Washington, DC — March 30, 2026 — The National Academy of Education, together with 28 other scholarly and professional societies representing more than 165,000 individual members and more than 170 colleges and universities, submitted a comment letter today urging the U.S. General Services Administration (GSA) to withdraw proposed changes to the System for Award Management (SAM) certification requirements for applicants and recipients of federal financial assistance.
The societies argue that the proposed amendments would impose new certification requirements on colleges, universities, research institutions, and other recipients of federal funds that are vague, overbroad, inconsistent with the Constitution and federal law, and contrary to well-documented research on the positive impact and national imperative of recognizing all promise and including all talent in education, research and science. In particular, the letter raises concerns about proposed provisions related to so-called “DEI” activities, immigration-related conduct, public safety, executive branch guidance, and heightened false claims liability.
As the societies explain, GSA lacks authority to use the SAM registration process to create new substantive funding conditions that Congress has not authorized. Additionally, several of the proposed provisions are inconsistent with the Constitution, federal civil rights law, and longstanding limits on the federal government’s ability to attach ambiguous or coercive conditions to federal funding.
The comment further explains that the proposal could chill lawful education, research, mentoring, and workforce practices that help institutions foster inclusive learning and professional environments. The societies emphasize that lawful efforts to remove unfair barriers, broaden opportunity, and support student and faculty success for everyone are consistent with both research evidence and existing law.
The signatories urge GSA to maintain the current certification framework, which already requires recipients to comply with the Constitution and applicable federal statutes, rather than proceed with changes that are unnecessary, confusing, and harmful to education and research institutions nationwide.
Please find the 29 societies’ submission to GSA here.
The 29 scholarly societies signed on to this letter are listed below.
- AACTE (American Association of Colleges for Teacher Education)
- American Association for Dental, Oral, and Craniofacial Research
- American Association of Biological Anthropologists
- American Association of Colleges of Pharmacy
- American Association of Physics Teachers
- American Educational Research Association
- American Mathematical Society
- American Physician Scientists Association
- American Society for Pharmacology and Experimental Therapeutics (ASPET)
- American Society of Ichthyologists and Herpetologists
- American Statistical Association
- Association for Education Finance and Policy
- Association for the Study of Higher Education (ASHE)
- Association for Women in Science
- Association of Family Medicine Residency Directors
- Biophysical Society
- Botanical Society of America
- Coastal and Estuarine Research Federation
- Mathematical Association of America
- NAPCRG
- NARST (National Association of Research in Science Teaching)
- National Academy of Education
- National Council on Measurement in Education
- Out to Innovate
- Society for Industrial and Applied Mathematics
- Society for Integrative and Comparative Biology
- Society for the Study of Evolution
- Society of Teachers of Family Medicine
- University Council for Educational Administration
For more information, contact Amy I. Berman, Deputy Director, National Academy of Education, at aberman@naeducation.org.