Letter to DHS and DOS with Recommendations on Visa Processing and OPT in Light of COVID-19 Crisis and Presidential Proclamation
Posted: May 06, 2020
Modified: August 20, 2020
Posted: May 06, 2020
Modified: August 20, 2020
The Presidents’ Alliance Steering Committee transmitted a letter to the U.S. Department of Homeland Security (DHS) and U.S. Department of State (DOS) containing recommendations regarding visa processing and Optional Practical Training (OPT).
May 6, 2020
|The Honorable Mike Pompeo
Secretary of State
U.S. Department of State
2201 C St., NW
Washington, DC 20520
|Chad F. Wolf
U.S. Department of Homeland Security
245 Murray Lane, SWWashington, DC 20528
Re: Recommendations on Visa Processing and Optional Practical Training (OPT) in Response to COVID-19 CRISIS and Presidential Proclamation
Dear Secretary Pompeo and Acting Secretary Wolf:
I write on behalf of the Presidents’ Alliance on Higher Education and Immigration (Presidents’ Alliance) to provide recommendations regarding specific policy and regulatory recommendations that the U.S. Department of Homeland Security (DHS) and the U.S. Department of State (DOS) can adopt to support international student and scholar visa processing and the continued vibrancy of our nation’s international student education, particularly in regards to Optional Practical Training (OPT). The COVID-19 crisis represents a growing and singular threat to American higher education, critical research, and the American economy during these turbulent times.
The non-partisan Presidents’ Alliance comprises over 450 college and university presidents and chancellors of public and private institutions. Together, our members’ institutions enroll over five million students across 41 states, D.C., and Puerto Rico. The Presidents’ Alliance is committed to supporting policies that create a welcoming environment for international, immigrant, and undocumented students, and are deeply concerned about how changes in our nation’s immigration policies and practices impact our students and campuses and the communities and states we serve.
We laud DHS and DOS for the flexibility already demonstrated by agencies to support the administration of international student education by our campuses. However, there is a strong need for longer-term, more comprehensive approaches. We also are particularly concerned that under the administration’s 30-day review of nonimmigrant programs, prospective international students and international students currently in the United States completing their educational experiences may be subject to an expanded ban. We urge you, based on widely available scholarship and research, to issue recommendations that these international student and scholar programs, including OPT, be excluded from future immigration bans.
Turning to the impacts of the COVID-19 crisis, we respectfully bring to your attention that the closure of U.S. consulates across the world can threaten life-saving research should access by international students and scholars be closed off much longer as well as the future finances of our colleges and universities. While some admitted international students scheduled visa-interview appointments, many still cannot, and others receive interview dates well beyond the start of their academic programs. The impact of these delays includes graduate students playing a key role in vital biomedical research at leading universities. At the same time, our current international students need continued support in their efforts to participate in OPT and STEM OPT, programs that also support American innovation and industry.
We are increasingly aware that DOS has not taken enough steps to institute alternative measures to issue student visas in a timely manner. There are common-sense actions DOS could take now to review and approve student visas in preparation for the end of the COVID-19 pandemic. Failure to do so could mean the loss of a quarter of a million new international students in the upcoming fall semester. The recent projections of a 25 percent decline in international student enrollments would mean the loss of $10 billion or more–threatening institutions, American jobs, and crucial research, including research related to responding to and preventing health pandemics. A dramatic decline in international students–their GDP contributions and the jobs they support–will only further dampen our economic rebound. All told, during the 2018-19 academic year, one million international students and their families contributed approximately $41 billion to our national economy, and the economic impact of our international student community more than tripled in the last ten years.
We ask you to consider supporting the following policy changes to ensure the new and continuing enrollment of international students at our institutions who bolster American innovation, research, and industry, especially during this time of critical public health challenges and economic turbulence.
1. Temporary Measures to Support Student and Scholar Visa Processing
First, we urge DOS and DHS to develop and publicly release full contingency plans for visa processing this year that will accommodate the timely requirements of the academic calendar and the surge in visa applications as a result of the consulate closures due to COVID-19, as well as clearly communicate the timetable for visa processing to potential students. Specific measures include:
2. Temporary Measures to Support International Education and Optional Practical Training (OPT)
COVID-19 is driving a dramatic increase in compliance and regulatory questions for campuses and international students. Although the government has granted temporary leniency as it relates to online education limitations for international students, our students and institutions need that leniency to continue through fall 2020 and the uncertainty of the pandemic period. It is vital that DHS provide clarity and guidance to ensure current international students can maintain their immigration status, remain eligible to change their status, and be able to access post-completion practical training as permitted under current DHS regulations.
This support is particularly critical as reducing OPT would lead to a .15 percentage increase in unemployment by 2020, with a total job loss of 443k positions and 255k job reduction for native-born workers, according to a Business Roundtable report. Moreover, a National Foundation for American Policy study found that OPT did not reduce job opportunities for U.S. workers; unemployment rates are lower in fields with large numbers of OPT participants. Specific measures of support include:
We thank you for your long-standing support for America’s colleges and universities, and we respectfully request that DHS and DOS safeguard the future of international education in America and its contributions to critical research and the U.S. economy.
Executive DirectorPresidents’ Alliance on Higher Education and Immigration
The Honorable Eugene Scalia, Secretary, U.S. Department of Labor
Kenneth T. Cuccinelli, Senior Official Performing the Duties of the Director, U.S.
Citizenship and Immigration Services
Matthew T. Albence, Acting Director, U.S. Immigration and Customs Enforcement
Mark A. Morgan, Acting Commissioner, U.S. Customs and Border Protection
Michael A. Dougherty, USCIS Ombudsman, U.S. Citizenship and Immigration Services
Rachel Canty, Director, Student and Exchange Visitor Program, U.S. Immigration and Customs Enforcement
Kevin Saba, Deputy Assistant Secretary for Private Sector Exchange, Acting
Charles Wollenhaupt, Acting Deputy Assistant Secretary, Private Sector Office
Trent Frazier, Executive Director, Office of Academic Engagement & Campaigns
 Proclamation No. 10014, 85 Fed. Reg. 23,441 (April 22, 2020).
 NAFSA, The United States of America Benefits from International Students (2019), available at https://www.nafsa.org/sites/default/files/media/document/isev-2019.pdf.
 The Economic Impact of Curbing the Optional Practical Training Program, Business Roundtable, https://www.businessroundtable.org/policy-perspectives/immigration/economic-impact-curbing-optional-practical-training-program (last visited May 4, 2020).
 Madeline Zavodny, Nat’l Found. for Am. Policy, International Students, STEM OPT and the U.S. STEM Workforce, National Foundation for American Policy (2019), available at https://nfap.com/wp-content/uploads/2019/03/International-Students-STEM-OPT-And-The-US-STEM-Workforce.NFAP-Policy-Brief.March-2019.pdf.