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The College Art Association has submitted a comment to the Federal Register objecting to a Department of Education proposal to rescind the regulations governing the federal Title VI International Education and Fulbright-Hays Programs. The comment emphasizes the importance of the regulations and urges the Department of Education to abandon this proposal.

CAA encourages constituents to post individual comments on the proposal here before the Friday, July 31, 11:59 p.m. EDT deadline.

July 29, 2026

To: U.S. Department of Education

Re: International Education Programs and Fulbright-Hays Program; Rescission of Regulations [Docket ID ED-2026-OPE-0991]

The College Art Association (CAA), the preeminent international organization serving professionals across the visual arts—including art historians, artists, designers, curators, administrators, and educators—fervently opposes the Department of Education’s proposal to rescind all regulations governing the Title VI and Fulbright-Hays programs. By dismantling the framework that has sustained language instruction and area studies for decades, the Department would erode a critical national asset and jeopardize longstanding investments in expertise on regions of profound geopolitical importance to the United States.

The existing regulations do not hinder effective governance as the Department of Education asserts—they enable it. These rules establish the consistency necessary for higher education institutions to plan multi-year language and area studies programming and compete for funding under a transparent and equitable framework. This is rendered impossible without a defined set of rules governing these programs. Further, the proposal to shift support toward contracts or subgrants outside the established grant and peer-review process would weaken academic rigor, undermine trust, and diminish the overall quality and effectiveness of these programs.

The Department of Education argues that eliminating these regulations would create greater flexibility in responding to evolving geopolitical priorities. In reality, Title VI already provides that flexibility by maintaining a nationwide network of language experts and regional specialists prepared to respond when urgent needs emerge. The Department’s proposal would replace this proven infrastructure with a reactive model that attempts to develop expertise only after a crisis or policy challenge arises. Such an approach would leave the United States less prepared, less agile, and more vulnerable. Building expertise on demand is neither efficient nor effective; it is far more costly than maintaining the deep reservoir of knowledge and talent that Title VI has cultivated for generations.

The wisdom of Title VI lies in its long-term vision. The federal government created these programs to ensure that the nation possesses enduring capacity in critical languages and regions, regardless of shifting political priorities. Dismantling the current infrastructure in favor of temporary, piecemeal solutions would significantly weaken the United States’ ability to anticipate, understand, and respond to future global challenges.

CAA therefore urges the Department of Education to abandon this proposed rescission and preserve the regulations that have made the Title VI and Fulbright-Hays programs indispensable pillars of the nation’s educational, cultural, and strategic strength.

Respectfully,

Meme Omogbai
Executive Director & CEO
CAA | Advancing Art and Design