Westminster Urges Protection of International Students
October 22, 2020
SALT LAKE CITY – Westminster College urges the U.S. Department of Homeland Security to abandon a proposed
rule that would require a fixed period of stay for international students instead
of the current duration of stay rule. The proposed rule would severely restrict international
students and exchange visitors by making it difficult for them to complete their studies. The
1. Eliminate the “duration of status,” which allows those on F-, I-, or J-visas to remain in the United States for the duration of their studies instead of a fixed period of time;
2. Introduce a “fixed time period” of admission for these visas, requiring renewal or extension after a maximum of four years, regardless of the length of the relevant educational program; and
3. Limit student visa admissions to two years for: (a) natives or citizens of countries on the State Sponsor of Terrorism List, regardless of their current country of residence; (b) citizens of countries with a visa overstay rate of over ten percent; and (c) those accepted to an unaccredited school or a school that does not use E-Verify.
Westminster submitted the following comment on October 21, 2020 to U.S. Immigration and Customs Enforcement, and the U.S. Department of Homeland Security regarding the proposed rule “Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media.” Comments must be submitted by October 26, 2020.
On behalf of Westminster College in Salt Lake City, Utah, I submit this comment letter in response to the U.S. Department of Homeland Security’s (Department) proposed rule, Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media (DHS Docket No. ICEB-2019-0006-0001), published September 25, 2020.
We urge that the proposed rule be withdrawn in its entirety, and that admission for the duration of status remain in effect. International students and exchange visitors contribute immensely to our campus community in Salt Lake City, as well as to the entire country and communities where they are studying. Westminster’s commitment to diversity is incomplete without the voices and lived experiences of our international students. At Westminster College we currently have 76 F1 international students from 30 different countries. In addition to the incredible diversity in language, thought, and culture that they bring to our classrooms in Utah, international students also make a very significant contribution to our local economy. According to the NAFSA International Student Economic Value Tool, 7,946 international students and their families contributed over $218 million to the Utah economy in 2018-19, supporting 2,185 jobs.
The proposed rule is unnecessary because the SEVIS system already provides DHS with detailed information related to almost every student and exchange visitor event that could impact a student or exchange visitor’s compliance with the regulations. The proposed rule creates an unnecessary, expensive, time-consuming and ultimately undue burden on school officials and students to apply for extensions. DHS should instead effectively use the data already collected in SEVIS to make data-driven initiatives focusing on risk factors, rather than subjecting entire nonimmigrant categories to a process that is duplicating the already heavy SEVIS reporting obligations. The workload of our institution’s Designated School Officials dedicated to immigration advising and SEVIS reporting has already increased tremendously with the new STEM OPT reporting requirements introduced in recent years. The additional workload that will come with many extension requests for students moving from English language programs to a bachelor’s degree, or bachelor’s degree to master’s degree will cost our institution greatly in terms of time and money.
Academic decision-making should be left in the hands of the trained experts at the educational institutions, not within a government regulation. At Westminster College we have faculty and staff who are trained academic advisors who assist students towards timely degree completion. There are many circumstances in which a student could take more than the standard 4 years to complete an undergraduate degree. Commonly students will need additional developmental coursework in math or writing. Or they might decide to change their major or add a second major or minor which will require additional time to complete. The phrase “compelling academic reasons” is troublesome because it is not clearly defined by the rule, meaning that the government will have more discretionary power over students than the academic advisors and faculty members who design the curriculum. Schools should maintain the authority to decide when academic extensions are warranted; it is an overstep of regulation by government to try and disrupt this system.
Finally, this rule makes US higher education less competitive internationally and will have significant negative financial implications for institutions and the local economies they support. In the past four years it has been increasingly difficult to recruit international students. International student enrollment at Westminster College is half of what it was five years ago. The United States is losing prospective students especially to Canada and Australia who have national recruitment plans and more welcoming policies for international students. It is a mistake to create yet another hurdle to study in the United States.
This change is not needed. We urge you to withdraw this proposed rule in its entirety and instead focus on a national plan to make the United States more welcoming to international students.
Past-chair, Study Utah
Assistant Provost for Global Learning
Salt Lake City, UT
Westminster is a private, independent, and comprehensive college in Salt Lake City, Utah. Students experience the liberal arts blended with professional programs in an atmosphere dedicated to civic engagement. With the goal of enabling its graduates to live vibrant, just, and successful lives, Westminster provides transformational learning experiences for both undergraduate and graduate students in a truly student-centered environment. Faculty focus on teaching, learning, and developing distinctive, innovative programs, while students thrive on Westminster’s urban Sugar House campus within minutes of the Rocky Mountains.