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AMIS's Response to Duration of Status

The Department of Homeland Security published a proposed rule on September 25 that would end "Duration of Status" for international students. Currently students may remain in the US as long as they maintain student status. This proposed rule would require students to finish a degree in a certain amount of time or apply for an extension on their visa. People may comment on this proposal until October 26 at This response has been submitted on behalf of AMIS.

October 13, 2020

Re: DHS Docket No. ICEB-2019-0006-0001, Comments in Response to 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

Atlanta Ministry with International Students (AMIS) is a nonprofit 501(c)3 organization whose mission is to promote global understanding through friendship and hospitality with international students and scholars in the greater Atlanta area.

We urge that the proposed rule be withdrawn in its entirety, and that admission for the duration of status remain in effect.

For over 40 years, we have witnessed the many benefits that international students and exchange visitors have contributed to our campuses, communities, and country. International students contributed $850.6 million dollars to our state economy and supported over 10,200 jobs in the 2018-2019 year.

Many of the international students are the best and brightest of their home countries and the future leaders of the world. As a result of their interaction with Americans they return to their home countries with a better understanding of the warmth and generosity of the American people.

The education of American students and communities is improved with the presence of international students in our higher education institutions. American students develop an understanding of other countries and cultures that will help them be successful in a global marketplace and connected world.

The proposed rule is a significant unwarranted, unnecessary and harmful

intrusion into academic decision-making. The rule encroaches on the role of the academic institution. It should be the institution’s, not the federal government’s, decision whether and when to grant students additional time to complete a degree. Restricting international student enrollment in language training programs to a lifetime aggregate of 24 months (including breaks and an annual vacation) is arbitrary. The length of time students require in ESL programs varies, and can extend beyond 24 months.

The proposed date-specific admission does not conform to academic programs, and harms students’ reliance on duration of status. The rule does not provide an admission period beyond 2- or 4-years. Four-year admission limits are impractical, and do not conform to academic program lengths. Most college students don’t graduate in four years. Many PhD programs require more than four years to complete, even if the student works continually and diligently towards their degree. The rule doesn't recognize today’s reality of the time needed for degree completion in many academic programs. This affects PhDs, surgery residents, neuroscience postdocs, joint degree program participants, and those pursuing BS/MS programs, among others. The new proposed rule would hold international students to a different standard. For instance, international students would only be able to request time off due to “compelling academic reasons,” including medical conditions or other natural disasters or major events.

This rule makes US higher education less competitive internationally. The proposed rule change will discourage international students from applying to higher education institutions in the USA. Many students and postdocs are not able to transfer to other programs easily (if at all) if their extension is not approved, and must leave the United States as a result. If U.S. colleges and universities are unable to provide international students with the confidence that they will be able to complete their entire academic program with that school, they may decide to study in another country as a consequence. The U.S. will then lose a critical pipeline of advanced STEM knowledge and talent, possibly to competitor nations. Other countries see the value of international students and have policies to attract and retain them. It is a mistake to create yet another hurdle to study in the United States.

Implementing the rule will have significantly greater economic effects on U.S. higher education institutions, including from the loss of the international student population resulting from the rule. Any loss of tuition revenue from international students will also have an adverse multiplying effect on the local economy.

In summary, we urge that the proposed rule be withdrawn in its entirety, and that admission for the duration of status remain in effect. It is better for the United States to welcome international students, rather than make it more difficult for them to study here.


Rev. Irene Wong

Executive Director, AMIS

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