Advocacy Alert: MSCHE Submits Comments Regarding DHS Proposal

On September 29, 2025, Heather F. Perfetti, Middle States Commission on Higher Education (MSCHE) President, provided written comments on the United States Department of Homeland Security (DHS) proposal to amend the regulations on the admissions period for certain classifications of the nonimmigrant status, published in the Federal Register via Docket ID ICEB-2025-0001.

The letter stated:

As a student-centered accreditor who understands the importance of welcoming international students into our institutions of higher education, we support any regulations that ensure efficient processes and integrity as part of the academic student visa approval process. DHS has proposed to apply a finite time period to F academic student visas for the identified purpose of consistency in enforcement. That consistency will come at the price of potentially cutting off a nonimmigrant student, lawfully in the country to pursue higher education, while in the middle of their higher education program. MSCHE recognizes the need for consistency in any legal and regulatory process. However, higher education programs, in responding to student needs and calls for innovation, vary so extensively from program to program and institution to institution that a finite time period does not make sense for this classification. Only the institution of higher education supporting the F academic student visa is best positioned to identify the exact nature and length of the program.

While MSCHE also recognizes the importance of enforcement mechanisms, there are other mechanisms available to DHS, including reinforcement of the reporting mechanisms through the supporting institution. These include but are not limited to the information exchange mechanisms in place through the institution and the Student and Exchange Visitor Information System (SEVIS). MSCHE ensures compliance with all applicable laws in monitoring institutions and has worked with SEVIS related to institutional compliance. We would strongly urge DHS to consider maintaining the duration status determined by the terms and conditions of the nonimmigrant classification and not move to apply a fixed time period as it relates to F academic student visas.

Read the full letter.