The CAMPUS Act requires the Director of National Intelligence, with Department of Defense input, to identify institutions of higher education domiciled in the People’s Republic of China that provide support to the People’s Liberation Army or implement China’s Military‑Civil Fusion strategy and to deliver that list to specified congressional committees within 180 days and annually thereafter. The bill then ties a range of domestic consequences to that list: it bars Department of Defense research, development, testing, and evaluation (RDT&E) funds from flowing to entities that contract with listed institutions; restricts eligibility to host or store classified information unless an entity certifies it has no active research partnerships with listed schools; authorizes visa denials for certain nonimmigrants affiliated with listed institutions; and prohibits Department of Education K–12 funds for schools contracting with PRC entities.
Beyond restrictions, the bill creates a counterparty pathway by authorizing Education Department grants to expand Mandarin and cultural programming through partnerships with the American Institute in Taiwan and Taipei Economic and Cultural Representatives Office, and lowers the higher‑education foreign gift disclosure threshold from $250,000 to $50,000. For compliance officers and research leaders, the Act replaces diplomatic case‑by‑case judgments with a sanctions‑style list that triggers immediate funding and access consequences for a wide range of university and K–12 collaborations.
At a Glance
What It Does
The Director of National Intelligence must identify PRC higher‑education institutions engaged in Military‑Civil Fusion and provide a list to Congress within 180 days and annually. Agencies must then block DoD RDT&E funds and other federal R&D funding from entities that contract with those listed institutions, require certification before facilities can store classified information, permit visa denials for certain nonimmigrants tied to listed schools, and bar K–12 Department of Education funds where contracts exist with PRC entities.
Who It Affects
U.S. research universities, defense contractors, federally funded research recipients, K–12 districts with contracts involving PRC‑domiciled entities, and foreign students or employees affiliated with listed Chinese institutions. Federal agencies with responsibilities for classified facilities, visas, and grant administration must add new screening and certification steps.
Why It Matters
The bill operationalizes the U.S. government’s concern about China’s Military‑Civil Fusion by converting intelligence designations into blunt funding and access prohibitions. That linkage pressures universities and contractors to sever or avoid collaborations with identified PRC institutions and expands scrutiny of foreign gifts and K–12 contracts, while simultaneously funding alternative Mandarin and Taiwan‑linked programming.
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What This Bill Actually Does
The Act starts by instructing the Director of National Intelligence, consulting with the Secretary of Defense, to identify PRC higher‑education institutions that provide support to the People’s Liberation Army, including schools participating in China’s Military‑Civil Fusion or its defense industrial base. The DNI must deliver that list to specified Armed Services and intelligence committees within 180 days of enactment and update it annually.
The identification is the bill’s hinge: once on the list, an institution triggers a set of mandatory domestic restrictions.
On the funding side, the bill prevents any Department of Defense RDT&E funds from being provided to an entity that maintains a contract with a listed institution. It extends related funding prohibitions by blocking federally supported R&D awards to entities that contract with listed PRC institutions or that are associated with entities on the Commerce Department’s Entity List.
The effect is to create a choke point at the contract level: U.S. entities with ongoing contractual relationships to listed Chinese schools become ineligible for sizeable categories of federal research support.The Act also targets access and personnel. The Defense Counterintelligence and Security Agency (DCSA) may not approve a facility to host or store classified information unless the entity certifies it lacks active research partnerships with any institution on the DNI’s list, shifting due diligence and attestation obligations onto prospective cleared facilities.
Separately, the Secretary of State is authorized to deny visa applications for certain nonimmigrants who are students or employees of listed institutions. For primary and secondary education, the Department of Education may not provide funds to K–12 schools that maintain contracts with entities domiciled in the PRC.As a counterweight to restrictions, the bill directs stronger engagement with Taiwan: it expresses a congressional preference that the American Institute in Taiwan expand partnerships with Taipei representatives to increase access to Mandarin and cultural programming in U.S. K–12 schools and colleges, and it authorizes Education Department grants to support such programming.
Finally, the Act tightens transparency by lowering the required disclosure threshold for foreign gifts and contracts under HEA section 117 from $250,000 to $50,000, and it defines key terms such as what counts as an institution domiciled in the PRC for purposes of the statute.
The Five Things You Need to Know
The DNI must submit the initial list of PRC higher‑education institutions with PLA or Military‑Civil Fusion ties to designated congressional committees within 180 days of enactment and update it annually.
Section 3 bars Department of Defense RDT&E funds from going to any U.S. entity that maintains a contract with a PRC institution on the DNI list, effectively blocking those contractors from a major category of defense research funding.
DCSA cannot certify a facility as eligible to host or store classified information unless the entity operating the facility certifies it has no active research partnerships with any institution on the DNI list.
Section 5 authorizes the Secretary of State to deny visa applications for nonimmigrants described in INA 101(a)(15)(F) or (J) who are students or employees of institutions identified on the DNI list.
Section 9 reduces the Higher Education Act foreign gift and contract disclosure threshold from $250,000 to $50,000, increasing reporting obligations for colleges and universities.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title and scope
Establishes the Act’s shorthand name, the CAMPUS Act, and frames its purpose as preventing U.S. support for universities that aid the People’s Liberation Army. Practically, this signals the bill’s focus on operational restrictions rather than purely declaratory findings.
DNI list of PRC higher‑education institutions
Mandates that the Director of National Intelligence, in consultation with the Secretary of Defense, identify PRC institutions of higher education that provide support to the PLA or are involved in Military‑Civil Fusion, and submit that list to specified congressional committees within 180 days and annually. The provision centralizes the designation authority in the intelligence community, creating a single, annually updated trigger for subsequent prohibitions.
DoD RDT&E funding prohibition
Prohibits any Department of Defense research, development, testing, and evaluation funds from being provided to an entity that maintains a contract with a listed PRC institution. This operates at the contract level: U.S. companies, universities, or nonprofits with contractual ties to listed schools could be excluded from DoD RDT&E awards regardless of the domestic work’s content.
Classified facility eligibility certification
Requires entities seeking DCSA approval for facilities to host or store classified information to certify they have no active research partnership with any institution on the DNI list. The certification requirement introduces a compliance checkpoint for cleared facilities and creates a legal attestation that could be audited or investigated.
Visa denial authority
Gives the Secretary of State discretion to deny visa applications for certain nonimmigrant classifications (those referenced in INA 101(a)(15)(F) and (J)) when the applicant is a student or employee of a listed institution. The statute bases denials on institutional affiliation, which can affect academic visitors and researchers depending on how the State Department applies the authority.
K–12 funding restriction
Bars Department of Education funds for elementary and secondary schools that maintain contracts with entities domiciled in the People’s Republic of China. This reaches local districts and charter schools that engage service providers, vendors, or program partners tied to PRC organizations.
Partnerships with Taiwan and grant authority
Expresses congressional support for expanded AIT–Taipei representative partnerships to increase Mandarin and cultural programming and authorizes Education Department grants to K–12 and higher‑education institutions to implement such programming. The provision creates an explicit funding channel for alternative language and cultural exchanges aligned with Taiwan rather than PRC institutions.
Broader federal R&D grant prohibition tied to Entity List
Extends R&D funding prohibitions beyond DoD by forbidding federal RDT&E awards to entities that maintain contracts with PRC institutions on the DNI list or with entities listed on the Commerce Department’s Entity List (15 CFR part 744 supplement). This cross‑references export control designations to widen the set of funding exclusions.
Lowered foreign gift disclosure threshold
Amends HEA section 117(a) to reduce the disclosure trigger for foreign gifts and contracts from $250,000 to $50,000. That change substantially increases the number of gifts and contracts that colleges must report publicly and to the federal government, expanding transparency and administrative workload.
Definitions
Defines ‘appropriate committees of Congress,’ what counts as an ‘institution of higher education domiciled in the People’s Republic of China’ (including control by PRC Ministry of Education or SASTIND), and cross‑references the K–12 definition to the National AI Initiative Act. The statutory definitions narrow the universe of covered institutions to those with formal ties to central PRC authorities.
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Explore Education in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- U.S. national security agencies and defense policymakers — they gain an intelligence‑driven tool that converts PRC institutional designations into enforceable domestic restrictions, streamlining the prevention of potential technology transfer pathways.
- Taiwan‑linked education and cultural organizations — the bill authorizes Department of Education grants and encourages AIT partnerships, creating funding and institutional partners for Mandarin and cultural programming in U.S. schools.
- Domestic defense contractors and federally funded researchers without PRC ties — by excluding competitors with PRC institutional relationships, the bill may reduce competition from entities that maintain those ties, protecting certain contractors’ access to RDT&E funds.
Who Bears the Cost
- U.S. universities and research centers with existing collaborations or contracts involving PRC institutions — they risk losing access to DoD and other federal R&D funding if their partners appear on the DNI list, requiring termination or restructuring of relationships.
- K–12 districts and vendors — school districts that contract with PRC‑domiciled entities for services, curricula, or technology may lose Department of Education funding and must reassess vendor relationships and procurements.
- Colleges’ compliance offices and registrars — lowering the foreign gift disclosure threshold from $250K to $50K increases reporting burden, legal exposure, and potential reputational risk for institutions that accept foreign support.
- Entities seeking to host classified work — firms and universities must perform more exhaustive screening and may face lost classified‑work opportunities if any research ties to listed PRC institutions exist.
- Foreign students and visiting scholars affiliated with listed PRC institutions — they face heightened visa denial risk under Section 5, affecting mobility and recruitment for U.S. academic programs.
Key Issues
The Core Tension
The bill pits two legitimate policy goals against one another: protecting national security and critical‑technology advantage by severing institutional pathways linked to PRC Military‑Civil Fusion, versus preserving open academic collaboration, foreign student mobility, and the administrative capacity of universities to engage in global research. Strengthening one set of objectives—blocking possible technology transfer—directly constrains the other—open scientific exchange and educational programming—without offering a precise calibration mechanism to balance them.
The bill relies on the intelligence community to create a durable, operationally decisive list, but the statute leaves few procedural guardrails for that process. The DNI’s consultative role with DoD is specified, but the bill does not require notice to affected entities, an appeals process, or publication standards beyond transmission to congressional committees.
That raises questions about due process, potential inaccuracies, and how rapidly agencies must act once a designation is made.
Mechanically, the contract‑level funding prohibitions create compliance complexity: organizations that receive federal RDT&E funds must map their entire contract and subaward networks to determine whether a tie to a listed PRC institution exists. The DCSA certification for classified facilities imposes an attestational duty that could expose entities to false‑statement risk if they certify absence of partnerships without exhaustive historical review.
Additionally, cross‑referencing the Commerce Department Entity List in Section 8 multiplies the bases for exclusion but creates potential duplication and inconsistent timing between agency lists.
Finally, lowering the foreign gift disclosure threshold and simultaneously increasing restrictions on academic collaboration presents a policy tradeoff: it increases transparency but also expands administrative workload and the potential for politicized scrutiny of university funding. Agencies charged with enforcement will need staffing and guidance to apply these provisions uniformly without unduly chilling benign academic exchange.
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