GW Federal Update (October 23)

Key Takeaways

• The university has launched a new Federal Issues Tracker to serve as a centralized resource for timely and ongoing updates related to GW and higher education broadly.
   
• In response to proposals seeking to reshape higher education governance and federal funding frameworks, GW submitted formal public comments highlighting administrative burdens, protecting institutional stability, and safeguarding long-term funding streams essential to research and student programs.
   
• GW also submitted comments on the Draft National Institutes of Health Biosafety Policy for Research Involving Biohazards, expressing concern that certain provisions could undermine a strong culture of incident reporting while increasing regulatory burden on research institutions.

Federal Issues Tracker

We recognize that members of our community remain interested in the current or potential impacts of various federal actions. The latest updates on key issues as of October 23, 2026, are available here.

Recent Federal Actions

Department of Education

• The Department of Education released two proposals aiming to reshape higher education governance and federal funding frameworks. The first proposal, as shared in the GW Federal Update in September, overhauls federal accreditation standards by requiring accrediting agencies to evaluate institutional policies on intellectual diversity, free expression and faculty evaluation processes, while easing pathways for new accreditors and introducing strict financial return-on-investment metrics. The second proposal revises ED’s General Administrative Regulations (EDGAR), significantly expanding federal authority to modify, suspend or terminate discretionary grants for convenience, while reshaping selection criteria around administration priorities, merit-based hiring or admissions mandates without proxies, and unspent multi-year balances. Together, these proposals shift administrative oversight toward direct executive priorities and increase federal discretion over higher education operations and research funding.
  
  These regulatory overhauls could impact both institutional autonomy and core research operations at GW. As a research university managing extensive federal grants and academic programs, GW faces potential volatility under the proposed EDGAR revisions. Separately, the accreditation proposal requires university leadership, legal counsel and academic governance to audit campus policies surrounding free expression, faculty evaluation and research integrity to ensure ongoing compliance. GW submitted formal public comments on the accreditation and EDGAR proposals on September 21 and 23, highlighting administrative burdens, protecting institutional stability and safeguarding long-term funding streams essential to research and student programs.

Department of Labor, Office of Federal Contract Compliance Programs

• As of September 21, federal contractors like GW no longer are required to invite applicants for employment or employees to voluntarily self-identify as individuals with disabilities under Section 503 of the Rehabilitation Act. The Department of Labor takes the position that the disability self-identification framework conflicts with Americans with Disabilities Act (ADA) restrictions on disability-related inquiries. The ADA generally prohibits an employer from asking about an applicant’s disability status prior to the employer extending the applicant an offer of employment and only allows post-employment inquiries when they are job-related and consistent with business necessity.

Congress

• Congressional leaders are preparing for an abbreviated lame-duck legislative session following the November elections. Their agenda includes extending federal government funding past December 11, passing the annual Defense Authorization Act and addressing pending bipartisan legislation on college sports oversight. Year-end congressional actions will directly affect higher education research funding stability and collegiate athletics. Extending federal government funding past December 11 is essential for sustaining GW’s sponsored research grants and institutional allocations, particularly as lawmakers debate recent executive spending rescissions. Additionally, potential movement on college sports legislation could establish new federal compliance standards for GW Athletics regarding name, image and likeness disclosures and athlete transfers. 
   
• The Senate passed the Protect College Sports Act (PCSA) in a 77-22 vote, marking the first time either chamber of Congress has approved legislation to establish federal oversight across collegiate athletics. The bill grants a limited antitrust exemption and federal preemption of the current patchwork of state laws, creating uniform national standards that would enable the NCAA to make and enforce rules regarding eligibility, recruitment, transfers, agents and revenue-sharing. The House will consider the bill following the midterm elections, where it faces significant opposition from labor-friendly members who seek to classify student-athletes as employees. GW and the Atlantic 10 Conference remain supportive of the bill as a way to bring a measure of governance and financial stability to the current chaotic landscape that is dominated by state and federal court decisions. If enacted, GW will need to expand its capacity to effectively manage the additional legal and regulatory mandates.
  
  Key provisions of the legislation include: increasing the current cap on direct revenue sharing payments to student-athletes from ~$22 million to ~50 million annually per school; codifying the five-year student-athlete eligibility window recently enacted by the NCAA; establishing a uniform one-time, penalty-free transfer rule for student-athletes; restricting future power conference expansion and consolidation and limiting their ability to reduce or eliminate Olympic sport opportunities and programs; codifying and expanding student-athlete health, safety and medical coverage; codifying and enhancing student-athlete academic and scholarship guarantees; capping agent representation fees at 5 percent; guaranteeing student-athlete representation on national committees and institutional governing boards; and granting student-athletes a private right of action to pursue civil suits for violations of their rights.

Research and Grantmaking

• On October 19, GW submitted comments on the Draft National Institutes of Health Biosafety Policy for Research Involving Biohazards, expressing concern that certain reporting and enforcement provisions could undermine a strong culture of incident reporting while increasing regulatory burden on research institutions. GW also called for additional clarification regarding implementation requirements and the respective roles of federal agencies and institutions in biosafety oversight.

Resources

GW is committed to supporting our students, faculty and staff through federal changes. Curated resources are available for staying informed and safe, in addition to FAQs addressing the most common topics on students' minds, including interactions with external law enforcement and supporting international community members.

About this Newsletter

GW publishes this Federal Update to inform students, faculty and staff about how developments in the federal government affect higher education generally and the university. This newsletter includes timely information, answers to questions from GW community members, and resources for support.