On November 19, 2009, NAFSA and AIEA (Association of International Education Administrators) submitted a joint comment on the Department of State's proposed rule to amend the J exchange visitor regulations at 22 CFR Part 62, Subpart A, the part of the regulations that applies to all exchange visitor programs and categories. The NAFSA/AIEA comments consist of a main comment letter and a detailed addendum.
The comment letter focuses on:
- The need for focusing on the spirit of exchange and public and citizen diplomacy.
- The need for interagency coordination regarding SEVIS.
- The need for tailoring regulatory requirements to account for differences between exchange visitor program categories.
The more technical addendum focuses on:
- The need to take into account the new data paradigms of SEVIS II, including the “paperless” environment of the future, and the SEVIS II “customer account” that will make individual nonimmigrants responsible for reporting name and address changes.
- The need for SEVIS to leverage data that is already in other U.S. government data systems, to avoid duplicative data entry efforts and improve the quality of data in SEVIS.
- The need to grant exchange program sponsor the level of discretion appropriate to manage their programs.
- The need to rely on measures of program quality and review that already exist in a program sponsor’s industry, rather than creating parallel or additional structures that are expensive and do not add to program integrity or security.
- The need to incorporate public comment into future changes to minimum health insurance coverage levels, and to provide time to transition current plans into the new coverage levels.
- The need for regulatory and policy clarity.