On October 12, 2012, NAFSA submitted comments on SEVP’s draft guidance on school governance. NAFSA suggested that SEVP:
- Consistently define the school as the legal entity petitioning SEVP for certification, and as the legal entity bound by the obligations of certification. While in many cases a “school” will be coterminous with a single instructional site, the instructional site itself should remain conceptually a physical location where the school provides instruction to F or M students, rather than the entity that takes on legal obligations.
- Develop precise guidance on how the I-17 should be completed and I-20s be issued, either as part of this guidance for adjudicators, or in the SEVP Form I-17 user manual.
- Designate “preponderance of the evidence” as the proper standard of proof for adjudicators to use.