Foreign Influence, Risk, Security, and Travel (FIRST) Working Group

The University is receiving an unprecedented amount of federal executive orders that have direct (or indirect) impact on the University and its personnel, resources, and financial stability.  On July 22, 2025, a number of University stakeholders met to review recent federal and state developments focused on national security, research integrity, and foreign influence; reaffirm the value of international engagement; and assess current compliance measures. The group concluded that a formal working group is needed to coordinate the comprehensive institutional review and response.

President Seidel charged this Working Group with coordinating a focused effort to review state and federal regulatory changes and anticipated changes, review existing University policies and procedures, identify any gaps, and propose necessary changes. The Group will also review current processes and prior working group recommendations regarding travel management and travel tracking and recommend next steps the University should take to enhance its travel practices. Specifically, the Working Group will look at the following:

  • Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA)
  • United States Department of Agriculture (USDA) Guidance Memorandum dated July 8, 2025
  • The University’s foreign influence and international engagement policies, and
  • The feasibility of a travel tracking system to increase the safety and protection of the University’s employees and students

Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA)

Understanding PRWORA

What It Is:
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) restricts certain federal public benefits to recipients who are U.S. citizens, U.S. non-citizen nationals, and "qualified aliens."

Why It Matters:
Federal agencies require institutions to verify the eligibility of recipients before providing them with a federal public benefit. Failing to verify can result in loss of funding and/or penalties.

Which Agencies Require PRWORA Compliance

PRWORA applies to any federally funded public benefit. However, the following agencies have issued new guidance on how PRWORA’s definition of “Federal public benefits” applies to their programs, including any exemptions:

Examples of Requirements Under the Agency Guidance:

  • To submit a grant proposal to the Department of Education (DOE), the Principal Investigator (PI) must confirm that they have a process to ensure all individuals receiving a federal public benefit through the grant are U.S. citizens, U.S. non-citizen nationals, or qualified aliens.
  • Prior to providing gift cards to survey participants for participating in the research survey funded through the Department of Education, the researcher must complete the Verification Process to ensure the recipient of the gift card is a U.S. citizen, U.S. non-citizen national, or qualified alien.

Exemptions from PRWORA

  • Employment under federal grants from one of the listed agencies is not considered a “Federal public benefit”.
  • Other exemptions as specifically identified in federal law and regulation as well as any additional guidance issued by the funding agency.

How to Comply with PRWORA

  • Current Sponsored Projects and Programs
    Beginning December 1, 2025, any project or program that falls under one of the listed agencies that does not have an exemption specifically stated in federal law or in agency guidance will need to implement the appropriate Verification Process.
  • New Proposals
    The submission process for all new proposals involving the above listed agencies will include the requirements to identify any specifically authorized exemptions and to certify compliance with the PRWORA verification for benefit recipients if the grant is awarded. This certification will carry over to the award letter when a grant is awarded. The Office of Pre-Award Services will assist faculty and staff with these new requirements as proposals are submitted.

Verification Process

Step 1
The Interim Verification Process, which will go into effect December 1, 2025, requires each individual recipient or participant to verify their eligibility prior to receiving a program benefit by completing and signing the PRWORA Eligibility Certification.  The Certification can be signed in person or electronically, using one of the methods approved by UW SAP 7-9.7, Electronic and Digital Signatures. The Certification will need to be completed by a parent or guardian of any recipients or participants under the age of eighteen (18).

If a program cannot obtain a signed PRWORA Eligibility Certification and requires an alternate verification process, they will need to submit the proposed alternate process to the Research Compliance Office in advance for consideration.  Please contact Carrie Hesco for submission of an alternate process.

University employees who have completed the 1-9 or E-Verify process are not required to complete the PRWORA Eligibility Certification.

The program or project must collect and retain the PRWORA Eligibility Certifications in a safe, secure, and confidential manner. They may be retained in physical or electronic format.

Step 2
A new Verification Process may slowly roll out upon the University’s access to the USCIS SAVE program and creation or procurement of necessary IT infrastructure. The new Verification Process will include determining eligibility for all recipients or participants through one or more of the following:

  • an attestation,
  • obtaining verifying documentation and
  • verification through the USCIS SAVE program.

 

Verifying documentation, such as immigration documentation or social security numbers, will only be retained long enough to verify eligibility, and USCIS SAVE program results will always be kept in a safe, secure, and confidential manner. Information on how to store electronic documentation in a safe, secure, and confidential manner can be found here - Setup Public Funding Attestation SharePoint Folder.
Additional information will be provided as the University obtains the necessary access and infrastructure to accommodate the new Verification Process.

Enforcement

The University will conduct periodic random audits of university offices, units, programs, and projects that receive funds from the listed federal agencies to ensure compliance with the requirement to verify eligibility for benefit recipients. Findings from the audits indicating noncompliance may result in remedial action at the discretion of the appropriate Vice President, Dean, or Director, as well as any disciplinary or corrective action pursuant to the UW Employee Handbook.

Frequently Asked Questions

Aerial view of UW campus

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) restricts eligibility for certain federal public benefits to U.S. citizens, non-citizen nationals, and specific categories of noncitizens known as “qualified aliens.”

Recent federal guidance, including guidance memos from DOE, HHS, DOJ, DOL and USDA, clarifies how the University must verify eligibility for benefits supported by federal funds to ensure compliance with PRWORA. It also expands the definition of federal public benefits covered by PRWORA and acceptable eligibility verification methods.

Yes, employment of international students here on visas that provide work authorization are exempt from the definition of “Federal public benefit”. 8. U.S.C. 1611(c)(2)(A)

Yes, assistantship stipend, tuition and fees, and health insurance of international students here on visas that provide work authorization are incidental to employment.

Questions can be submitted to the Research Compliance Office.

(1) A person born in a U.S. outlying possession after it officially became U.S. territory
(2) A person born abroad to parents who are both U.S. nationals (but not citizens)
(3) A young child found in a U.S. territory, and no one knows the identity of their parents, and
(4) A person born abroad to one U.S. national parent and one non-U.S. parent, with special conditions.

  • Lawful Permanent Residents (Green Card Holders): Individuals lawfully admitted to the U.S. on a permanent basis.
  • Refugees and Asylees: Individuals granted refugee status or asylum under the Immigration and Nationality Act.
  • Parolees: Those paroled into the U.S. for at least one year, with some exceptions.
  • Victims of Severe Abuse and Trafficking: Aliens who have been battered or subjected to extreme cruelty, or victims of trafficking, and who meet specific requirements.
  • Conditional Entrants: Those who were granted conditional entry before April 1, 1980, and certain victims of trafficking.
  • Withholding of Removal: Aliens whose deportation is being withheld.
  • Cuban and Haitian Entrants: Individuals defined as Cuban or Haitian entrants under the Refugee Education Assistance Act of 1980.
  • Citizens of Freely Associated States (FAS): Citizens of the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau may be eligible based on recent changes.

  • Many nonimmigrant visa holders.
  • Individuals granted parole for less than one year: Those granted short-term parole for less than 12 months are not considered qualified aliens for benefits eligibility.
  • Recipients of Deferred Action: This includes individuals with Deferred Action for Childhood Arrivals (DACA), which does not confer a qualified immigration status for benefits.
  • Recipients of Temporary Protected Status (TPS): Individuals with TPS are lawfully present but do not hold a "qualified alien" status for federal benefits.
  • Recipients of Deferred Enforced Departure (DED): Like TPS, this temporary status does not qualify an individual for benefits. 
  • Undocumented immigrants: People who entered the United States without authorization or overstayed a valid visa are not qualified aliens. 
  • Asylum seekers with pending applications: Individuals who have applied for asylum but have not yet received a decision are generally not considered qualified aliens during the pendency of their application. 

Programs providing a “federal public benefit” funded by federal agencies (currently DOE, HHS, DOJ, DOL, USDA) that have provided updated guidance are affected by the current changes. This may include some forms of financial aid, research participation funded by federal agencies, and employment or training supported by federal funds.

A “Federal public benefit” is defined as any grant, contract, loan, professional license, or commercial license provided by an agency of the United States or by appropriated funds of the United States; and any retirement, welfare, health, disability, public or assisted housing, postsecondary education, food assistance, unemployment benefit, or any other similar benefit for which payments or assistance are provided to an individual, household, or family eligibility unit by an agency of the United States or by appropriated funds of the United States.

8 U.S.C. 1611(c)(1)(A)

Non-financial benefits, such as assistance in the form of education and training, if supported by federal funds, are considered “federal public benefits” and would require the appropriate verification process. 

No. Institutions are not required to affirmatively report citizenship or immigration data to the federal agencies. However, the University should be ready to demonstrate that benefits are not being provided to those that are ineligible.