In what it claims is an effort to "de-politicize" the funding of its grants and contracts, the Department of Education is considering new requirements for "high-risk" applicants who file suits, lobby or engage in other forms of "propaganda."

Critics, however, see the proposals as an attempt to politicize the funding process and possibly part of the New Right's effort to "defund the left."

The proposals, which were circulated in a "confidential" July 13 memo from deputy general counsel Hugh Joseph Beard Jr., would amend the department's grant and contract regulations to set up "special approval procedures" for high-risk applicants.

According to the memo, these include groups that are new, have never won a government contract before, get most of their money from the government, sue any federal, state or local government or engage in "propaganda."

Such applicants would have to provide additional information to the department, including their constitution, by-laws and "a list of all matters upon which the organization has been engaged in propaganda."

Propaganda, the memo said, includes participating in a campaign, lobbying on a bill or regulation or assisting others in litigation.

Ed Dale, a spokesman for the Office of Management and Budget, said that the Education Department's plans weren't part of any government-wide directive. But he said that inspectors general in some agencies have discussed such ideas as ways of tightening up grant regulations and he believed that the Commerce Department was considering similar proposals.

Rep. Don Edwards (D-Calif.), chairman of the House Judiciary subcommittee on constitutional rights, said that the ideas in Beard's memo "smack of McCarthyism" and would have "a chilling effect on a person's right to speak publicly on any issue." He said that he is planning to hold a hearing on the subject next week.

An Education Department spokesman said that the proposals are still under consideration. He said that the department is studying whether new regulations are needed "to protect the taxpayers from misuse of their monies . . . . There are a number of laws prohibiting the use of federally appropriated funds for lobbying activities. However, in the past these laws have not been effectively enforced."

The spokesman said that there was no specific incident that prompted the study, although he noted that Congress last year had expressed concern about Legal Services Corp. suits against government agencies.

The Beard memo comes at a time when leaders of the New Right are campaigning against federal aid to organizations the conservatives see as having a liberal bent. But the department spokesman denied any connection, saying, "We are trying to depoliticize federal funding, left, right and center."