[ASA_PEWS] Fwd: ASA CBSM - URGENT Call to Action on proposed DHS rule change on international students

Wed Sep 10 09:52:02 PDT 2025

---------- Forwarded message ---------
From: Cunningham, David <00000051c3804f8e-dmarc-request at listserv.asanet.org>
Date: Wed, Sep 10, 2025 at 9:32 AM
Subject: ASA CBSM - URGENT Call to Action on proposed DHS rule change on
international students
To: <ASA-CBSM at listserv.asanet.org>

Hello CBSM community,

In advance of our next section announcements message around proposals for
next year's ASA panels, I'm forwarding an important time-dependent call for
action, related to proposed changes by the Department of Homeland Security
(DHS) that have a fast-approaching deadline for public comment.

Apologies for any repeated postings you see across ASA section lists, but
especially if you haven't received these details already, please see the
letter attached, which calls for action around DHS's proposed rule
<https://www.regulations.gov/document/ICEB-2025-0001-0001> to replace
existing "duration of status" horizons for international students and
scholars with a "fixed time period" admissions model. If implemented, this
policy change would severely impact graduate students and postdoctoral
researchers whose work requires legal status beyond 4 years.

The attached letter drafted by our colleagues provides additional
background on the implications of this proposed regulation and the related
call for action, and the template below is a helpful resource for filing
effective comments on the proposed rule. In 2020, during the first Trump
administration, these comments successfully led to the withdrawal of a
similar immigration policy proposal.

Note also that the current policy comment window will close on *September
29, 2025*.

Thank you for your consideration of this urgent matter.

Best wishes,

David

_________________

*Resource template for commenting on the proposed DHS regulation*

Proposal Text: *https://www.regulations.gov/document/ICEB-2025-0001-0001
<https://www.regulations.gov/document/ICEB-2025-0001-0001>*
Leave Comment Here: *https://www.regulations.gov/commenton/ICEB-2025-0001-0001
<https://www.regulations.gov/commenton/ICEB-2025-0001-0001>*

*Introduction*

   - *Explain why you are interested in the regulation and highlight any
   experience with the subject of the rule that may distinguish your comment*

*Incorporate human impact stories: Include personal testimonies and
community perspectives—especially from U.S. students, faculty, employers,
and institutions—to demonstrate the *real-life consequences beyond the
international student community.

   - *State your position clearly:*

I urge DHS not to implement the proposed changes to 8 CFR 214.2(f)(5)(i)
and to maintain the current Duration of Status framework. The proposed
policy changes will lead to a backlog of hundreds of thousands of extension
requests that the current staff level at DHS cannot handle. This is
unenforceable because it creates confusion for both college administrators
and scholars and drives leading scientists away from American institutions.
The detailed reasons are listed below:

*Background and analysis*

   - Regarding the proposed change to remove duration of stay (D/S) to
   limit the admittance period to 4 years or fewer

a. Virtually every doctoral program takes longer than 4 years. The Survey
of Earned Doctorates from the National Science Foundation in 2024 estimates
the average doctoral program takes 5.7 years, meaning that all doctoral
international students would have to file an I-539 extension of stay form
at least once. In 2023, there were 206,433 international students pursuing
PhDs, or 15.3% of all international students at the time.
b. Currently, the USCIS processing times tool estimates that an I-539
extension review for F, J, and M visas takes 3.5 months, unless applicants
pay a premium price of  $1,965. Almost every single doctoral student
needing to file this form would significantly lengthen the wait time
c. All of those students would have to submit extension requests for each
year after the 4 year maximum, which would impose unnecessary costs and
strain on USCIS and the broader immigration system. According to USCIS’s
own data, pending cases are already at an all-time high in Q2 FY 2025, with
a record 11.3 million pending cases.
d. Each extension application carries the risk of denial, even for
something as small as a clerical error; in 2022, 10% of USCIS’s petition
rejections were due to clerical errors. A student could possibly spend 4+
years working on their degree, only to not be able to continue.
e. Designated School Officials (DSOs) would have to undergo additional
training and adaptation, estimated to cost $93.3 million across the sector
in year one.
f. The additional bureaucratic complication and financial cost disrupts
academic studies and discourages international students from applying and
studying in the US.
g. F-1 visas are not just limited to higher education: in 2024, there were
over 54,000 international students in K-12 schools.

   - Regarding the proposal to limit "school transfer and change in
   educational objectives"

a. Prohibiting graduate F-1 students from changing educational objectives
or transferring from within the United States severely limits
graduate-level study

   - Overall, the proposal undermines America’s ability to attract global
   talent, weakens technological innovation, slows economic growth, and harms
   national interests.

a. In 2024-25, international students contributed an estimated $46 billion
to the US economy and supported 400,000 jobs, but this year, NAFSA is
estimating that newly implemented visa bans and regulations affecting
international students will cost the economy $7 billion and 60,000 jobs.
b. International students are an important source of talent in critical
fields. Recent data from the Association of American Universities shows
that 73% of STEM international graduates continue to live and work in the
US several years after graduation, providing vital scientific,
technological, and economic benefits to the US. A 2024 report from the
National Science Board estimates that foreign-born individuals make up 43%
of doctorate-level scientists and engineers in the US.
c. The proposed changes jeopardize U.S. leadership in global higher
education. The US higher education system hosts X students, X of whom are
international.
d. the rule makes it harder for U.S. institutions, research labs, academic
teams, and entrepreneurs to recruit and retain qualified workers.
e. Many of the proposed changes faced widespread opposition in 2020,
amassing over 32,000 comments, 99% of which were opposed.

   - The Risks to the Integrity of the F, J, and I Nonimmigrant
   Classifications, as outlined to support the proposal, are not enough to
   justify such a drastic change in policy which would affect every
   international student in the US.

a. Under risks within the F classification, DHS alleges that as of 2025,
2,100 international students have been on F-1 status for 15 years or more,
have entered consecutive educational programs or transferred schools to
maintain this status, and could therefore be abusing the system to stay in
the US indefinitely. F-1 visas are issued for students from K-12 all the
way through doctoral educational programs. A student who began studying in
the US during high school, who is now finishing a doctoral degree, would be
included in this list of 2,100, and viewed as suspicious despite fully
complying with the laws and intent of the visa policy. Furthermore, between
2010-2024, the US has issued 5,817,019 F-1 visas, meaning that these
potential cases of fraud make up at most 0.036% of all F-1 issuances.
b. Under risks within the J classification, the proposal cites several
examples of J-1 holders who were charged with serious counts of fraud or
intellectual property theft, who are all Chinese nationals. A program which
investigated Chinese Communist Party affiliated espionage in academia that
officially ran from 2019-2022 investigated hundreds of academics for fraud
and espionage, but by 2021, less than 30 percent of cases resulted in
convictions or guilty pleas — a staggering discrepancy from the overall
federal rate, which sits above 90 percent. The US admits hundreds of
thousands of Chinese students every year (329,541 in 2024) who are already
subject to stringent restrictions during visa application. Although
national security concerns are valid, these extremely rare cases should not
justify a proposed rule change that would affect millions of international
students.

   - Conclusion: It is more practical to offer constructive alternatives
   before such a policy is withdrawn because it is unenforceable. I recommend
   maintaining the D/S framework, preserving the F-1 grace period, and
   ensuring that immigration policy remains stable and predictable.

------------------------------

To unsubscribe from the ASA-CBSM list, click the following link:
http://listserv.asanet.org/scripts/wa-ASANET.exe?SUBED1=ASA-CBSM&A=1

-- 
chris chase-dunn   邓宇歌
institute for research on world-systems
university of california-riverside
riverside, ca 92521 USA
mailing address: 2007 mt vernon ave, riverside, ca 92507 usa
Consider using my textbook in your class:
_Social Change: Globalization from the Stone Age to the Present_ Routledge
-------------- next part --------------
A non-text attachment was scrubbed...
Name: Call for action to oppose DHS new rule.pdf
Type: application/pdf
Size: 160764 bytes
Desc: not available
URL: <https://lists.ucr.edu/pipermail/asa_pews/attachments/20250910/f3ab0409/attachment-0001.pdf>