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Guidance for ELPs to Submit Comments to Proposal to End Duration of Status
EnglishUSA has prepared guidance for English language programs on how to submit a comment letter regarding the proposal to end Duration of Status and what to include in that letter before the public comment deadline ends on September 29.
EnglishUSA prepared a preliminary analysis [LINK] of the proposed role and how it impacts English language programs. The rule's changes and implications do not adequately describe ELPs. The information below presents XXX and YYY. It is essential in your program's or your comments that you include XXXX.
Please be sure to take action with NAFSA's advocacy campaign to Congress to defend D/S.
NOTE: NAFSA and several other larger international education association do NOT address the impact on English language programs. It is vital for English language program professionals to understand the intricacies of the harmful changes being proposed so that we....
Key Considerations
Please share this information with whoever is preparing a comment on behalf of your program/institution. If one has already been submitted, consider submitting one of behalf of your program.
As you draft your comment, keep in mind that the following guidance is intended to help guide you and give you an example and ideas, but the comment should be edited with original input.
Any text included in a program/institution comment should be, where possible, unique, as DHS may bundle any comments that are too similar to each other (we know what AI can do!).
Choose bullet points you want to focus on and the arguments that are most relevant to your program/institution and edit them to better reflect your perspective on the issue. You do not need to cite this document in your comment, nor do you need to provide all of the information suggested here.
The Federal Register notice says: "Comments providing the most assistance to DHS will reference a specific portion of this rule, explain the reason for any recommended change and include the data, information, or authority that supports the recommended change."
Program/institution comments should be signed by a representative of the program/institution and provide the business contact information of the representative for any follow-up questions or concerns. However, keep in mind that this comment will be publicly available, so personal addresses or cell phone numbers are not recommended. Who signs the letter is at the discretion of the program/institution and does not impact the review of the letter.
Comments can only be submitted online. You will click on the button, "Submit a Public Comment."
You may type directly into the comment box but the text must be fewer than 5,000 characters or you can upload a file containing your comment. We recommend submitting a text-searchable PDF.
The proposed rule to replace D/S (Duration of Status) with a fixed time period for admission and impose a 24-month aggregate limit on English language training will severely burden students and diminish the competitiveness and flexibility of U.S. English Language Programs (ELPs) and the broader English Language Training (ELT) industry. All evidence suggests that such changes are out of step with the dynamic needs of language learners and the realities of educational program structures in the United States.
Caveats
EnglishUSA strongly opposes the elimination of Duration of Status and this proposal. What follows here is an overview of our field in the larger scope of studying in the U.S., how this proposal the industry as a whole and how this proposal and assumptions exacerbate this....and how particular aspects, one impacting others, is harmful to students, programs, and the U.S. as a leader in XXXX
A few alternatives are being suggested to show that the arbitrary, blanket definitions and proposed actions may describe a government "fix" for overstays by degree-seeking students cannot apply to English language programs.
In other words, while the association is strongly against D/S and recommend the withdrawal of this proposal, will describe in this section XXXXX how ELPs need to be treated....
Overview
xxxxx
Terms/concepts that cannot be arbitrarily applied to ELPs
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EnglishUSA has prepared guidance for English language programs on how to submit a comment letter regarding the proposal to end Duration of Status and what to include in that letter before the public comment deadline ends on September 29.
EnglishUSA prepared a preliminary analysis [LINK] of the proposed role and how it impacts English language programs. The rule's changes and implications do not adequately describe ELPs. The information below presents XXX and YYY. It is essential in your program's or your comments that you include XXXX.
Please be sure to take action with NAFSA's advocacy campaign to Congress to defend D/S.
NOTE: NAFSA and several other larger international education association do NOT address the impact on English language programs. It is vital for English language program professionals to understand the intricacies of the harmful changes being proposed so that we....
Key Considerations
The proposed rule to replace D/S (Duration of Status) with a fixed time period for admission and impose a 24-month aggregate limit on English language training will severely burden students and diminish the competitiveness and flexibility of U.S. English Language Programs (ELPs) and the broader English Language Training (ELT) industry. All evidence suggests that such changes are out of step with the dynamic needs of language learners and the realities of educational program structures in the United States.
Caveats
EnglishUSA strongly opposes the elimination of Duration of Status and this proposal. What follows here is an overview of our field in the larger scope of studying in the U.S., how this proposal the industry as a whole and how this proposal and assumptions exacerbate this....and how particular aspects, one impacting others, is harmful to students, programs, and the U.S. as a leader in XXXX
A few alternatives are being suggested to show that the arbitrary, blanket definitions and proposed actions may describe a government "fix" for overstays by degree-seeking students cannot apply to English language programs.
In other words, while the association is strongly against D/S and recommend the withdrawal of this proposal, will describe in this section XXXXX how ELPs need to be treated....
Overview
xxxxx
Terms/concepts that cannot be arbitrarily applied to ELPs
xxxxx
How XX Harms ELPs
xxxxx
How YY Harms ELPs
xxxxx