There were three potentially seismic developments this week that further illustrate the stakes that universities like ours face. The first is already in effect, albeit was just blocked by a federal court. The second has wide-ranging potential implications. And the third is a tragic foreshadowing of what could yet come.
Note: Last evening, the Department of Health and Human Services Office of Civil Rights, in response to “unprecedented public interest” posted the formal Notice of Violation online. We will have additional things to say about it in the days ahead. Right now, we would simply observe that the conclusion suggests that Columbia has 10 days (well, now 8) to “comply with the regulation and to take such corrective action as may be appropriate.” That takes us to June 1.
Harvard’s International Student Ban
On May 22, 2025, the Department of Homeland Security formally revoked Harvard’s ability to enroll international students via the Student and Exchange Visitor Program. The letter, which you can see here, is very serious. It states: “The revocation of your Student and Exchange Visitor Program certification means that Harvard is prohibited from having any aliens on F- or J- nonimmigrant status for the 2025–2026 academic school year. This decertification also means that existing aliens on F- or J- nonimmigrant status must transfer to another university in order to maintain their nonimmigrant status.”
In other words, not only is Harvard barred from enrolling new international students, its existing international students—roughly 6,000 of them—must transfer to other institutions to remain in the United States. This isn’t a real choice for many: in schools where many PhD students are international and who are forced to disrupt their research ecosystem by transferring, this will be devastating; it will also shatter the research programs of their advisors, which are built around these specific students.
We take no pleasure in having predicted this. Using publicly available tuition and enrollment data, we estimated Harvard’s financial exposure at $560 million per year—however, we will now revise that to $300 million based on a better understanding of Harvard’s international population. Furthermore, we assessed this as a high short-term risk. Were a similar action taken against Columbia, the comparable impact would be approximately $800 million.
One day after the ban was announced, Harvard sued, and a temporary restraining order was swiftly granted.
We were curious so we consulted OPIR on Columbia’s exposure. The results are below. The x-axis is number of international students. The y-axis is number of total students. Schools that are over 50% international are denoted with a red dot. In brief, there are widely divergent impacts based on school (for example, the undergraduate schools are only 21% and CUIMC is 16%, but SEAS Graduate is 65%, SIPA is 63%, A&S Professional Studies is 59%, and GSAS is 58%). The upper right quadrant shows schools at high risk for the University as a whole—due to both high enrollment and high international enrollment—but schools like SIPA and GSAPP are at high risk themselves due to the >50% proportion of international students. In short, this is not a STEM-only problem.
Two of the three first-quadrant schools (GSAS and Professional Studies) are associated with the Faculty of Arts and Sciences. According to this Columbia Spectator article from 2016, “Arts and Sciences has also become reliant on the proliferation of master’s-only programs and expanded its enrollment and offerings at the School of Professional Studies to generate hundreds of millions dollars of new tuition revenue over the last decade.” Back then, SPS enrollment was at 2,500; it’s now at over 4,000. If we scale A&S’s 2016 budget of $823 million by inflation, the total annual budget of A&S now is likely more than $1 billion now. Our assessment is that indirect costs from federal grants are likely a de minimis part of the budget because only the natural sciences departments have federal grants; therefore SPS international tuition revenue is likely an essential component of the budget without which A&S could not survive in anything like its current form.
Implications for Federal Student Aid
As we shared earlier this week, the Department of Health and Human Services has now formally found Columbia in violation of Title VI of the Civil Rights Act. This is a serious determination: the federal government has concluded that the University “showed deliberate indifference to the hostile environment faced by its Jewish students,” a finding that carries potential funding consequences.
On the other hand, the sequence here is unusual. Ordinarily, the government issues a violation first and then—with warning—initiates financial enforcement. Here, it happened in reverse: the $400 million federal funding freeze was announced in March, and the Title VI finding has only now followed. In that sense, this is not new information so much as the bureaucratic formalities catching up to earlier political decisions.
At the time of the March freeze, the law firm Hogan Marren Babbo & Rose laid out the standard enforcement process for Title VI. What’s notable is that the current administration appears to be following that process with some measure of procedural discipline. If that pattern holds, and if Columbia contests future steps in court, the legal path will likely run through the Administrative Procedure Act. The bar for a university to prevail on “arbitrary and capricious” grounds is high, and we are not confident it would be met. The recent end of Chevron deference only adds to the uncertainty.
If additional enforcement measures follow, one possible next step is action against federal financial aid. When we first flagged this as a long-term tail risk, it was largely theoretical. Now, based on the Hogan memo and recent developments at other institutions, it appears well within scope.
This matters. The initial freeze targeted research funding, particularly in STEM—most of whose faculty had absolutely nothing to do with those identified with the government’s grievances. That impacted a subset of the university. Financial aid is different. It cuts to the center of our teaching mission, and its loss would affect nearly every school and student population.
We’ve tried to estimate what’s at stake. Columbia collects $1.51 billion in net tuition revenue. Of that, we believe roughly $1.14 billion, or over 76%, is dependent on federal support or facilitation. Let us repeat: even tuition—the portion many assume to be independent revenue—is overwhelmingly contingent on federal support. Visa policies, loan programs, and financial aid structures mean that the vast majority of Columbia’s net tuition is federally mediated, not market-secured. This includes:
- $800 million in international student tuition (as we previously estimated), which depends on visa policies and federal discretion.
- $354 million in direct federal financial assistance, according to the Uniform Guidance Report, and laid out below:
That $354 million does not include funds from the Post-9/11 GI Bill or the Yellow Ribbon Program, nor does it include institutional aid—which Columbia provides out of pocket from endowments, annual funds, and cross-subsidies—and which is substantial at $595 million. Based on data from OPIR:
- $256 million for Columbia College, undergraduate SEAS, and General Studies
- $68 million for GSAS PhD tuition waivers (one might assume some of this is funded by research grants)
- $178 million for Morningside professional schools
- $93 million for CUIMC graduate and professional schools (similarly, one might assume some of this is funded by research grants)
Here is a way to visualize it. The ones dependent on government are highlighted in green.
These figures are net of grants, but they illustrate the integrated nature of our financial model. Previously, we mooted that one of the options for universities that wanted to “fight Trump” might be to shrink into a Hillsdale-esque teaching-only school without research. Well, it appears that even if we were to do that, 76% of tuition revenue depends on federal government support or facilitation. Without it, our financial aid programs would be the first to unravel.
That is the context in which this week’s Title VI announcement should be read. Not as an isolated headline, but as the next turn in a process that is already underway, and that continues to deepen the structural vulnerabilities of the modern research university.
Bottom line: We are here because of declining bipartisan public support for higher education. According to a recent survey by the University of Chicago Project on Security and Threats, half of the country sees us as “the enemy.” The other half is hardly brimming with excitement. We must take ownership of our story and communicate our value to the American taxpayer. Otherwise, this situation where America’s incredible research enterprise which has underwritten American prosperity and security is both 1) dependent on federal funding and 2) under immense pressure from a lack of political or public support—is untenable.
A Tragedy in Washington
We mourn the horrific shooting in Washington, D.C., and grieve the loss of Yaron Lischinsky and Sarah Milgrim. May their memories be a blessing. Violence of this nature is always a tragedy, but this one carries a particularly chilling resonance. The alleged perpetrator had been affiliated with a communist organization (which led protests at Columbia’s gates, and since disavowed him), and has now been praised by certain extremist groups as embodying “the highest expression of anti-Zionism” and “an act of solidarity and love.” One these groups (which has a following at Columbia) is now going further, calling for its members to be “completely willing and ready at all times to KILL.”
We previously wrote in these pages: “Meanwhile, these extremists are going beyond public displays of support for terrorism, to claiming they are actively in coordination with and ‘seeking instruction’ from actual terrorists… Left unchecked, we fear it is only a matter of time before some unhinged individual decides to stop ‘playing make-believe’ and turns to actual violence.”
Tragically, it appears that time has come. When those who commit acts of violence are celebrated rather than condemned, we cross a line—from protest into something far more sinister. What once may have felt like theoretical risk has now crystallized. This is no longer a matter of campus politics. It is a matter of domestic terrorism and national security.
News Roundup
– May 23, 2025. In an op-ed in the NYT, Harvard professor Steven Pinker confronts what he calls “Harvard Derangement Syndrome”: the increasingly unhinged vilification of America’s most famous university by critics across the political spectrum, culminating in the Trump administration’s effort to defund it entirely. A longtime Harvard professor and vocal internal critic, Pinker doesn’t deny the institution’s flaws (academic intolerance, political homogeneity, mishandling of antisemitism) but argues that cartoonish portrayals obscure more than they reveal. This essay insists that complex problems require measured solutions—not ideological purges
– May 23, 2025. The Guardian reports on a panicked mood on Harvard’s campus after the Trump administration tried to walk back the legality of international students enrolling at the school, the oldest American university. Harvard has sued over this “blatant violation” of the constitution, and the ban has been prevented (for now) by a Massachusetts federal judge. International students compose 27% of the Harvard enrollment–around 6,700 students. One student said that he felt more hopeful given Alan Garber’s strong denunciation of the ban and the prevention from the federal judge: “They’ve got our back. I have to trust that they want what is best for all of us.”
– May 23, 2025. The WSJ reports that a judge has granted Harvard a temporary restraining order from the government’s mandate to stop enrolling international students. On Thursday, it was announced by the Department of Homeland Security that it was curtailing Harvard’s ability to matriculate international students because of Harvard’s perceived failure to create a “safe campus for students, especially Jewish ones” and stated that there were a great deal of “anti-American, pro-terrorist agitators” enrolled at the school. On Thursday evening, 1636 Forum, a Harvard alumni group like Stand Columbia Society, published a comprehensive analysis of the government’s actions on Harvard’s ability to host international students and the complex decisions Harvard now faces. You can subscribe here to receive a copy of the analysis immediately in your inbox.
– May 22, 2025. The WSJ reports that a government investigation has come to the conclusion that Columbia “violated federal civil-rights” by “ignoring the harassment of Jewish students by classmates” and acting with “deliberate indifference towards student-on-student harassment of Jewish students” following Oct. 7, 2023. According to the investigation, the deliberate indifference comes from not acting fast enough on punishing students misconduct or addressing matters like vandalism. Anthony Archeval, who is acting director of HHS OCR, said, “The findings carefully document the hostile environment Jewish students at Columbia University have had to endure for over 19 months. We encourage Columbia University to work with us to come to an agreement that reflects meaningful changes that will truly protect Jewish students.” A spokesperson for the university stated, “We understand this finding is part of our ongoing discussions with the government.” We will have more to say about this next week.
– May 22, 2025. The College Fix reports that on Monday, the Justice Department launched a Civil Rights Fraud Initiative leveraging the False Claims Act to look into accusations against “federally funded entities that knowingly violate civil rights laws” such as “favoring one race over another.” Attorney General Pam Bondi said in the press release, “Institutions that take federal money only to allow anti-Semitism and promote divisive DEI policies are putting their access to federal funds at risk.” A critical piece of the initiative is that it encourages “private citizens to file complaints on behalf of the government, called “qui tam” lawsuits, against those who have allegedly defrauded the government.” Significantly, anyone who “successfully brings” such a suit could walk away with part of the fines, a way to incentivize potential campus whistleblowers who have firsthand knowledge.
– May 22, 2025. The WSJ published an opinion piece by two people who believe that “libraries are wasted” on elite college students. They comment on a “tweet” from Columbia University Apartheid Divest on May 7 after the “storming” of Butler library on campus: “This entire building and all the knowledge it holds will be liberated for good, and every book will belong to the free children of the world.” The protesters had joined arms in the reading room and “chanted that they had nothing to lose but their chains.” The writers think about what “liberating the libraries” might alternatively look like, including open-access “digitization” of materials.
– May 21, 2025. The WSJ reported on Columbia’s Wednesday graduation ceremony. Claire Shipman, acting Univeristy president, spoke to the absence of a pro-Palestinian protester, Mahmoud Khalil, who is currently detained by ICE in Louisiana but was due to graduate this year. She also spoke to affirm her support of international students at Columbia, saying, “We firmly believe that our international students have the same rights to freedom of speech as everyone else and they should not be targeted by the government for exercising that right.” In explaining the government’s choice to ban international students from enrolling at certain American schools, Homeland Security Secretary Kristi Noem called it “a privilege, not a right, for universities to enroll foreign students and benefit from their higher tuition payments to help pad their multibillion-dollar endowments.”
– May 21, 2025. The Gothamist adds some color to student reactions to Shipman’s speech on Wednesday’s commencement. While there was occasional booing during her remarks, some students also decided to walk out. SIPA graduate Kayla Bouazouni said, “There’s been a lot of discontent with the administration’s handling of Mahmoud Khalil’s case and just in general international students’ safety on campus so, a lot of students, we had a show of protest by walking out.” She also labeled Shipman’s speech “performative,” explaining, “A lot of the things she said did not match up with what we’ve lived on campus.”
– May 20, 2025. Gothamist reports that in a bizarre development, Tarek Bazrouk, a 20-year-old accused of assaulting demonstrators at multiple NYC protests (including punching two Columbia students), had $750,000 in cash—along with weapons and spent shell casings—stashed in a Manhattan apartment. Now facing federal hate crime charges and up to 30 years in prison, Bazrouk has pleaded not guilty. His defense says the money came from a Connecticut smoke shop job, not flight plans. The case, spotlighted by the Department of Justice as part of its aggressive push against antisemitism, underscores the growing federal role in protest-related prosecutions, and the blurred lines between activism and extremism.
– May 19, 2025. The NYT reported that Mohsen Mahdawi, another former pro-Palestinian protester and Columbia student, was able to attend Commencement, where a judge had granted him special permission to travel after his detention by ICE. He has been accused of no crime. Rather, Marco Rubio stated in a report that some of his actions could “‘potentially undermine’ the Middle East peace process by reinforcing antisemitism” although the people protesting in favor of Palestine do not see their critique of Israel as antisemitic. On Sunday evening, an unofficial graduation ceremony was put together for Mahmoud Khalil and other student protesters who were not able to come to the graduation in person. About 50 students, including some who were expelled from Columbia for protest-related incidents, were awarded mock degrees from “The People’s University for Palestine.”
– May 16, 2025. According to the Guardian, ICE is being accused of using “false pretenses” to “hunt for Columbia students.” According to certain accusations, the warrant applications were a “pretext” to get to two different students for the eventual goal of deporting them, and ICE “effectively misled a judge in order to gain access to the homes of students.” According to a “recently unsealed search warrant application,” ICE relayed to a judge that it was looking for a warrant because they were looking into Columbia for “harboring aliens.” Nathan Freed Wessler, an ACLU lawyer, says that this proves ICE “was manufacturing an allegation of ‘harboring’, just so agents can get in the door… to arrest them.” He is concerned by the government leveraging the “harboring aliens” legal term in order to enter the building, saying, “There is a lot of concern by people and organizations for [the Trump administration’s] extremely aggressive interpretations of the harboring statute. As this episode illustrates, those interpretations don’t hold up to scrutiny.”
– May 8, 2025. In another bizarre case, the Daily Guardian reports that Li Sixuan, 28, a Chinese beauty queen and 2024 Miss Universe Shenzhen titleholder, has been jailed for 240 days after using forged documents to gain admission to the University of Hong Kong’s linguistics master’s program. Claiming a Columbia University degree she never earned, Li also faked a “distinction” HKU diploma and paid an agent over 380,000 yuan (or about US$53,000) to facilitate the fraud. Her attempted escape to mainland China failed after HKU launched an investigation and confirmed with Columbia that she was never enrolled. Magistrates cited her “consistently dishonest” conduct in handing down the sentence. She had, however, completed an “online course” at Columbia.