Collegial Conversation on Recertification, December 2010

December 17, 2010

SEVP began the SEVIS recertification process in May 2010. This collegial conversation asks representatives from five diverse institution types, all of which have successfully been recertified, how the process went and how they prepared for it.

Linda Melville, international advisement specialist at the University of New Mexico and the ISTA network leader, asked a series of questions on the recertification process. Our contributors are:

  • Jim Hammerschmidt, Director of the Office of International Services, University of Illinois at Chicago
  • Jeff Hutcheson, ELS Language Centers, Assistant Director of US Operations
  • Allison Rhea, Senior Director of Enrollment Management, Sinclair Community College
  • Ravi Shankar, Director, International Office, Northwestern University
  • Ron Vick, Sr., Licensed Counselor, Wayne State College

 

Who did you inform on your campus that SEVIS Recertification was coming and whom did you inform once your institution received its 180-day recertification notice from SEVP? Were there any unexpected responses from others on campus? Do you wish you had informed anyone else?

Jim: We informed the various colleges and school administrators to ensure we obtained current academic program information. Additionally, the Office of Admissions and Records, Institutional Research as well as the Graduate College were notified. Everyone offered their support to ensure we had the information we needed.

Jeff: I informed our President and CEO, along with our VP of Operations, and then informed Regional Directors, as part of our annual I-17 review (we have over 50 campuses), verifying that all I-17s were up-to-date, inclusive of assigned DSOs. We had just gone through re-accreditation the year prior, so all accreditation documents were in order. As a provider of language training, we are limited to one CIP code.

Allison: Upon notification that Sinclair was slated for re-certification I informed my DSOs, the President's Office, the Vice President for Student Services (under which I serve) and Sinclair's Research Analytics and Reporting office. I did not wish I had informed anyone else. All parties who were informed, including myself, were new to their roles since the last re-certification process – so there were no unmet expectations as to how the process was to proceed.

Ravi: All the stakeholders-- Registrar, Institutional Research and University Enrollment, Office of the Provost, General Counsel, Human Resources, Admission offices, Risk Management and System Engineers/Information Technology (these are the people who run our enterprise system-PeopleSoft) -- were privy to the prospect of recertification and once the request was made, we pulled all the key units and people together to coordinate the process. We feel that we had a comprehensive group of key holders and therefore we did not get unexpected responses.

Ron: I informed my immediate supervisor, the Director of Counseling and Advising Services, who is a DSO for our campus and had served for several years as the international student advisor prior to SEVIS and my taking over the responsibilities. To my knowledge, no one else on campus was aware of recertification. Not being the type of person to put anything off, I started immediately to respond, in case there were any problems and to give myself time to get everything they wanted in place.

 

What supporting materials and documentation did you assemble prior to the Recertification process? What was actually requested by SEVP?

Jim: During the many presentations that SEVP made with regard to recertification, our office started to routinely check the information on Form I-17 to ensure that it was up to date. Since we are a large institution that offers many academic programs, we made copies of all literature and website pages pertaining to our academic programs. This was very helpful since SEVIS limits the number of characters you can type on the I-17. Therefore, we were able to provide the website links and attach copies of the information when we submitted the recertification package electronically. We also collected both program information and addresses of our instructional sites. SEVP requested that we submit the Recertification Attestation, Data Sheet, signed I-17 and any supporting documents (i.e. instructional site verification).

Jeff: We assembled proof of accreditation and proof of US Citizenship/Residency (and any name changes) of DSOs. These documents were already maintained and up to date. As we operate in several states, I also verified that all letters of licensure/regulation from the State or District were up to date, inclusive of waivers for operations in States that do not regulate intensive English programs.

Allison: My preliminary work was to review our current I-17 information. I made a list of any demographic information I believed warranted a review and then pursued that particular information. For example, I reached out to RAR to determine the number of Teachers/Instructors Sinclair employs now, as well as Non-teaching employees. SEVP required review and verification of data on two specific forms the I-17 and the NCES Data Sheet. The 3rd and final piece required was a simple Attestation Statement.

Ravi: We knew that we had to keep the I-17 and all student records up to date. We also knew from SEVP's public comments and presentations, they were going to utilize DOE's IPEDS data to reduce the burden on schools. So, we worked with the Office of The Registrar and academic units to ensure data and instructional site consistency. As expected, SEVP used the DOE data-provided to us on a spread sheet- to check against the I-17 and to correct and comment on information in the spread sheet. The recertification request also asked for accreditation and authorization information as part of the Recertification and Attestation Statement; the signed I-17 and Data Sheet.

Ron: Since international advising/PDSO is only a portion of what I do, it is difficult for me to keep up with everything and I can only attend regional NAFSA conferences if they are close enough for me to drive to and the budget allows. With this in mind, I had no supporting materials or documentation in place as I had no idea what to expect. All I knew was that it was coming. The following is an excerpt from the e-mail I received showing what they requested for the recertification process:

Instructions for Recertification

You will receive an email from sevis.recert@dhs.gov containing the attestation statement, update pending statement, data document and fax cover sheet. In order to file for Recertification, you must electronically submit the following documents at the same time:
  1. Attestation Statement: Complete the attestation statement. Complete either section I to Recertify or section II to withdraw from SEVP Certification.
  2. National Center for Education Statistics (NCES) Data Sheet: Review the document for accuracy. If portions of the document are incorrect, make the corrections and sign the document. If the document is accurate, sign the document only.
  3. Form I-17: Print a copy of the Form I-17 from SEVIS and sign the petition. Also sign the supplemental pages A and B.

If the information contained within Form I-17 accurately reflects your school and its operation, submit all three via e-mail at: recert.sevis@dhs.gov, or via FAX SERVER at 877-268-5563. Include the fax cover sheet for all fax submissions. For email submissions, in the subject line type in: RECERTIFICATION PACKAGE followed by your school code.

AND

File for Recertification via SEVIS by clicking the SUBMIT button.

All documents must be received at the same time, and received no later than 11:59 p.m. Eastern Standard Time on the day prior to the CED.

Petitions received on the CED will not be accepted.

 

Does your institution have more than one location or branch listed in SEVIS, and if so, how were multiple campuses or instructional sites addressed by SEVP during the Recertification process?

8 C.F.R. § 214.3(a)(1) states that a petition for school approval (I-17) "must identify by name and address each location of the school that is included in the petition for certification or recertification, specifically including any physical location in which a nonimmigrant can attend classes through the school (i.e., campus, extension campuses, satellite campuses, etc.)." Clearly all branch campuses where F-1 or M-1 students study should be reflected on the I-17. SEVP guidance, however, indicates that schools should also update their I-17 with all "instructional sites" that meet the following criteria:
  • "Meets the Department of Education's definition of a ‘branch campus'[see 34 CFR 600.2 ]; or
  • "Meets most but not all of the branch campus requirements (e.g. All records are centrally stored)" or
  • Is an instructional site where a student "can either complete their degree requirements for a program of study or complete more than 51% of their requirements for a program of study…"
  • SEVP's Recertification Primer for Certified Schools also states that "These additional locations must have... A school official who can physically verify the presence of international students and assist them when necessary."

Jim: Yes, we have six instructional sites that are listed in SEVIS on the I-17. All of these instructional sites were listed on the document based upon previous guidance provided by SEVP at the various conferences as well as telephone conversations that took place during the Recertification process. No fee was assessed by SEVP for listing the instructional sites on the I-17.

Jeff: ELS has 10 campuses listed as sub-campuses or instructional sites, attached to other I-17s. We are currently working with SEVP to consolidate all ELS centers into one I-17, with each center identified as a sub-campus. This move, if possible, provides organizational efficiencies in our business/work flows, while preparing us for the SEVIS II structure. To date, ELS has had only one campus identified for recertification and it was a main campus, without any sub-campuses.

Allison: Sinclair does not have more than one location listed in SEVIS. While Sinclair has added additional instructional locations in the last five years, none of those locations yet meets the definitions as listed above. However, one location will inevitably meet the last definition within the very near future. Once this threshold has been reached we will submit a change request to our I-17 supplement B.

Ravi: SEVP's interpretation of "campus" was based on input and extensive discussions with DSOs. Given the complex institutional structures and multi-disciplinary nature of higher education, SEVP came to the conclusion that an instructional site was a better interpretation than "campus." This eliminated the need for a fee, for which we are grateful. As a result, the recertification process required us to list only instructional sites-Northwestern University has two sites: Chicago and Miami-on the I-17 by clicking on the campus button. Instructions from the Recertification Branch were to list the PDSO as the main school officer for the sites.

Ron: We are a small campus and there is only the one school location listed.

 

Did you do any additional updating of your I-17 information or updating of your school/DSO documentation in preparation for Recertification (e.g. collect passport copies for proof of citizenship of DSOs, require DSOs to certify that they are familiar with the regulations and with their responsibilities, record completion of SEVIS training, etc.)? Did SEVP request further updates during Recertification?

Jim: Whenever new staff is hired we collect copies of passports, update the I-17 to add the new DSOs, and submit the documentation to SEVP. Additionally, we established a practice that every 30 days we would review the I-17 and update when appropriate. Furthermore, when SEVP provided the opportunity for PDSO/DSOs to use their online training tool, we integrated it as part of our new staff orientation program, although it was not required by SEVP. During the Recertification process SEVP only required that our I-17 be updated if necessary prior to the adjudication and that we submit an Update Pending Sheet to alert them of pending adjudication.

Jeff: ELS already utilizes an internal form for DSOs to attest to their familiarization and understanding of pertinent federal regulations and policies, along with the ELS institutional policies and procedures. We provide institutional training and support for our DSOs, requiring training prior to the authorization of DSO responsibilities. As part of this process, ELS collects proof of US citizenship/residency and proof of legal name changes.

Prior to the recertification, I had to request an expedited update to our I-17 (ELS/Nashville), as SEVP had not adjudicated a relocation update (site visit had occurred over a year before the recertification request).

SEVP did not request any further updates during recertification.

Allison: On our I-17, I updated:

  • the date registration begins as those patterns had recently undergone minor changes
  • the average annual number of classes, students, non-instructional employees and teachers/instructors
  • The annual total cost of tuition per student

Further, I reviewed my files to determine that we still had copies of birth certificates/passport for our DSOs and me.

Ravi: As a management and operational issue, we continually review the I-17 for accuracy the DSO information must always be kept current with proof of citizenship. The recertification request asked us to update the I-17 as part of the process. There were no further requests once the I-17 was submitted.

Ron: Some time back I had gathered all of the required documentation (passport copies or birth certificates for proof of citizenship of our DSOs). I have compiled a DSO manual for their use, but there are really only two active DSOs - myself and one person in admissions. Typically she will do data input and I confirm the information and submit the I-20s and from then on I am the only one advising them.

I did update our I-17 prior to submitting the recertification after getting some information from our institutional research office. I called the recertification office to confirm that the minor changes I was making were not something that required adjudication. I don't believe they asked for anything specific to be updated, just that we check and update as needed to make sure it was accurate when we submitted it for recertification. I checked the accuracy of our DSO information, tweaked some of the numbers for student/faculty/staff, etc., and updated our costs.

 

Did you do any auditing of SEVIS records for accuracy in preparation for Recertification? Were you asked to clarify or explain any SEVIS specific information by SEVP?

Jim: Since we run audit reports on a regular basis all of our SEVIS records are kept as current as possible. The only document we had to review and provide any changes to was the spreadsheet that was generated from the NCES database SEVP provided at the time of recertification.

Jeff: ELS has a routine audit of its files, as required for batch processing, so we did no additional preparation. SEVP did not ask for any clarification or explanation of any SEVIS specific information outside of that requested in the recertification itself.

Allison: No, it was never my understanding that this was an expectation or a necessity in this process. SEVP did not ask for clarification or explanation.

Ravi: As stated above, it is critical to begin the audit process early. We ran query reports from our system and used the data from the SEVIS alerts to check and cross-check data of student records; requested information from key holders for programs, IPEDS and institutional data, vis-à-vis the NCES data. We were not asked to explain any SEVIS specific information.

Ron: I did not audit any records in SEVIS as I was involved in submitting the majority of them and felt there were no major problems that should be addressed. I have not been asked to clarify or explain any SEVIS specific information by SEVP.

 

Were there any other ways that you prepared for the recertification process? Is there anything else you wish you would have done beforehand?

Jim: Since SEVP through their many means of communications explained to academic institutions what to expect during the recertification process, I feel we were well prepared for the process. In addition, when SEVP contacted us to see if we would be interested in participating in the BETA Recertification process, they went over the process once again and were always available to us during the process. The entire process was simple and straightforward. As a result, I think we were in a pretty good place when the actual e-mail notification concerning recertification came to us.

Jeff: Having the accreditation and proof of state regulatory compliance or waiver from state oversight helped greatly. Coordinating President and DSO schedules does present some time delay in obtaining signatures. Having signatures done ahead of time or immediately upon receipt of recertification notice is helpful.

Because of the time needed to collect signatures, I wish I had begun immediately in the collection of signatures on the I-17 itself. Scheduling signatures over the summer proved problematic and time consuming.

Allison: I would answer both questions "No". The process was extremely straightforward and uncomplicated. Having the facts about the institution and our current demographics was essential. At its core, the process was simply about ensuring an accurate description of your institution.

Ravi: To reiterate, it is very important to continually look at the I-17 and create a system where you can track new programs and levels that are being developed. We cannot capture every new program, but at least we have done due diligence. In addition, since SEVP had communicated their thinking and expectations, we feel that we were prepared by our audit process and involving stakeholders. As a BETA school, we had ample opportunities to work with the School Recertification Branch on some of the instructional and process issues.

Ron: There was no preparation for me, I just responded as best I could. If anything, I wish there had been more detailed information about what they were looking for as I submitted the attestation statement based on what we had on the I-17, which in turn is based on our catalog information. The first time it was not accepted because they said I failed to mention that our institution is "authorized to operate in the state by Nebraska Coordinating Commission for Postsecondary Education" and to please include this licensing body in the Attestation Statement. I had included our accreditation by the Higher Learning Commission of the North Central Association of Colleges and Schools, but nowhere in our catalog or anywhere on our publications or website could I find information about the Nebraska Coordinating Commission being a licensing body and part of our accreditation, which was the intent of the attestation statement. I called the recertification office and mentioned this, but they wanted it included, so I added this information and submitted everything again. Within a few days I received a notice saying,

This is to acknowledge receipt of all required documentation for your SEVIS recertification. While your petition for recertification is pending adjudication, you will maintain your existing approval status. Moreover, you will retain your SEVIS access to issue Forms I-20 and maintain current F-1/M-1 student records.

This was followed a few days later (11/05/2010) by an attached letter saying:

Student and Exchange Visitor Program
Notice of Confirmation of Complete Filing

The Student and Exchange Visitor Program (SEVP) received your institution's petition for Recertification within 180 days of your certification expiration date. The School Certification Branch (SCB) will adjudicate your petition to determine whether your institution continues to comply with the Federal regulations that govern SEVP Certification and nonimmigrant students. This letter serves to notify you that the SCB will review the petition for Recertification and you will be notified of the outcome in the coming weeks.

Sincerely,

Recertification Team
School Certification Branch

On 11/29/2010 I received notification that our institution had been recertified. They listed a couple of discrepancies they wanted addressed. The information the letter contained is below:

"Student and Exchange Visitor Program
Notice of Recertification

The Student and Exchange Visitor Program (SEVP) School Certification Branch approves your institution's petition for Recertification. Your Certification Expiration Date is:

March 29, 2013.
Discrepancies:
  1. In the state regulatory agency field of your school's Form I-17, you have listed "Nebraska State College Board of Trustees ". This field should read "Nebraska Coordinating Commission for Postsecondary Education". Please file an update to correct this field as soon as possible.
  2. Student records in SEVIS must be updated to include travel information of students (i.e. passport number, visa number, port of entry, etc.).
SEVIS may temporarily reflect a different CED based on the date of adjudication. Please disregard that date. The SEVP will notify your institution 180 days from your next CED via SEVIS. The SEVP requests that you continue to update your institution's information via SEVIS as per the regulations. If you have any questions, you may contact the School Certification Branch at (703) 603-3400 or you can email the Recertification Team at Recert.Sevis@dhs.gov.

Sincerely,

Recertification Team,
School Certification Branch

Also attached with the letter was an SEVP Recertification Scorecard that had headings for:

  • Section 1 (Accredited/Non-Accredited) with subheadings for Licensed (local, state, federal), Financial Statements, Facilities, Teacher Qualifications, Attendance and Grading Policies, and Course Catalogs.

    All seemed to have a rating of Yes/No and we had all "Yes." No idea what that means, but I have to assume it was good?
  • Section 2 was for ownership and had a question on whether a change of ownership was reported in 60 days, so being a State College this was marked n/a.
  • Section 3 was for school reporting. Ratings again appeared to be yes/no (we had yes on all) and included Completed Updates, Correct I-20 Issuance - Programs, and Correct I-20 Issuance - Visas
  • Section 4 was Student Reporting. Yes/No ratings for the following: Students have physical location address that is different from school physical address, Student name accurate, and Student birth date accurate

It had a place for total score, which only said "Decision." It had a green, yellow, and red "stoplight rating" category. We were green "pass."

Final Outcome:

I did update our I-17 to reflect the changes they wanted adding the Coordinating Commission information I mentioned above.

To my knowledge, the majority of travel information is not accessible to us. POE, visa/passport numbers, etc., need to come from different entities. The only thing we can update is the "A" number, and that is not a mandatory field, and I usually don't input anything that is not mandatory. It was a strange process and I'm not sure what to do about their request for the travel information updates.

 

Having been through it, what advice would you offer others?

Jim: Keep your I-17 updated. Keep a file on all of your academic programs, especially any changes or additions. Also, keep up with the status of instructional sites (especially addresses, programs offered, number of international students attending classes there). Continue to build a strong network of support from the various offices and colleges that are the repository for the information that you need to update your I-17. For example, Office of Admissions and Records, various colleges and schools, Institutional Research, etc. Finally, utilize your staff (if you have staff members within your office) you do not have to do this alone.

Jeff: The process is straight forward; just read and follow the instructions, and make sure that you have access to and have prepped all necessary departments. Do not wait for recertification to ensure that your I-17 is up to date and you will lessen impact and delays. Pay attention to and adhere to the timelines, have a plan in place and begin immediately when the recertification alert is received. There is no need to risk adverse actions or decisions because of delays.

Allison: The most important people to work with are those who hold the demographic data of your institution. Ensure that your Institutional Research group knows that you will be calling on them for some basic elemental data. Review your I-17 now to reacquaint yourself with the information SEVP currently holds on your institution.

Again, for me this process was not cumbersome and most importantly was not confusing. I commend SEVP for providing clear instructions and guidelines. In fact, when I inadvertently faxed the wrong (unsigned) copy of a form, I was contacted in very quick, professional fashion to ask me to address the error. Don't be intimidated by the process – let it work for you as an opportunity to view your institution through the eyes of others.

Ravi:
  • Do not panic!
  • Gather your staff and look at this as a project together. You do not have to do this on your own.
  • Involve your key holder/stakeholders in the process.
  • Continually gather academic and instructional site information.
  • Once I-17 is submitted with changes, do not make any changes (it cancels any updates) until it's adjudicated.
  • Call the Recertification Branch with questions, concerns and assistance.
  • It's a very simple process.

Ron: Advice I would offer is that it is not as horrible an experience as I expected. Don't be afraid to call the number they list and ask for guidance - they were very pleasant to talk to and seemed eager to help.

At this point everything has been completed and we have been recertified through March 29, 2013.