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Letter from Marlene Johnson to the State Department Desk Officer in the Office of Management and Budget
State Department Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20530
Re: 30-Day Notice of Proposed Information Collection: Recordkeeping, Reporting and Data Collection Requirements Under 22 CFR Part 62 – the Exchange Visitor Program, Student and Exchange Visitor Information System (SEVIS); OMB 1405-0147
Dear Sir or Madam:
This letter constitutes the comment of NAFSA: Association of International Educators on the above-referenced information collection regarding the Exchange Visitor Program, Student and Exchange Visitor Information System (SEVIS). NAFSA is the world’s largest association of international education professionals in higher education, with more than 8,700 members throughout the United States and worldwide. Our members include most of the responsible officers and alternate responsible officers who manage the SEVIS system for colleges, universities, and exchange programs.
NAFSA fully supports the purpose for which SEVIS was created: the implementation of a workable electronic tracking system for foreign students and exchange visitors. However, SEVIS has fallen short of meeting this objective while also becoming a flawed and burdensome system for users and federal agencies to maneuver. SEVIS requires further development before it can reach the system’s information collection goals or be relied upon for reporting and enforcement activities, especially as it relates to the Department of State’s Exchange Visitor Program (J SEVIS).
The strength of this country’s research community, which resides to a large extent at the colleges, universities, and exchange programs mentioned above, depends heavily on the Office of Exchange Visitor Programs. NAFSA applauds the efforts put forward thus far by the EVP staff to make needed modifications to J SEVIS in order to support the requirements of the user community. We recognize the challenge of this task considering that the database is housed in a separate government agency altogether.
More Resources Are Needed to Develop Technology for J SEVIS
The amount of resources and support dedicated to J SEVIS is presently insufficient to meet the needs of its users. The Office of Exchange Visitor Programs has a very small staff available to handle the numerous J SEVIS-related inquires and requests for necessary data fixes submitted by responsible officers and alternate responsible officers from across the country. For example, if a request is made for a simple data fix, there is only one staff person available with the technical expertise and the direct access to make corrections to the J SEVIS system. Therefore, as the office receives ever-increasing numbers of requests regarding technical problems, the staff is unable to keep up with the demand, which leads to long delays. These delays leave program sponsors in a state of uncertainty, and leave exchange visitors unable to access benefits related to their status, such as employment or travel. Moreover, these delays increase the risk that they will violate their visa status, due to no fault of their own. Clearly, more staff resources need to be provided to assist exchange program sponsors with their J SEVIS-related questions and requests.
There is also a lack of technological development in J SEVIS. Functions necessary for exchange visitor programs to be able to comply with current regulations continue to be unavailable, unlike similar functions available to the F visa program. For example, in the regulations, an exchange visitor college student, during his or her studies, is eligible to participate in academic training and the student’s SEVIS record is to be updated to reflect this. However, the academic training functionality is not yet available in J SEVIS, while functionality for recommending and authorizing F-1 practical training is available. Additionally, there are functions in J SEVIS that are not working correctly, such as the annual report function. This is arguably the most important reporting function for exchange visitor programs to be able to use, as every program sponsor is required to submit an annual report to DOS detailing program activities. Program sponsors rely on this function to provide them with the detailed information they need for the annual report. Responsible officers frequently run these reports, and receive the response “no data found” when in fact information has clearly been entered. This is a serious limitation that impacts the reliability, quality and utility of the data in the system for reporting purposes. More resources are needed to improve the technological development of J SEVIS.
“Workarounds” Create Data Integrity Problems
DOS’s Exchange Visitor Program does recognize instances where J SEVIS is not functioning properly and therefore creates “workarounds” as needed in order to allow users to input data or otherwise use the system. The workarounds often require the user to input inaccurate data or somehow trick the system to allow the user to fulfill the reporting requirements. While, these workarounds are certainly necessary, given the state of the system, it must be recognized that they impact the quality and utility of the information within J SEVIS, resulting in inaccurate or unreliable data. Therefore, reports run from the system will not extract correct or complete information, such as the data needed for the annual report. The ongoing use of workarounds is evidence that the system is not yet functioning at a level that would support its use for enforcement or reporting purposes.
Again, NAFSA greatly appreciates the effort that the Office of Exchange Visitor Programs has expended to implement modifications to J SEVIS. We also appreciate DOS’s willingness to include NAFSA in the ongoing discussion regarding the challenges present in the system. Several improvements are required though, before J SEVIS will fulfill its stated goals.
Thank you for this opportunity to comment.
Sincerely,
Marlene M. Johnson
Executive Director and CEO
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20530
Re: 30-Day Notice of Proposed Information Collection: Recordkeeping, Reporting and Data Collection Requirements Under 22 CFR Part 62 – the Exchange Visitor Program, Student and Exchange Visitor Information System (SEVIS); OMB 1405-0147
Dear Sir or Madam:
This letter constitutes the comment of NAFSA: Association of International Educators on the above-referenced information collection regarding the Exchange Visitor Program, Student and Exchange Visitor Information System (SEVIS). NAFSA is the world’s largest association of international education professionals in higher education, with more than 8,700 members throughout the United States and worldwide. Our members include most of the responsible officers and alternate responsible officers who manage the SEVIS system for colleges, universities, and exchange programs.
NAFSA fully supports the purpose for which SEVIS was created: the implementation of a workable electronic tracking system for foreign students and exchange visitors. However, SEVIS has fallen short of meeting this objective while also becoming a flawed and burdensome system for users and federal agencies to maneuver. SEVIS requires further development before it can reach the system’s information collection goals or be relied upon for reporting and enforcement activities, especially as it relates to the Department of State’s Exchange Visitor Program (J SEVIS).
The strength of this country’s research community, which resides to a large extent at the colleges, universities, and exchange programs mentioned above, depends heavily on the Office of Exchange Visitor Programs. NAFSA applauds the efforts put forward thus far by the EVP staff to make needed modifications to J SEVIS in order to support the requirements of the user community. We recognize the challenge of this task considering that the database is housed in a separate government agency altogether.
More Resources Are Needed to Develop Technology for J SEVIS
The amount of resources and support dedicated to J SEVIS is presently insufficient to meet the needs of its users. The Office of Exchange Visitor Programs has a very small staff available to handle the numerous J SEVIS-related inquires and requests for necessary data fixes submitted by responsible officers and alternate responsible officers from across the country. For example, if a request is made for a simple data fix, there is only one staff person available with the technical expertise and the direct access to make corrections to the J SEVIS system. Therefore, as the office receives ever-increasing numbers of requests regarding technical problems, the staff is unable to keep up with the demand, which leads to long delays. These delays leave program sponsors in a state of uncertainty, and leave exchange visitors unable to access benefits related to their status, such as employment or travel. Moreover, these delays increase the risk that they will violate their visa status, due to no fault of their own. Clearly, more staff resources need to be provided to assist exchange program sponsors with their J SEVIS-related questions and requests.
There is also a lack of technological development in J SEVIS. Functions necessary for exchange visitor programs to be able to comply with current regulations continue to be unavailable, unlike similar functions available to the F visa program. For example, in the regulations, an exchange visitor college student, during his or her studies, is eligible to participate in academic training and the student’s SEVIS record is to be updated to reflect this. However, the academic training functionality is not yet available in J SEVIS, while functionality for recommending and authorizing F-1 practical training is available. Additionally, there are functions in J SEVIS that are not working correctly, such as the annual report function. This is arguably the most important reporting function for exchange visitor programs to be able to use, as every program sponsor is required to submit an annual report to DOS detailing program activities. Program sponsors rely on this function to provide them with the detailed information they need for the annual report. Responsible officers frequently run these reports, and receive the response “no data found” when in fact information has clearly been entered. This is a serious limitation that impacts the reliability, quality and utility of the data in the system for reporting purposes. More resources are needed to improve the technological development of J SEVIS.
“Workarounds” Create Data Integrity Problems
DOS’s Exchange Visitor Program does recognize instances where J SEVIS is not functioning properly and therefore creates “workarounds” as needed in order to allow users to input data or otherwise use the system. The workarounds often require the user to input inaccurate data or somehow trick the system to allow the user to fulfill the reporting requirements. While, these workarounds are certainly necessary, given the state of the system, it must be recognized that they impact the quality and utility of the information within J SEVIS, resulting in inaccurate or unreliable data. Therefore, reports run from the system will not extract correct or complete information, such as the data needed for the annual report. The ongoing use of workarounds is evidence that the system is not yet functioning at a level that would support its use for enforcement or reporting purposes.
Again, NAFSA greatly appreciates the effort that the Office of Exchange Visitor Programs has expended to implement modifications to J SEVIS. We also appreciate DOS’s willingness to include NAFSA in the ongoing discussion regarding the challenges present in the system. Several improvements are required though, before J SEVIS will fulfill its stated goals.
Thank you for this opportunity to comment.
Sincerely,
Marlene M. Johnson
Executive Director and CEO
