In a Federal Register notice published on June 6, 2012, the Department of State (DOS) invited public comments on changes it is proposing to Form DS-7002, Training/Internship Placement Plan (T/IPP). That form is required in the Trainee, Intern, and Student Intern J-1 exchange visitor categories.
A copy of the proposed DS-7002 can be downloaded to the right. For comparison, access a copy of the current Form DS-7002 here.
Comments are due to DOS by July 6, 2012. The Federal Register directs the public to submit comments by e-mail to [email protected] with “OMB Control Number 1405–0170” in the subject line of the message, or by fax to 202–395–5806, “Attention: Desk Officer for Department of State.” (DOS also asked NAFSA to request that members also send courtesy copies of their comments directly to the Exchange Visitor Program at [email protected], if it’s not too much trouble, in addition to submitting their comments as above)
A brief summary of the proposed changes to the form:
Participant Information section
- The checkboxes indicating that the form will be used for Trainee, Intern, or Student Intern will be removed
Site of Activity Information
- The DUNS Number field will
- The student intern regulations [22 CFR 62.23(i)(3)(iii)(A)] still require program sponsors to obtain the Dun & Bradstreet identification number (DUNS) of all potential host organizations (unless the host organization is an academic institution, government entity, or family farm). However, the DUNS number would no longer have to be provided on the DS-7002.
- The questions: “Does your
organization have a Worker’s Compensation (WC) policy;” and “Will your WC
Policy cover the intern/trainee?” will be added.
- Use of the word “your” would seem to apply to the site of activity, not to the program sponsor, but DOS could clarify this by asking instead, “Does the host organization have a worker’s compensation policy,” and “will that WC policy cover the intern/trainee?”
- The form will ask for the “Number
of Full-Time Employees” and the “Annual Revenue.”
- Clarification is needed as to whether this information should be provided about the site of activity or about the host organization.
- The contractual
certifications are expanded, for each party. Some notable changes:
- Under the program sponsor certification is the requirement for sponsors to certify that they have “verified with the Supervisor” that “continuous on-site supervision and mentoring of trainees and interns will be provided by experienced and knowledgeable staff” and that skills, knowledge, and competencies will be received “through the structured and guided activities listed in the T/IPP, and will include activities such as classroom training, seminars, rotation through several different departments, attendance at conference, and similar learning experiences.”
- Attestations regarding deviations from the T/IPP
- Attestations that the purpose of activity is to receive training, not to provide “sources of labor.”
- Attestations that supervisors and sponsors will contact each other and the Department of State regarding risks to the health, safety, or welfare of the participant or of behavior that may bring the Department or the exchange visitor program into disrepute.
Training/Internship Placement Plan
- Divides the “Knowledge, Skills, or Techniques to be imparted during this phase” question into 4 specific sub-questions
- Separates the Methods of Supervision and Methods of Evaluation question into two separate questions.