# Federal Agencies Strengthen University Contract Certifications

Federal agencies have introduced and proposed new certification and compliance requirements for colleges and universities receiving federal grants and contracts, focusing on diversity, equity, and inclusion (DEI), foreign funding transparency, and False Claims Act (FCA) risk mitigation. Key developments include the implementation of FAR 52.222-90, which prohibits racially discriminatory DEI activities for federal contractors, and proposed government-wide certifications via SAM.gov for federal financial assistance recipients. These evolving requirements increase institutional obligations and necessitate enhanced compliance processes, risk assessments, and coordinated review procedures prior to certification acceptance to mitigate legal exposure.

- Federal grant certifications and contract clauses now explicitly address DEI, nondiscrimination, foreign influence, and compliance with executive orders, impacting universities and colleges nationwide.
- The Department of Justice highlights potentially actionable practices such as demographic hiring targets and diversity-linked compensation, signaling increased FCA enforcement risks.
- Procurement professionals should advise educational institutions to establish coordinated internal review processes before accepting awards to reduce post-award challenges.
- Organizations supporting higher education clients can leverage these developments to offer compliance advisory services and risk management solutions aligned with new federal mandates.

**Jurisdictions:** federal
**Industries:** Education
**Topics:** Regulatory Compliance
**Published:** September 17, 2026

### Government Entities
- National Institutes of Health (NIH)
- National Science Foundation (NSF)
- General Services Administration (GSA)
- Department of Justice (DOJ)
- Office of Management and Budget (OMB)

### Key Quotes
> Institutions best positioned to navigate this environment will be those that establish a coordinated review process before an authorized official signs a certification or accepts an award96not after an agency or whistleblower questions it.
> — Brigid Harrington, Senior Attorney

> DOJ has identified practices such as demographic hiring targets, 'diverse slates,' compensation tied to diversity metrics, restricted mentoring or leadership programs, promotion and staffing decisions, and monthly summaries tracking demographic goals as potentially actionable.
> — Gerry Leone, Special Counsel

> Certification is the common thread across many of these developments.
> — Amy Fabiano, Senior Attorney

### Sources
- [Federal Certification and Contracting Requirements for Colleges and Universities: A Year in Review](https://www.hunton.com/insights/legal/federal-certification-and-contracting-requirements-for-colleges-and-universities-a-year-in-review) - Hunton Andrews Kurth LLP