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:
- Department of Education (DOE)
- Department of Justice (DOJ)
- Department of Labor (DOL)
- Health & Human Services (HHS)
- Department of Agriculture (USDA)
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
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.”
In addition to the PRWORA Eligibility Certification for an individual, General Counsel has also provided a PRWORA Eligibility Certification for a minor and a Multi-Party PRWORA Eligibility Certification. If none of these variations fit your situation and you would like to discuss an alternative certification form, please contact the Research Compliance Office.
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.
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.
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.
Yes, if the grant is federally funded from one of the [named agencies], the funding flows through to the subcontractor or subawardee, and the subcontractor or subawardee is providing a federal public benefit, then the subcontractor or subawardee does have to comply with PRWORA.
Yes, if the conference or other activity is actually part of the individual’s employment. If it is separate from employment, then it is a federal public benefit and eligibility verification is required.
Yes. If a federal public benefit (the incentive) is provided using federal funds from one of the [named agencies], eligibility verification is required. Depending on the circumstances, you may be able to create an alternative verification process with the Research Compliance Office prior to implementation that allows participants to remain anonymous but still attest to their eligibility. For example, as part of the participation criteria, you may include that individuals must be eligible for federal public benefits under PRWORA and have a statement that the participant verifies they meet the participation criteria before they continue.
Maybe. If funded by one of the [named agencies], the proposal and award documentation will need to be reviewed and discussed with Pre-Award Services and the Research Compliance Office, for any exemptions. PI’s should work with Pre-Award Services during the proposal submission process to clearly detail international incentives that will be offered.
Yes; however, depending on the circumstances, you may be able to create an alternative verification process with the Research Compliance Office prior to implementation. For example, individuals may be asked to sign in as they enter the program, training, or lecture and attest that they have read a posted eligibility notice and they meet the requirements.
No. If the event is not being paid for with federal funds from one of the [named agencies], then verification of participants is not required.
No. If you are only presenting at the event as a guest, you are not required to verify eligibility of the participants prior to your presentation.
Maybe. This would be considered an alternate process and depending on the circumstances, you may be able to create this alternative verification process with the Research Compliance Office prior to implementation.
Technically, this is considered a federal public benefit; however, depending on the language of the award or other funding documentation and the specific guidance by the funding agency, there may be an eligible exemption or reasonable alternative verification process that you can get approved by the Research Compliance Office.
Yes, American Indians and Alaska Natives are United States citizens and eligible for federal public benefits.
Yes, unless there is specific guidance from the funding agency or in the award that prohibits this. Generally, benefits paid for by other funding sources are not federal public benefits. Documentation will need to be maintained to show that alternative funding was used for participants who were not eligible to receive the federal funding.
If a program, like 4-H, uses federal funds combined with non-federal funds co-mingled in such a way that the funding source is indistinguishable, PRWORA still applies.
The required eligibility verification process can be worked into the existing registration process to make it as efficient for the program participants as possible. Depending on the circumstances, you may be able to create an alternative verification process with the Research Compliance Officeprior to implementation.
Yes. Eligibility will need to be verified for current members or participants that are receiving federal public benefits. Depending on the circumstances, you may be able to create this alternative verification process with Research Compliance Officeprior to implementation.
No, it is not necessary to collect a new attestation.
It can be done either way as long as each individual is clearly identified. If it is preferred that both individuals attest to their eligibility to receive the offered federal public benefit(s) in the same form, then you can seek assistance modifying the form by submitting a request to the Research Compliance Office.
Yes, if these programs are funded by a [named agency] and are providing a federal public benefit to individuals, households, or family units.
Maybe. This will depend on what funds, equipment, or services are being provided to the university and what terms of the original federal award apply. Before the acceptance of the subaward, PIs should work with Pre-Award Services and the Research Compliance Office to determine if the funding comes from one of the [named agencies], if a federal public benefit will be provided with the funds, and what terms of the prime, federal award apply to the university.
No. If a project or program is federally funded by an agency other than a [named agency], the new verification process is not currently being required under the new interpretation; however, any original requirements of the grant or award continue to apply.
The requirements are being built into the current electronic submission process in RoamWyo to guide you through what is required. They will be live in RoamWyo before December 1, 2025.
New IRB protocols will need to include details on how the program or project will comply with the required eligibility verification. Prior IRB protocols will need to be reviewed, and any revisions of the protocol will need to be submitted to the IRB if the eligibility requirement would change the previously approved protocol.
At least 25 states are parties in a lawsuit against the DOJ, which has delayed implementation in several peer institutions; others in states not party to the suit are currently going through their own similar review and implementation process.
Internal audit will follow their standard audit process to select and appropriate number of programs covered by PRWORA, review compliance with the requirements, determine if there are any gaps in the audited programs and work with the department to address the gaps.
