The Forum Issues Comment on Proposed Changes to Federal Financial Assistance

The Forum on Education Abroad submitted the following formal comment expressing concerns about the White House Office of Management and Budget’s proposed changes to how federal grants are awarded.

​July 13, 2026
Office of Federal Financial Management
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
RE: Comments in response to Notice of Proposed Rulemaking – Regulation for Federal
Financial Assistance (Docket No. OMB-2026-0034)

To Whom It May Concern,

On behalf of The Forum on Education Abroad, I am writing to comment on the Office of Management and Budget (OMB) proposed rule dated May 29, 2026, titled “Regulation for Federal Financial Assistance.”
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The Forum on Education Abroad is a 501(c)(3) nonprofit membership association recognized by the U.S. Department of Justice and the Federal Trade Commission as the Standards Development Organization (SDO) for the field of education abroad. The Forum provides training and resources to education abroad professionals, and its Standards of Good Practice are recognized as the definitive means by which the quality of education abroad programs may be judged. The Forum’s mission is to cultivate educators who champion high quality education abroad experiences that ignite curiosity, impact lives, and contribute to a better world. In service of this mission, in 2025, it launched the Education Abroad: The Career Catalyst campaign, which underscores how education abroad drives career and economic success in today’s global economy.

We have concerns about the changes proposed in §200.202 regarding program planning and design. Establishing a “domestic-first framework” that introduces possible new restrictions on international program activities and collaborations could negatively impact the ability of students to engage in a global education. International education and cultural exchange programs already are overseen by the U.S. Department of State, which promotes alignment with U.S. policy priorities. The proposal offered in §200.202 should clarify that international education and education abroad programs already authorized by Congress and overseen by the State Department would not be subject to additional review or restrictions. 

Policies that restrict the ability of students to engage in education abroad would be detrimental to U.S. economic strength. As recent research from The Forum demonstrates, 90% of alumni who studied abroad report their experiences helped them build critical job skills. With their earnings premium, employed alumni added $1.8 billion in income to the U.S. economy in 2024. Education abroad helps students build skills that employers increasingly seek as they position their businesses to be more globally competent in order to stay competitive. 

We respectfully request OMB to consider how this lack of clarity around a “domestic-first framework” may, in fact, work to the detriment of U.S. economic strength. 

Thank you for the opportunity to offer feedback on this proposed rule and for your consideration of our thoughts. 

Respectfully submitted,
Melissa Torres
President and CEO
The Forum on Education Abroad​