NAFSA Comments on Proposed Changes to Form I-539

August 06, 2013 Download pdf


On June 13, 2013, U.S. Citizenship and Immigration Services (USCIS) proposed several changes to Form I-539, Application for Extension or Change of Status, and the instructions. NAFSA submitted this comment letter encouraging USCIS to revise the form to accommodate the "duration of status (D/S)" period of admission and to improve the form instructions by:

  1. explicitly stating that a photocopy of an admission stamp or a print-out of the electronic I-94 record from CBP's web site will suffice as evidence of admission;
  2. resolving inconsistencies in Form I-539 and Form I-765 instructions for M-1 students;
  3. further explaining the agency's practices concerning extension of status for multiple applicants and change of status; and
  4. defining "A number" and clarifying when an applicant should provide one.