philanthropies and places fellows at state attorneys general offices, raises "ethical concerns and questions about the independence of state governments."¹⁴⁵ Meanwhile, the House Committee on Foreign Affairs, led by Chairman Brian Mast (R-FL), demanded that Boston University implement safeguards to prevent federally funded research from being used as a vehicle for political advocacy.¹⁴⁶ This inquiry arose after Boston University published a dashboard explaining the tangible impacts of federal funding changes, including the closure of USAID.

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VIII. Conclusion

The 2025 developments in higher education underscore a new reality: regulatory risk is no longer episodic or siloed but systemic and persistent. Federal enforcement and regulatory agencies have made it a clear priority to deploy executive authority, funding controls, civil rights enforcement, and general scrutiny to influence institutions of higher education at every level, including governance, operations, academic policy, and cultural priorities. Likewise, Congress has reinforced these efforts through sustained investigative pressure and legislative proposals targeting the education sector.

For institutions of higher education, the implications of this shift are significant. Colleges and universities should expect continued enforcement intensity, evolving legal theories, and further convergence between policy objectives and regulatory action. Successfully navigating this landscape will require institutions to reassess governance structures, strengthen compliance infrastructures, and approach strategic decision‑making with an eye toward accountability, transparency, and risk management. In this environment, institutions that proactively adapt will be best positioned to preserve the autonomous pursuit of their educational missions. Our ongoing coverage of 2026 developments will continue here.

¹ Exec. Order 14173, 90 Fed. Reg. 8633 (Jan. 21, 2025), https://www.govinfo.gov/content/pkg/FR-2025-01-31/pdf/2025-02097.pdf.

² Id. § 1.

³Id. §§ 3(b)(iv), 4(b).

⁴ Id. § 4(b).

⁵ Id. §§ 4(b), 7.

⁶ Memorandum from Pamela Bondi, US Att'y Gen., to US Dep't of Just. (Feb. 5, 2025), https://www.justice.gov/ag/media/1388501/dl?inline.

⁷ What to Do If You Experience Discrimination Related to DEI Work, US Equal Opportunity Comm'n, https://www.eeoc.gov/what-do-if-you-experience-discrimination-related-dei-work (accessed Feb. 25, 2026).

⁸ US Equal Employment Opportunity Commission, What You Should Know About DEI‑Related Discrimination at Work, US Equal Opportunity Comm'n, https://www.eeoc.gov/wysk/what-you-should-know-about-dei-related-discrimination-work (accessed Feb. 25, 2026).

⁹ What to Do If You Experience Discrimination Related to DEI Work, US Equal Opportunity Comm'n, https://www.eeoc.gov/what-do-if-you-experience-discrimination-related-dei-work (accessed February 25, 2026).

¹⁰ Exec. Order 14279, 89 Fed. Reg. 57454 (Apr. 28, 2025), https://www.govinfo.gov/content/pkg/FR-2025-04-28/pdf/2025-07376.pdf.

¹¹ Id. § 1.

¹² Id. §§ 1, 2.

¹³ Id. § 2(b).

¹⁴ Brittney Denley, President Trump's Federal Grant Freeze and Higher Education, Steptoe LLP (Feb. 28, 2025), https://www.steptoe.com/en/news-publications/president-trumps-federal-grant-freeze-and-higher-education.html; Patrick F. Linehan, Universities Face Full Funding Freezes Amid Trump Administration Demands, Steptoe LLP (Apr. 25, 2025), https://www.steptoe.com/en/news-publications/universities-face-full-funding-freezes-amid-trump-administration-demands.html.

¹⁵ Id.

¹⁶ Id.

¹⁷ Id.

¹⁸ Id.

¹⁹ Id.

²⁰Id.

²¹ Id.

²² Id.

²³ Press Release, EEOC, $21 Million Payout Process Begins in Columbia University Antisemitism Settlement with EEOC (Dec. 4, 2025), https://www.eeoc.gov/newsroom/21-million-payout-process-begins-columbia-university-antisemitism-settlement-eeoc; Edward Simon Cruz and Yong-Yu Huang, The Daily Explains: How Northwestern's deal compares to other university agreements with Trump administration, The Daily Northwestern (Nov. 29, 2025), https://dailynorthwestern.com/2025/11/29/campus/the-daily-explains-how-northwesterns-deal-compares-to-other-university-agreements-with-trump-administration/.

²⁴ Cruz and Huang, The Daily Explains: How Northwestern's deal compares to other university agreements with Trump administration, The Daily Northwestern, https://dailynorthwestern.com/2025/11/29/campus/the-daily-explains-how-northwesterns-deal-compares-to-other-university-agreements-with-trump-administration/.

²⁵ Id.; Elissa Nadworny and Jordan Owens, What we know about Columbia's $221 million settlement with the Trump administration, NPR (July 25, 2025), https://www.npr.org/2025/07/25/nx-s1-5479240/columbia-trump-administration-settlement-details.

²⁶ Elissa Nadworny and Jordan Owens, What we know about Columbia's $221 million settlement with the Trump administration, NPR, https://www.npr.org/2025/07/25/nx-s1-5479240/columbia-trump-administration-settlement-details; Cruz & Huang, The Daily Explains: How Northwestern's deal compares to other university agreements with Trump administration, The Daily Northwestern, https://dailynorthwestern.com/2025/11/29/campus/the-daily-explains-how-northwesterns-deal-compares-to-other-university-agreements-with-trump-administration/.

²⁷ Lexi Lonas Cochran, Harvard in ‘much more powerful position' against Trump after funding ruling, The Hill (Sept. 5, 2025), https://thehill.com/homenews/education/5486763-harvard-trump-funding-fight/.

²⁸ Alex Wolf, White House Looks to Seize Control of Higher Education Policy Through "Compact for Academic Excellence in Higher Education," Steptoe LLP (Oct. 23, 2025), https://www.steptoe.com/en/news-publications/white-house-looks-to-seize-control-of-higher-education-policy-through-compact-for-academic-excellence-in-higher-education.html.

²⁹ Id.

³⁰ Id.

³¹ Id.

³² Id.

³³ Tyler Evans, Update on the Compact for Academic Excellence in Higher Education, Steptoe LLP (Nov. 12, 2025), https://www.steptoe.com/en/news-publications/update-on-the-compact-for-academic-excellence-in-higher-education.html.

³⁴ Id.; see also Katherine Knott, St. Augustine's Offers to Help Shape Trump's Compact, Inside Higher Ed (Nov. 21, 2025), https://www.insidehighered.com/news/quick-takes/2025/11/21/st-augustines-offers-help-shape-trumps-compact.

³⁵ Katherine Knott, St. Augustine's Offers to Help Shape Trump's Compact, Inside Higher Ed (Nov. 21, 2025), https://www.insidehighered.com/news/quick-takes/2025/11/21/st-augustines-offers-help-shape-trumps-compact.

³⁶ Katherine Knott, Trump Signs "Big, Beautiful Bill" into Law Ushering in New Era for Higher Ed, Inside Higher Ed (July 4, 2025), https://www.insidehighered.com/news/government/politics-elections/2025/07/04/big-beautiful-bill-means-big-changes-higher-ed.

³⁷ Id.

³⁸ Id.

³⁹ In re Coll. Athlete NIL Litig., 803 F. Supp. 3d 959, 970 (N.D. Cal. 2025), appeal dismissed, No. 25-4185, 2025 WL 2831020 (9th Cir. July 29, 2025), and objections overruled, No. 20-CV-03919 CW, 2025 WL 3501920 (N.D. Cal. Nov. 13, 2025).

⁴⁰ David Purdum, NCAA: Ex-Temple Men's Basketball Player Bet Against Own Team, ESPN (Nov. 21, 2025), https://www.espn.com/mens-college-basketball/story/_/id/47049132/ncaa-former-temple-men-basketball-player-bet-team.

⁴¹ Meghan Durham Wright, 6 Former Men's Basketball Student-Athletes Committed NCAA Violations Involving Betting-Related Game Manipulation, NCAA Media Center (Nov. 7, 2025), https://www.ncaa.org/news/2025/11/7/media-center-6-former-mens-basketball-student-athletes-committed-ncaa-violations-involving-betting-related-game-manipulation.aspx.

⁴² David Purdum, NCAA: Ex-Temple Men's Basketball Player Bet Against Own Team, ESPN (Nov. 21, 2025), https://www.espn.com/mens-college-basketball/story/_/id/47049132/ncaa-former-temple-men-basketball-player-bet-team.

⁴³ Meghan Durham Wright, Former San Francisco Men's Basketball Student-Athlete Violated Sports Betting Rules, NCAA Media Center (Dec. 10, 2025), https://www.ncaa.org/news/2025/12/10/media-center-former-san-francisco-mens-basketball-student-athlete-violated-sports-betting-rules.aspx.

⁴⁴ Meghan Durham Wright, 3 Former Eastern Michigan Men's Basketball Student-Athletes Did Not Cooperate with Investigation into Potential Sports Betting Conduct, NCAA Media Center (Oct. 24, 2025), https://www.ncaa.org/news/2025/10/24/media-center-3-former-eastern-michigan-mens-basketball-student-athletes-did-not-cooperate-with-investigation-into-potential-sports-betting-conduct.aspx.

⁴⁵ Doug Feinberg, NCAA Will Allow College Athletes to Bet on Professional Sports Starting Nov. 1, Assoc. Press (Oct. 23, 2025), https://apnews.com/article/ncaa-college-athletes-pro-sports-betting-7e34635dd4738fe9ad7393bc1301ca41.

⁴⁶ Doug Feinberg, NCAA Won't Allow Athletes or Athletic Department Staff to Bet on Pro Sports Amid Gambling Scandals, Assoc. Press (Nov. 21, 2025), https://apnews.com/article/ncaa-gambling-pro-sports-vote-2f092726cc0b44d9881b91d7356a1ee3.

⁴⁷ SCORE Act, H.R. 4312, 119th Congress (2025), https://www.congress.gov/bill/119th-congress/house-bill/4312.

⁴⁸ SAFE Act, S. 2932, 119th Congress (2025), https://www.congress.gov/bill/119th-congress/senate-bill/2932; Press Release, US S. Comm. on Com., Sci., & Transp., Senators Cantwell, Booker & Blumenthal Introduce Student Athlete Fairness & Enforcement (SAFE) Act (Sept. 29, 2025), https://www.commerce.senate.gov/2025/9/senators-cantwell-booker-blumenthal-introduce-student-athlete-fairness-enforcement-safe-act.

⁴⁹ CARA Act, H.R. 6350, 119th Congress (2025), https://www.congress.gov/bill/119th-congress/house-bill/6350; Press Release, Rep. Lori Trahan, Trahan to Introduce College Athletics Reform Act (Dec. 1, 2025), https://trahan.house.gov/news/documentsingle.aspx?DocumentID=3689.

⁵⁰ H.R. 5693, 119th Congress (2025), https://www.congress.gov/bill/119th-congress/house-bill/5693; Cami Mondeaux, University of Utah Athletics Private Equity Deal Catches the Attention of Congress, KSL (Dec. 16, 2025), https://www.ksl.com/article/51419673/university-of-utah-athletics-private-equity-deal-catches-the-attention-of-congress.

⁵¹ Id.

⁵² Dennis Romboy, University of Utah unveils first-of-its-kind revenue plan for athletics department, Deseret News (Dec. 9, 2025), https://www.deseret.com/sports/2025/12/09/university-utah-college-sports-private-equity-deal-nil-football/.

⁵³ Steve Bartle, Utah Turned to Private Equity — The Next Era of Athletic Funding?, KSL Sports (Dec. 16, 2025), https://kslsports.com/ncaa/utah/utah-private-equity-rev-nil/567140.

⁵⁴ Steve Bartle, Utah Turned to Private Equity — The Next Era of Athletic Funding?, KSL Sports (Dec. 16, 2025), https://kslsports.com/ncaa/utah/utah-private-equity-rev-nil/567140.

⁵⁵ Ralph D. Russo and Stewart Mandel, UC Investments Puts $2.4 Billion Big Ten Deal on Hold Amid Pushback from Michigan and USC, The Athletic (Nov. 17, 2025), https://www.nytimes.com/athletic/6815788/2025/11/17/uc-investments-puts-2-4-billion-big-ten-deal-on-hold-amid-pushback-from-michigan-and-usc/.

⁵⁶ Pete Thamel and Dan Wetzel, Proposed Big Ten Private Capital Deal in Holding Pattern, ESPN (Oct. 16, 2025),

https://www.espn.com/college-sports/story/_/id/46620086/proposed-big-ten-private-capital-deal-holding-pattern.

⁵⁷ Justin Williams and Matt Baker, Big 12 Negotiating Capital Partnership That Would Allow Schools to Opt in to More Funding: Sources, The Athletic (Dec. 12, 2025), https://www.nytimes.com/athletic/6885987/2025/12/12/big-12-conference-business-partnerships/.

⁵⁸ Press Release, Mich. State U., NCAA and Michigan State Reach Negotiated Resolution (Nov. 12, 2025), https://msuspartans.com/news/2025/11/12/general-ncaa-and-michigan-state-reach-negotiated-resolution; NCAA Div. I Comm. on Infractions, Michigan State University Public Infractions Decision (Nov. 12, 2025), https://web3.ncaa.org/lsdbi/search/miCaseView/report?id=103151.

⁵⁹ Jake Trotter, MSU Gets 3-Year Probation; 14 Wins From 3 Seasons Vacated, ESPN (Nov. 12, 2025), https://www.espn.com/college-football/story/_/id/46944587/msu-hit-3-yr-probation-14-wins-3-seasons-vacated.

⁶⁰ Jake Curtis, Cal Football Receives Probation, Fine, Suspensions for NCAA Violations, Sports Illustrated (May 5, 2025), https://www.si.com/college/cal/football/cal-football-receives-probation-fine-suspensions-for-ncaa-violations-01jth9pzv4zt; NCAA Div. I Comm. on Infractions, Case Summary, Recruiting Violations Occurred in California Football Program, https://web3.ncaa.org/lsdbi/search/miCaseView/report?id=103109.

⁶¹ OSU Women's Tennis Program Receives 3-Year Probation for Recruiting Violations, The O'Colly (July 4, 2025), https://www.ocolly.com/sports/tennis/osu-womens-tennis-program-receives-3-year-probation-for-recruiting-violations/article_c19078c4-fda3-4987-90ad-d33494a46db0.html.

⁶² Ralph D. Russo and Chris Vanini, Brian Kelly Files Lawsuit Against LSU Alleging School Wants to Fire Him For Cause, The Athletic (Nov. 11, 2025), https://www.nytimes.com/athletic/6796896/2025/11/11/brian-kelly-lsu-lawsuit/.

⁶³ Pete Thamel, Sources: LSU Fires Brian Kelly Without Cause, Owes Buyout, ESPN (Nov. 26, 2025), https://www.espn.com/college-football/story/_/id/47113365/lsu-officially-terminates-football-coach-brian-kelly-cause.

⁶⁴ David Ubben, Kansas State says Jerome Tang's Words Cost Him His Job. Do His Comments Justify It?, The Athletic (Feb. 18, 2026), https://www.nytimes.com/athletic/7053723/2026/02/18/kansas-state-jerome-tang-fired-for-cause/.

⁶⁵ Nate Raymond, Settlements Near $320 Mln in College-Aid Lawsuit After Caltech, Johns Hopkins Deals, Reuters (Jan. 20, 2025), https://www.reuters.com/legal/litigation/settlements-near-320-mln-college-aid-lawsuit-after-caltech-johns-hopkins-deals-2025-01-20/.

⁶⁶ Id.

⁶⁷ Id.

⁶⁸ Hansen v. Nw. U., 2025 WL 2731378, No. 24-C-9667 (N.D. Ill. Sept. 24, 2025).

⁶⁹ Id. at *1

⁷⁰Class Action Compl., D'Amico v. Consortium on Financing Higher Education, 1:25-cv-12221-JDH (D. Mass. Aug. 8, 2025). Steptoe represents the Common Application in the pending litigation.

⁷¹ Id at 6.

⁷² Compl., Risner v. Law School Admission Council, Inc., 2:25-cv-04461-JFM (E.D. Pa. Aug. 4, 2025).

⁷³ Id.

⁷⁴ Id.

⁷⁵ Press Release, US H. Comm. on the Judiciary, Chairmen Jordan, Grassley, Fitzgerald, and Lee Demand Information from Ivy League Schools (Apr. 10, 2025), https://judiciary.house.gov/media/press-releases/chairmen-jordan-grassley-fitzgerald-and-lee-demand-information-ivy-league.

⁷⁶ Id.

⁷⁷ Dhruv T. Patel and Grace E. Yoon, House Judiciary Committee Subpoenas Harvard for Financial Aid Documents in Ivy League Antitrust Probe, The Harvard Crimson (Jun. 27, 2025), https://www.thecrimson.com/article/2025/6/27/harvard-antitrust-subpoena/.

⁷⁸ House Republicans Escalate Ivy League Price-Fixing Probe, Insight on Academia (Jul. 2, 2025), https://insightintoacademia.com/ivy-league-price-fixing-probe/.

⁷⁹ Press Release, US Dep't of Educ., Office for Civil Rights Initiates Title VI Investigations into Institutions of Higher Education (Mar. 14, 2025), https://www.ed.gov/about/news/press-release/office-civil-rights-initiates-title-vi-investigations-institutions-of-higher-education.

⁸⁰ Juliana Khan, Over 50 Universities are Under Investigation as Part of Trump's Anti-DEI Crackdown, NPR (Mar. 14, 2025), https://www.npr.org/2025/03/14/g-s1-53831/dei-universities-education-department-investigation.

⁸¹ Press Release, US Dep't of Educ., US Department of Education Opens Investigations into Five Universities for Alleged Exclusionary Scholarships Benefitting Illegal Alien Students (July 23, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-opens-investigations-five-universities-alleged-exclusionary-scholarships-benefitting-illegal-alien-students.

⁸² Press Release, US Dep't of Educ., US Department of Education's Office for Civil Rights Sends Letters to 60 Universities Under Investigation for Antisemitic Discrimination and Harassment (Mar. 10, 2025), https://www.ed.gov/about/news/press-release/us-department-of-educations-office-civil-rights-sends-letters-60-universities-under-investigation-antisemitic-discrimination-and-harassment.

⁸³ David Hood-Nuño and Sarah N. Lynch, Exclusive: US civil rights agency opens sweeping antisemitism probe, Reuters (Oct. 6, 2025), https://www.reuters.com/legal/government/us-civil-rights-agency-opens-sweeping-antisemitism-probe-2025-10-06/.

⁸⁴ Id.

⁸⁵ Press Release, US Dep't of Educ., US Department of Education Initiates Investigation into Duke University and Duke Law Journal (July 28, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-initiates-investigation-duke-university-and-duke-law-journal.

⁸⁶ Press Release, US Dep't of Educ., ED, HHS Launch Title VI Investigations of Harvard University and Harvard Law Review Amid Allegations of Discriminatory Practices (Apr. 28, 2025), https://www.ed.gov/about/news/press-release/ed-hhs-launch-title-vi-investigations-of-harvard-university-and-harvard-law-review-amid-allegations-of-discriminatory-practices.

⁸⁷ Julianne Hill, Conservative group sues Northwestern University law school for alleged hiring discrimination against white men, ABA J. (July 3, 2024), https://www.abajournal.com/web/article/conservative-group-sues-northwestern-law-school-for-hiring-discrimination.

⁸⁸ Rebecca Klar, EEOC to Close Workers' Disparate Impact Job Bias Charges, Bloomberg (Sept. 19, 2025), https://news.bloomberglaw.com/daily-labor-report/eeoc-to-close-workers-disparate-impact-discrimination-charges.

⁸⁹ Press Release, US Dep't of Educ., U.S Department of Education and US Department of Justice Announce Title IX Special Investigations Team (Apr. 4, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-and-us-department-of-justice-announce-title-ix-special-investigations-team; see Exec. Order No. 14201, 90 Fed. Reg. 9279 (Feb. 11, 2025), https://www.govinfo.gov/content/pkg/FR-2025-02-11/pdf/2025-02513.pdf.

⁹⁰ Collin Binkley, US colleges returning to campus sexual assault rules created during Trump's first term, Assoc. Press (Jan. 31, 2025), https://apnews.com/article/title-ix-trump-lgbtq-sex-assault-b7b6ad1cbe28331ce38ef896e6d4fd2b.

⁹¹ Press Release, US Dep't of Educ., US Department of Education and US Department of Health and Human Services Find that Minnesota Violated Title IX (Sept. 30, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-and-us-department-of-health-and-human-services-find-minnesota-violated-title-ix.

⁹² Press Release, US Dep't of Educ., US Department of Education Announces Wagner College Has Entered into a Resolution Agreement to Resolve its Title IX Concerns (Aug. 1, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-announces-wagner-college-has-entered-resolution-agreement-resolve-its-title-ix-concerns.

⁹³ Press Release, US Sen. Comm. on Health, Educ., Lab. & Pensions, Chair Cassidy, Fetterman Reintroduce Bill to Protect Students from Antisemitism, Discrimination on College Campuses (Jan. 21, 2025), https://www.help.senate.gov/rep/newsroom/press/chair-cassidy-fetterman-reintroduce-bill-to-protect-students-from-antisemitism-discrimination-on-college-campuses; Press Release, Sen. Jacky Rosen, Rosen, Scott Introduce Antisemitism Awareness Act (Feb. 13, 2025), https://www.rosen.senate.gov/2025/02/13/rosen-scott-introduce-antisemitism-awareness-act/.

⁹⁴See Jeanne Clery Campus Safety Act, 20 U.S.C. § 1092(f).

⁹⁵ Press Release, US Dep't of Educ., US Department of Education Initiates Review of University of California, Berkeley for Potential Clery Act Violations (Nov. 25, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-initiates-review-of-university-of-california-berkeley-potential-clery-act-violations.

⁹⁶ Press Release, US Dep't of Educ., US Department of Education Announces Review of Brown University for Potential Clery Act Violations (Dec. 22, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-announces-review-of-brown-university-potential-clery-act-violations.

⁹⁷ Memorandum from Todd Blanche, Dep'y Att'y Gen., to US Dep't of Just. (May 19, 2025), https://www.justice.gov/dag/media/1400826/dl?inline; see Patrick F. Linehan and Karima Malone, US Launches Unit to Target DEI Policies at Colleges and Other Federal Contractors and Grantees with Civil Fraud Probes, Steptoe LLP (June 30, 2025), https://www.steptoe.com/en/news-publications/us-launches-unit-to-target-dei-policies-at-colleges-with-civil-fraud-probes.html.

⁹⁸ Memorandum from Todd Blanche, Dep'y Att'y Gen., to US Dep't of Just. (May 19, 2025), https://www.justice.gov/dag/media/1400826/dl?inline.

⁹⁹ Id.

¹⁰⁰ Exec. Order No. 14282, § 1, 90 Fed. Reg. 17541, 17541 (Apr. 23, 2025), https://www.govinfo.gov/content/pkg/FR-2025-04-28/pdf/2025-07379.pdf.

¹⁰¹ See Patrick F. Linehan, Foreign Influence in Higher Ed: New Federal Guidance and Congressional Scrutiny, Steptoe LLP (Sept. 30, 2025), https://www.steptoe.com/en/news-publications/foreign-influence-in-higher-ed-new-federal-guidance-and-congressional-scrutiny.html.

¹⁰² Exec. Order No. 14282, § 2(b), 90 Fed. Reg. at 17541, https://www.govinfo.gov/content/pkg/FR-2025-04-28/pdf/2025-07379.pdf.

¹⁰³ Elizabeth Redden, Foreign Gift Investigations Expand and Intensify, Inside Higher Ed (Feb. 19, 2020), https://www.insidehighered.com/news/2020/02/20/education-department-escalates-inquiry-reporting-foreign-gifts-and-contracts.

¹⁰⁴ Exec. Order No. 14282, § 3, 90 Fed. Reg. at 17541–2, https://www.govinfo.gov/content/pkg/FR-2025-04-28/pdf/2025-07379.pdf.

¹⁰⁵ Press Release, US Dep't of Educ., US Department of Education, Federal Partners Issue Guidance to Help Colleges and Universities Mitigate Foreign Threats to Research (Aug. 25, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-federal-partners-issue-guidance-help-colleges-and-universities-mitigate-foreign-threats-research.

¹⁰⁶ Press Release, US Dep't of Educ., US Department of Education Announces New and Improved Portal for Universities to Report Foreign Funding (Dec. 1, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-announces-new-and-improved-portal-universities-report-foreign-funding.

¹⁰⁷ Id.

¹⁰⁸ See e.g., Press Release, US Dep't of Educ., US Department of Education Initiates Records Request from Harvard University After Discovering Inaccurate Foreign Financial Disclosures (Apr. 18, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-initiates-records-request-harvard-university-after-discovering-inaccurate-foreign-financial-disclosures.

¹⁰⁹ Press Release, US Dep't of Educ., US Department of Education Opens Foreign Funding Investigation into the University of Michigan (July 15, 2025), https://www.ed.gov/about/news/press-release/us-department-of-education-opens-foreign-funding-investigation-university-of-michigan.

¹¹⁰ Id.

¹¹¹ See DETERRENT Act, H.R. 1048, 119th Cong. (2025), https://www.congress.gov/bill/119th-congress/house-bill/1048; Disclose GIFT Act, H.R. 1999, 119th Cong. (2025), https://www.congress.gov/bill/119th-congress/house-bill/1999.

¹¹² Heritage Fdn., Mandate for Leadership 625 (2025), https://static.heritage.org/project2025/2025_MandateForLeadership_FULL.pdf.

¹¹³ Phillip Bantz, Ex-Harvard Morgue Manager Gets 8 Years In Body Parts Case, Law360 (Dec. 16, 2025), https://www.law360.com/whitecollar/articles/2422260.

¹¹⁴ Staff, Harvard researcher accused of smuggling frog embryos indicted on more charges, Guardian (June 25, 2025), https://www.theguardian.com/us-news/2025/jun/25/harvard-russian-researcher-frog-embryos.

¹¹⁵ Press Release, US Dep't of Just., Three Chinese National Scholars from University of Michigan Laboratory Charged for Conspiring to Smuggle Biological Materials into the US (Nov. 5, 2025), https://www.justice.gov/opa/pr/three-chinese-national-scholars-university-michigan-laboratory-charged-conspiring-smuggle.

¹¹⁶ Exec. Order No. 14173, § 5, 90 Fed. Reg. 8633 (Jan. 21, 2025), https://www.govinfo.gov/content/pkg/FR-2025-01-31/pdf/2025-02097.pdf.

¹¹⁷ Nathan Goldman, 3 Ways Losing Tax-Exempt Status Could Cost Harvard University Billions, Forbes (Apr. 17, 2025), https://www.forbes.com/sites/nathangoldman/2025/04/17/3-ways-losing-tax-exempt-status-could-cost-harvard-university-billions/; Benjamin Guggenheim, Trump eyes targeting more tax-exempt groups while denouncing Harvard, Politico (Apr. 17, 2025), https://www.politico.com/news/2025/04/17/harvards-a-disgrace-trump-eyes-targeting-more-tax-exempt-orgs-00298039.

¹¹⁸ Jeffrey Scott Tenenbaum, How the IRS Can—and Cannot—Revoke Federal Tax-Exempt Status, Am. Bar Ass'n (May 6, 2025), https://www.americanbar.org/groups/business_law/resources/business-law-today/2025-may/how-irs-revoke-federal-tax-exempt-status/.

¹¹⁹Owen McCarthy, MSU: Dean Accused of Plagiarism, Targeted By DEI Opponents, ‘Exonerated', The State News (Jan. 23, 2025), https://statenews.com/article/2025/01/msu-dean-accused-of-plagiarism-targeted-by-dei-opponents-exonerated?ct=content_open&cv=cbox_latest.

¹²⁰ Rachel Hoppe, Prominent UMN Researcher Resigns Amidst Plagiarism Allegations, The Minn. Daily (Apr. 16, 2025), https://mndaily.com/campus/prominent-umn-researcher-resigns-amidst-plagiarism-allegations/04/17/2025/.

¹²¹ Ellie Wolfe, The $600,000 Plagiarism Report the University of Maryland Won't Release, The Baltimore Banner (Jan. 8, 2026), https://www.thebanner.com/education/higher-education/university-of-maryland-plagiarism-darryll-pines-IEZYYI5TXFGEREX7I6CLW2FTHA/.

¹²² Id.

¹²³ University of Georgia, Annual Report on Academic Honesty Cases 2024–2025 (2025), https://honesty.uga.edu/wp-content/uploads/Academic-Honesty-Annual-Report-2024-2025.pdf.

¹²⁴ Anastasiia Carrier, UVA Health CEO Resigns After Allegations From Faculty, Charlottesville Tomorrow (Feb. 26, 2025), https://www.cvilletomorrow.org/uva-health-ceo-resigns-after-allegations-from-faculty/.

¹²⁵ Sofia Schwarzwalder, Independent Investigation Finds UW Systems Lab Conduct Not Harassment, The Daily (Feb. 3, 2025), https://www.dailyuw.com/article/independent-investigation-finds-uw-systems-lab-conduct-not-harassment-20250203.

¹²⁶ Nicholas Gutteridge, A&M's Corps Commits to Ongoing Self-Assessment Amid Increasing Rule Violations, The Battalion (May 6, 2025), https://thebatt.com/news/ams-corps-initiates-internal-review-amid-increasing-misconduct/.

¹²⁷ Rebecca Cohen, Texas A&M Fraternity Suspended Amid Probe into Reported Hazing Allegations Of Black Urine, Difficulty Walking, NBC News (Sept. 23, 2025), https://www.nbcnews.com/news/us-news/texas-m-fraternity-suspended-pending-investigation-hazing-allegations-rcna233196.

¹²⁸ Sofia Rodriguez, IU Assistant Professor Sanctioned After Discrimination Complaint, Ind. Daily Student (Jan. 15, 2026), https://www.idsnews.com/article/2026/01/iu-assistant-professor-sanctioned-discrimination-complaint.

¹²⁹ Cate Charron, 'Utterly Chilling': IU Professor Sanctioned Over Indiana's Intellectual Diversity Law, Indy Star (Aug. 14, 2025), https://www.indystar.com/story/news/education/2025/08/14/iu-sanctions-professor-indiana-intellectual-diversity-law-202/85643279007/.

¹³⁰ Id.

¹³¹ Press Release, US H. Comm. on Educ. & Workforce, Chairman Walberg Investigates Antisemitism at University of Illinois, UCSF, and UCLA Medical Schools (Aug. 25, 2025), https://edworkforce.house.gov/news/documentsingle.aspx?DocumentID=412693.

¹³² Press Release, Univ. of Ill. Chi., Response to the House Education and Workforce Committee Letter (Aug. 26, 2025), https://smc.uic.edu/news-stories/response-to-the-education-and-workforce-committee-letter; Press Release, Univ. of Cal. S.F., Inquiry from Committee on Education & Workforce (Aug. 29, 2025), https://chancellor.ucsf.edu/news/inquiry-committee-education-workforce.

¹³³ Press Release, US H. Comm. on Educ. & Workforce, Walberg, Owens, Demand Answers from Five Colleges Following Their Lackluster Response to Antisemitism (Mar. 27, 2025), https://edworkforce.house.gov/news/documentsingle.aspx?DocumentID=412306.

¹³⁴ Kaya Patel, Congressional Investigation Into College's Response to Antisemitism and SJP Encampment Accuses College of Noncompliance, Bowdoin Orient (June 5, 2025), https://bowdoinorient.com/2025/06/05/congressional-investigation-into-colleges-response-to-antisemitism-and-sjp-encampment-accuses-college-of-noncompliance.

¹³⁵ 135 Press Release, US H. Comm. on Educ. & Workforce, Walberg, Owens, Demand Answers from Five Colleges Following Their Lackluster Response to Antisemitism (Mar. 27, 2025), https://edworkforce.house.gov/news/documentsingle.aspx?DocumentID=412306.

¹³⁶ Maya Yang, U.S. House Panel Drops Inquiry Into Northwestern's Law School Clinics, The Guardian (Apr. 11, 2026), https://www.theguardian.com/us-news/2025/apr/11/northwestern-us-house-committee-investigation.

¹³⁷ Press Release, US H. Comm. on Oversight and Gov't Reform, Comer & Foxx Investigate Biden Administration's Failure to Enforce Foreign Funding Reporting Requirements at American Universities (Feb. 19, 2025), https://oversight.house.gov/release/comer-foxx-investigate-biden-administrations-failure-to-enforce-foreign-funding-reporting-requirements-at-american-universities.

¹³⁸ US House of Rep. Comm. on the Strategic Competition Between the US & the Chinese Communist Party and the Comm. on Educ. & the Workforce, Joint Institutes, Divided Loyalties (Sept. 2025), https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/joint-institutes-report-final.pdf; US House of Rep. Comm. on the Strategic Competition Between the US & the Chinese Communist Party, From Ph.D. to PLA (Sept. 2025), https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/from-ph.d-to-pla-report_final.pdf.

¹³⁹ US House of Rep. Comm. on the Strategic Competition Between the US & the Chinese Communist Party and the Comm. on Educ. & the Workforce, Joint Institutes, Divided Loyalties (Sept. 2025), https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/joint-institutes-report-final.pdf.

¹⁴⁰ Id.

¹⁴¹ US House of Rep. Comm. on the Judiciary, Illegal Racial Discrimination in Faculty Hiring at George Mason University Under the Direction of President Gregory Washington (Nov. 6, 2025), https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/file_3662.pdf.

¹⁴² Students for Fair Admission, Inc. v. President & Fellows of Harv. Coll., 600 U.S. 181 (2023).

¹⁴³ Letter from Chairman Tim Walberg, Chairman, H. Comm. on Educ. & Workforce, to President Alan Garber, Harvard University (June 10, 2025), https://edworkforce.house.gov/uploadedfiles/06.10.25_inquiry_to_harvard_university.pdf.

¹⁴⁴ Letter from Chairman James Comer, H. Comm. on Oversight & Gov't Reform, to President Alan Garber, Harvard University (Apr. 17, 2025), https://oversight.house.gov/wp-content/uploads/2025/04/Letter-to-Harvard-re-Title-VI-Compliance-04172025.pdf.

¹⁴⁵ Letter from Chairman James Comer, Comm. on Oversight & Gov't Reform, to Bethany Davis Noll, Exec. Dir., The State Energy & Environmental Impact Ctr., NYU Sch. of L. (July 17, 2025), https://oversight.house.gov/wp-content/uploads/2025/07/NYU-and-law-activism-071725.pdf.

¹⁴⁶ Letter from Chairman Brian Mast, H. Comm. on Foreign Affs., to President Melissa Gilliam, Boston U. (June 24, 2025), https://foreignaffairs.house.gov/sites/evo-subsites/foreignaffairs.house.gov/files/evo-media-document/hfac-bu-impact-counter-letter-180-2.pdf.

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Higher Education — Year in Review for 2025

Overview

TABLE OF CONTENTS

I. Introduction

II. Executive Orders Targeting DEI, Research Funding, the Compact, and the Big Beautiful Bill

1. Executive Order: Ending Illegal Discrimination and Restoring Merit-Based Opportunity

2. Executive Order: Reforming Accreditation to Strengthen Higher Education

III. Collegiate Athletics

IV. Antitrust

V. Criminal and Civil Enforcement Developments

VI. Internal Investigations

VII. Congressional Investigations

VIII. Conclusion

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