TRACE Act Demands Schools Disclose Foreign Funding and Curriculum Purchases to Parents

This bill, officially called the Transparency in Reporting of Adversarial Contributions to Education Act (TRACE Act), creates new rules for how K-12 schools must handle and disclose financial ties to foreign governments or what the bill calls a “foreign entity of concern.” Essentially, if a school wants to keep receiving federal education funds, it now has to grant parents specific, detailed rights to investigate any foreign funding sources, the staff paid by them, and any curriculum purchased with that money. These new rights are triggered only when a parent submits a written request to the school.

The Parent’s Right to Know: What Changes?

If you’re a parent, this bill gives you three key rights, all of which must be fulfilled within 30 days of your written request. First, you get the right to review and get free copies of any school curriculum or teacher training materials purchased using money from a foreign government or a “foreign entity of concern.” The school must provide access to these materials at least every four weeks. Second, the school must provide a written response stating exactly how many staff members are paid, even partially, by money from these foreign sources. Third, the school must disclose any donation, written agreement, or financial transaction it has with a foreign government or entity, including the name of the foreign country and the amount and terms of any money received. Think of it as a mandatory financial audit response, but for parents.

The School’s New Homework: Compliance Costs

For local school districts, this isn't free. The TRACE Act makes these new disclosure requirements a condition of receiving federal education funding. This means districts now have significant new administrative burdens. They must track and document all financial transactions and staff payments linked to foreign sources, and they must be prepared to compile this information quickly—within 30 days—every time a parent asks. For a busy school administrator, the effort involved in researching, compiling, and providing physical access to potentially voluminous curriculum materials "at least every four weeks" could be substantial. If a district struggles with staffing or record-keeping, this compliance could be a real headache.

The Fine Print: What’s a “Foreign Entity of Concern”?

The bill relies heavily on the term “foreign entity of concern,” but it doesn't define it itself. Instead, it points to a definition found in another piece of legislation (42 U.S.C. 19221(a)). This is common in policy, but it means the scope of what schools must disclose could change if that external definition changes. For schools, this means they have to be constantly aware of what constitutes a “foreign entity of concern” as defined by a separate federal law, adding complexity to their compliance efforts. While the goal is transparency regarding foreign influence, the implementation relies on school districts becoming experts in external federal definitions to avoid losing funding.