Managing Change in Higher Education: Strategies to Endure Uncertain Times
 

September 2, 2025
Managing Change in Higher Education: Strategies to Endure Uncertain Times

Executive Order Targets Federal Grantmaking

 

The executive order (EO), Improving Oversight of Federal Grantmaking, introduced several changes to the federal grantmaking process. Notably, it:

  • Mandates discretionary awards must, where applicable, demonstrably advance the president’s policy priorities.
  • Directs agency heads to appoint a senior administrator to vet funding opportunity announcements (FOAs) and review discretionary awards to ensure alignment with agency priorities, the president’s policy priorities, and the national interest.
  • Mandates simplification of FOAs and applications.
  • Directs agencies to prioritize institutions that have demonstrated success in implementing Gold Standard Science (as defined in another EO) and applicants that commit to that standard.
  • Instructs the director of the Office of Management and Budget (OMB) to revise Uniform Guidance to require all discretionary grants permit termination for convenience.
  • Instructs the OMB to require all discretionary grants include provisions that limit use of the funds for costs related to facilities and administration (indirect costs).
  • Directs agency heads to give preference to institutions with lower indirect cost rates, all else being equal.
  • Requires grantees to justify each drawdown request and provide a written explanation or support, with specificity, for each drawdown.
  • Mandates future discretionary grant agreements prohibit recipients from directly drawing down general grant funds without affirmative authorization from the agency.
  • Imposes a thirty day deadline for agency heads to survey existing discretionary grants and report to the OMB whether the standard terms and conditions include termination for convenience and termination based on national interest provisions.
  • Directs agency heads to amend terms of existing discretionary grants to include a termination for convenience clause, where possible.
  • Mandates agencies conduct an annual review of all grants.

 

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Litigation Updates
Law

Court Rules on Dear Colleague Letter

A district court struck down the Dear Colleague Letter of February 14, 2025, and the accompanying certification requirement. Judge Stephanie A. Gallagher found they violated the Administrative Procedure Act and the First and Fifth Amendments to the Constitution.

 

Apportionment Data

The Office of Management and Budget (OMB) is required by the Consolidated Appropriations Acts of 2022 and 2023 to maintain a website that provides public access to apportionment data. In March, OMB took down the website and informed Congress that compliance had undermined its effectiveness in supervising agency spending. Congress and the Government Accountability Office requested the site be restored. Two nonprofits who depend upon the data for their operations sued and won. Judge Emmet G. Sullivan ordered OMB to restore the website and an appellate court upheld that ruling.

 

National Science Foundation (NSF)

District Judge Rita Lin ordered the NSF to restore grants it cut in violation of a preliminary injunction awarded in a class action lawsuit. Initially, NSF cited conflicts with the priorities of the current administration in grant termination notices. However, in cuts made after the injunction, the NSF issued grant suspension notices that cited affirmative action policies, failure to combat antisemitism, and other offenses as causes. The court ruled there was no difference between the suspensions and the previous terminations which were enjoined. She ordered the grants restored. A petition to stay the injunction has been filed. The case is poised to have a significant impact due to the number of agencies involved.

 

National Endowment for the Humanities (NEH)

In separate class action lawsuits, Judge Michael H. Simon and Judge Colleen McMahon issued temporary injunctions blocking the NEH from canceling grants and reallocating the funding. Judge McMahon noted that the Court of Federal Claims would have to approve any order directing disbursement of previously allocated awards.

 

National Institutions of Health (NIH)

The Supreme Court of the United States (SCOTUS) lifted an injunction that prohibited the NIH from canceling $783,000,000 in research funding. The grants typically involve study on topics the Trump administration has sought to curtail—including DEI, race, COVID, health disparities, climate change, and transgender issues. Notably, the stay does not reinstate the enjoined anti-DEI executive order that the cancelations were based upon. That remains vacated and unenforceable. Counsel reportedly warned NIH administrators against re-terminating restored grants. They suggest the agency wait until rules that permit termination for not aligning with agency priorities go into effect on October 1, 2025.

 

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Department of Education
Education

Loan Forgiveness Application Processing Paused

The Department of Education (Department) confirmed processing Income-Based Repayment Plan (IBR) loan forgiveness applications is currently paused. It cited compliance with a court-ordered recalculation of borrowers’ progress as the cause. However, several Senators questioned that assertion noting that IBR is not involved in any litigation.

 

New IPEDS Reporting Requirements

The White House published a memorandum and fact sheet directing the Department to expand the scope and scrutiny of IPEDS reporting. The Secretary of Education directed the head of the National Center for Education Statistics (NCES), which oversees IPEDS, to implement changes. Institutions will be required to submit to IPEDS data relating to applicants, admittees, enrollees, standardized test scores, grade point averages, first-generation status, graduation rates, final grade point averages, financial aid offered, financial aid provided disaggregated by race, and sex. NCES was also tasked with developing a verification process for data submitted to IPEDS. Notably, NCES recently suffered extensive personnel cuts. Recent reports indicate its roster consists of  only five employees. On the compliance side, experts estimate the new requirements will add significantly to the administrative burden of IPEDS reporting. The updates would go into effect during the current 2025-2026 academic year.

 

Advocacy Group Petitions to Join Department in Lawsuit

The Hispanic Association of Colleges and Universities (HACU) petitioned the court to add it as a defendant in the State of Tennessee and Students for Fair Admissions v. Department of Education lawsuit. The suit accuses the Department of unlawful discrimination for awarding grants to institutions designated as Hispanic-Serving Institutions (HSIs). Created by Congress, the designation is one of several Minority-Serving Institution types defined by enrollment thresholds. This, the plaintiffs argue, is unconstitutional. The Department of Justice agreed with the plaintiffs and will not defend the Department of Education. HACU notes that HSI awards are competitive and when won, are generally used for capacity building initiatives that benefit the entire student body. The addition of HACU as a defendant could prevent the case from going straight to settlement.

 

Federal Work Study Restriction

The Department rescinded previous guidance that allowed Federal Work Study funds to be used to pay students who work on nonpartisan voter registration. The Department also reminded institutions of their obligation to make a good faith effort to distribute voter registration forms to students. To do so, they must request forms at least 120 days prior to the registration deadline.

 

Reinstatements Scheduled to Start in September

Laid-off employees from the Department of Education’s Office of Civil Rights will begin returning to work in September. The reinstatements are in compliance with a ruling by Judge Myong J. Joun. The case is separate and not impacted by the Supreme Court’s lifting of the stay in New York v. McMahon, another case before Judge Joun.

 

Update to the Public Service Loan Forgiveness Program

The Department of Education (Department) published a notice of proposed rulemaking in regard to the Public Service Loan Forgiveness program (PSLF) in the Federal Register. The rule affords the Secretary of Education (Secretary) broad authority to determine eligibility. Employers could certify that they did not participate in listed activities. Failure to do so or in cases where the Secretary has determined an employer has engaged in one of the banned activities, could cause the employer to be ineligible to participate in the program for ten years. Alternatively, the employer can agree to adopt a corrective action plan approved by the Secretary. Critics say the proposed regulation could cause underreporting of workplace discrimination; lead to confusion; and embroil the Department in litigation at a time when it is understaffed. Comments are open through September 17, 2025.

 

Cybersecurity

Amid the fall semester hustle, cyberattacks against educational institutions increased. The surge was global, with attacks targeting the education sector in the US up 75%, compared to the same period last year. Attackers used phishing emails, weaponized PDFs, fake websites, and vulnerabilities in unpatched software. They have begun using AI to  accelerate and automate attacks. Experts advise institutions to keep track of changes in reporting requirements and cyber insurance trends.  In Cybersecurity Updates September 2025, Federal Student Aid (FSA) offered tips, a checklist, and a list of recent advisories to help institutions fortify their defenses.

 

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News
News

States Increase Regulatory Oversight of Colleges

Pen America released a report on recent state regulations aimed at restricting curriculum, program requirements, shared governance policies, tenure, hiring policies, admissions practices, and accreditation in higher education. Challenges to the new laws—often initiated by civil rights groups—have had mixed results. For example:

In Mississippi, a federal judge extended an injunction preventing enforcement of key provisions in an anti-DEI law while legal challenges proceed. But, in Alabama, a federal judge refused to enjoin enforcement of a similar law, known as SB 129, while challenges go through the legal system. He also removed the governor as a defendant, ruling that the grievances are not traceable to her.

 

Guidance for Recipients of Federal Funding

The US Department of Justice (DOJ) published guidance regarding discrimination for recipients of federal funding. DOJ describes scholarships, internships, mentorships, and leadership initiatives that reserve spots for specific racial groups as unlawfully discriminatory regardless of intent to promote diversity or address underrepresentation. It cited “Black Student Excellence Scholarship” as an example of unlawful discrimination. The DOJ also recommended maintaining documentation on rationales and policies. This follows the agency’s announcement that it will use the False Claims Act (FCA) to enforce its anti-DEI policies. However, the legality of those policies and the validity of expanding the Supreme Court ruling on admissions to cover all walks of life have not yet been settled. To counter FCA charges, experts suggest institutions plan ahead, document all compliance efforts, and employ traditional FCA defenses.

 

Funding for National Resource Centers Uncertain

National Resource Centers, a Title VI program, had been overseen by the Office of International and Foreign Language Education until that office was shuttered earlier this year. They are now overseen by the Office of Higher Education Programs. Recently, reports surfaced indicating Congressionally appropriated funding for the centers has not been disbursed. There is no entry for the program in the database of approved apportionment maintained by the Office of Management and Budget (OMB). As the end of the federal fiscal year approaches, directors of the centers fear it may not be forthcoming.

 

Exchange Programs Cut

Several cultural, language, and international exchange programs in the Bureau of Educational and Cultural Affairs were stripped of funding already appropriated by Congress. The bureau is a part of the State Department. Thousands of students, faculty, and institutions participate in exchange program annually. Program administrators had expected to receive the funds by the end of July but in mid-August, they were informed told the programs had been cut. They allege the programs were not renewed because  OMB prevented required notifications from being sent to Congress in time. Supporters are trying to get the funds released before September 30, 2025, after which they revert to the Treasury.

 

Self-Reporting Violation and Correction Program

The Department of Labor’ Wage and Hour Division (WHD) revised and relaunched the Payroll Audit Independent Determination program (PAID). Under the update, eligible participating employers can submit Fair Labor Standards Act minimum wage and overtime violation data from self-audits to the WHD online. WHD will oversee disbursement of back wages and other remedies. Note that participation in the program does not impact employees rights under state and local laws or under other federal laws such as the Americans with Disabilities Act. Further, employees are not required to accept the remedies offered.

 

False Reports Disrupt Campuses

Several colleges and universities have been victimized by fake bomb threats and active shooter reports known as swatting. In 2022, HBCUs were targeted by a slew of false bomb threats. Although false, such hoaxes put both the victimized campus communities and the first responders at risk. While those incidents were ultimately traced to a single underage individual, Wired magazine tied the current campaign to an organization that peddles threats for cash.

 

Cities Examine HBCU Satellite Feasibility

Cities far from the southern part of the country are seeking opportunities to host HBCU satellite campuses. As the federal government escalates its attack on diversity initiatives, cities far from the South are seeking opportunities to host HBCU satellite campuses. The hope is that doing so will help them maintain diverse workforces and communities. Boston, Massachusetts, recently held a hearing to gauge public support for bringing an HBCU satellite campus to the city.

 

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Leadership
Leadership

• Howard University President Dr. Ben Vinson III has resigned. The Howard University board of Trustees announced the appointment of Dr. Wayne A. I. Frederick as interim president. Details regarding the search for the next president will be available soon.

 

• Tennessee State University named alumnus Mr. Dwayne Tucker president. Mr. Tucker was serving as interim president and chair of the Tennessee State University Board of Trustees’ finance committee at the time of the appointment. He is active in the community.

 

• United Negro College Fund named Dr. Walter M. Kimbrough executive vice president of research and member engagement. Dr. Kimbrough is an experienced administrator who previously served as president at Dillard University, Philander Smith University and Talladega College.

 

• Howard University named Mr. Kerry Watson interim chief executive officer of Howard University Hospital Corporation. Mr.Watson is an experienced hospital executive having served as chief executive officer at University of Florida Health St. Johns, Maui Health System, and Memorial University Medical Center. He also served as an administrator for the Howard University Hospital’s department of radiology.

 

• Commissioners of the National Collegiate Athletic Association announced the formation of an alliance that will provide a unified front, financial sustainability and stability for HBCU athletics. Dubbed HBC4US, the alliance will pursue joint ventures including multimedia opportunities while working to preserve the traditions of HBCU athletics. MEAC Commissioner Sonja Stills, SWAC Commissioner Charles McCelland, CIAA Commissioner Jacqie McWilliams Parker, and SIAC Commissioner Anthony Holloman formed HBC4US during a leadership retreat.

 

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Grants
Grants

Anonymous Donor

Livingstone College received $10,000,000 from an anonymous donor. It is the third $10,000,000 gift from the anonymous donor. The college has been using the funds to revitalize its campus. The most recent donation will be used to upgrade residential halls.

 

Alumni Show Up

Benedict College announced its 2025 Annual Giving Campaign raised a total of $1,717,222. This surpassed previous campaigns and exceeded the fundraising goal. President Dr. Roslyn Clark Artis commended the college’s alumni and alumni clubs for their generous donations.

 

Trustee Donates

Virginia State University announced it received a $100,000 donation from  alumna Dr. Valerie K. Brown. Dr. Brown was appointed to Virginia State University Board of Visitors in 2018. In 2022 she was named rector.

 

Scholarship Program Support

Wiley University announced it was one of 9 HBCUs to receive a $10,000 HBCU Endowment donation from the Western Area of The Links, Incorporated. The university will use the gift to support its President’s Promise Scholarship program.

 

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Programs
Ptograms

Nursing Program

The Higher Learning Commission has given Philander Smith University a green light to begin offering a bachelor of science degree in nursing. The university secured over $8,000,000 to support the program and expects to welcome its first cohort soon.

 

Nutrition and Dietetics Concentration

North Carolina A&T State University College of Agriculture and Environmental Sciences launched a nutrition and dietetics concentration. Students enrolled in the nutritional sciences master’s degree program are eligible to apply for the spring 2026.

 

AI Training

Clark Atlanta University announced it is collaborating with IBM SkillsBuild to provide students and faculty the opportunity to develop core AI competencies. Under the agreement, IBM SkillsBuild will provide access to its portfolio of generative AI products and its family of open-source large language models. It will also provide interactive labs, group challenges, and access to mentors and courses.

 

Exchange Program

The University of Maryland Eastern Shore School of Business, Engineering, Applied Sciences, Technology, and Tourism Management signed a memorandum of understanding with Buea, Cameroon’s Redemption Higher Institute of Biomedical and Management Science. The agreement establishes a student and faculty exchange program.

 

Veterinary Opportunity

Fort Valley State University signed a memorandum of understanding with Zoo Atlanta. Under the agreement, eligible students in the university’s veterinary technology program can apply to attend Zoo Atlanta’s summer program. Enrollees will have access to cutting-edge equipment and facilities.

 

Pathway to Law School

Lincoln Memorial University Duncan School of Law and Kentucky State University signed an agreement that provides a pathway to law school for the HBCU’s students. Under the agreement the law school will reserve up to five seats for qualified eligible students from Kentucky State University. The institutions hope to increase interest in pursuing a degree in law.

 

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Strategic Financial Aid Management
(404) 874-0555

Federal Student Aid (FSA) and Compliance

 

  • Federal Student Aid (FSA) provided information regarding FAFSA reject code 68 and possible solutions. 
  • The 2025-2026 FAFSA Verification-IRS Tax Return Transcript Matrix is available. Institutions can use the matrix to map 2023 IRS tax return transcript data to FAFSA/ISIR data. Read instructions here and download the matrix here.
  • The third and final Pell Grant administrative cost allowance payment for 2023-2024 award year will be posted as an available balance in the G5 website. Sign in and process a drawdown transaction to receive the funds
  • The second Pell Grant administrative cost allowance payment for the 2024-2025 award year will be posted as an available balance in the G5 website. Sign in and process a drawdown transaction to receive the funds. 
  • Contact information in the COD system must be kept current. Changes to the Pell Grant and Direct Loan financial aid officer’s contact information can be made through the COD website. All other updates must be made using E-App. Changes must be reported within 10 days of the change. View the announcement for additional information.
  • FSA announced the report on nonpayment rates is available. 
  • The deadline to submit the Fiscal Operations Report for 2024–2025 and Application to Participate for 2026–2027 (FISAP) is October 1, 2025. 
  • The 2026–2027 Test ISIR Data File is available for use.
  • Financial Value Transparency and Gainful Employment data reporting for the 2025 cycle began on July 1, 2025, and runs through October 1, 2025.
  • Updates to the 2026-2027 FAFSA mandated by the passage of the One Big Beautiful Bill Act are outlined in this electronic announcement. They are included on the beta test version of the form. 
  • Preview of the 2026-2027 FAFSA form is available as a Powerpoint and in PDF format. 

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About this Publication
 
WPG HBCU News is a monthly email published by the Wesley Peachtree Group, CPAs (WPG) as a service to the sector. It consists of short summaries of news articles, government regulations, and announcements found online.

WPG HBCU News is available at no cost to HBCU administrators, trustees, and senior stakeholders. It is not intended as legal or financial advice. WPG's staff, writers, editors,  publishers, web hosts, email distributors, and others involved with the production and presentation of this newsletter are not liable for errors, omissions, losses, injuries, or damages arising directly or indirectly from use of this newsletter or any information presented therein.

WPG is a full-service accounting firm serving privately held businesses and clients in the education, government, faith-based, and not-for-profit sectors. We specialize in higher education with a particular emphasis on minority-serving institutions. We hope you find this publication useful and welcome your feedback.
 
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Managing Change in Higher Education: Strategies to Endure Uncertain Times
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