September 2026 Update from the Federal Orders and Actions Core Team
Dear UMBC Community,
We write to you today to share our first update of the 2026 – 2027 academic year. The Federal Orders and Actions Core Team continues to closely monitor and respond to orders and actions from the U.S. government that impact the UMBC community. Please visit the Federal Orders and Actions website for additional information.
Curricular Practical Training (CPT)
CPT allows F-1 international students to participate in an internship, practicum, or other alternative work/study program that is an “integral part” of an “established curriculum.” The U.S. Department of Homeland Security’s Student and Exchange Visitor Program (SEVP) historically deferred to universities on most curricular matters, including decisions on eligibility for CPT.
SEVP recently sent a broadcast message to SEVP-certified schools indicating that school officials should “only authorize CPT if its absence would make attainment of a degree an impossibility and if the work associated with CPT is required for all students pursuing that degree.” In light of this new guidance, UMBC’s Office of International Students and Scholars (OISS) will only authorize CPT for students enrolled in programs of study in which practical training is required for every student in that curriculum.
Update on Duration of Status Rule
We previously updated the campus regarding a new rule published by the U.S. Department of Homeland Security limiting the period of authorized stay for F-1 international students, J-1 exchange visitors, and their legal dependents. The rule was challenged by various higher education professional associations and that challenge was supported by multiple states, including Maryland. Earlier this month, the District Court for Massachusetts issued a nationwide injunction, meaning that the implementation of this rule is paused while the legal challenge moves through the courts.
New Restrictions on Collaborations with Certain International Entities
China, Iran, and Russia – Expansion of 1286 List
The U.S. government maintains various lists, including the National Defense Authorization Act Section 1286 List, of foreign individuals, companies, and institutions for which official and unofficial collaborations are restricted. The 1286 List, which contains restricted academic entities in China, Iran, and Russia, was recently expanded to include several additional universities. Collaboration with an entity on the 1286 List may constitute a compliance risk, potentially violate federal law and negatively impact eligibility for federal funding. Last month, 30 U.S. universities were ordered by the government to audit their international collaborations with proscribed entities. Any researcher considering activities with an entity on the 1286 List or other federal sanctioned entities lists must first contact the Office of Research Protection and Compliance at researchintegrity@umbc.edu.
Iran – Suspension of General License G
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a rule on August 24, 2026, indefinitely suspending five general licenses that created exemptions for transactions with Iranian entities, including Iran General License G of the Iranian transactions and sanctions regulations. Academic collaborations with Iranian entities that were previously permitted under General License G will now require a specific license. Further, financial transactions, including tuition payments from Iranian financial institutions to U.S. banks, are also no longer exempt. If you have questions about how this development may impact future research collaborations, please contact the Office of Research Protection and Compliance at researchintegrity@umbc.edu.
Federal Agencies to Consider Additional Factors in H-1B Adjudications
A new executive order, Enhancing Program Integrity and Interagency Coordination in the Administration of the H-1B Nonimmigrant Visa Program, adds direct or indirect employer layoffs and their effect on similarly situated U.S. workers as a consideration across H-1B processing (i.e., applications, petitions, visas, and entry into the U.S.), expands interagency information sharing for H-1B administration, and directs the Department of Labor (DOL) to review previously filed Labor Condition Applications for possible enforcement action. Its full effect will depend on agency implementation.
Expansion of Social Media Screening to TN and I Applicants
Effective October 1, the Department of State will broaden its online presence review to cover applicants for I (foreign media representatives), TN, and TD (United States-Mexico-Canada Agreement professionals and their dependents) visas.
Proposed Regulations Regarding Federal Awards or Funding
This past May, the Office of Management and Budget (OMB) released a proposal for new “Regulations for Federal Assistance.” These proposed new regulations would lead to fundamental changes to the existing framework, known as Uniform Guidance, with substantial implications for how investigators and institutions apply for, manage, and sustain federally funded research projects.
These changes include options for political appointees to receive veto power over peer review; a renewed focus on Facilities and Administration (F&A) rates through competitive cost comparisons of proposals; and removal of certain routine research activities from federal grant awards, such as conference attendance, publication costs, and journal subscriptions. The proposed new regulations will impact all recipients, sub-recipients, and contractors who receive federal funds, including state and local government employees who apply for, accept, manage, distribute, or track federal funds.
The OMB received almost 500,000 written comments – including one from UMBC – during the 45-day public comment period. Currently, the OMB is working through the process of reviewing and addressing the comments and has not yet formally adopted any of the proposed changes. We are in close contact with the national organizations that are tracking these developments and advocating on our behalf.
Although the original notice projected that the new regulations would go into effect this Thursday, October 1, Congress has issued a delay for any implementation until at least after the midterm elections in November.
Monitoring the Distribution of Federal Awards or Funding
We are tracking publicly available federal award data from the National Science Foundation (NSF) and National Institutes of Health (NIH), and a few other agencies. As of September 26, the NSF has awarded 45 percent fewer awards and 23 percent less dollars in funding than the prior four-year average to date between fiscal years 2021 and 2024. Traditionally, the NSF has been working to distribute all of its allocated budget prior to September 30, the end of the federal fiscal year.
Effective September 25, the NIH has distributed 13 percent fewer awards versus the prior four-year average to date, but has allocated one percent more dollars than the prior average to date. This means that fewer principal investigators (PIs) are receiving awards, although those who have received awards may have seen multi-year funding increments awarded as a one-time distribution.
We are continuing to monitor this situation and are in frequent conversations with colleagues across the University System of Maryland (USM) and in national organizations, such as the Association of Public and Land-grant Universities (APLU), Council on Research (COR), and the Council on Government Relations (COGR).
If you have any questions about this information, please reach out to a member of the Federal Orders and Actions Core Team.
Thank you.
Regards,
The UMBC Federal Orders and Actions Core Team
Valerie Sheares Ashby, President
Manfred H. M. van Dulmen, Provost and Senior Vice President, Academic Affairs
Tanyka M. Barber, Vice President, Institutional Equity and Chief Diversity Officer
Kacey Hammel, Chief of Staff to the President
Renique T. Kersh, Vice President, Student Affairs
Paul A. Meggett, Vice President and General Counsel
D. Paul Monteiro, Vice President, Government Relations and Community Affairs
Yvette Mozie-Ross ’88, Senior Advisor to the President, Strategic Priorities and Initiatives
Karl V. Steiner, Vice President, Research and Creative Achievement
Lisa K. Van Riper, Vice President, University Communications and Marketing
David L. Di Maria, Vice Provost, Global Engagement
Ana Oskoz, Vice Provost, Faculty Affairs