Updated: November 14, 2006




Phase II Validation Project




During the week of November 6, 2006, the Student and Exchange Visitor Program (SEVP) sent out a second set of e-mails to selected schools, as part of "Phase II" of their "SEVIS Data Validation Project." This phase is similar in all regards to the Phase I project discussed below, except for the dates involved.

SEVP says that schools selected for the Phase II project must return information to SEVP by Monday, November 27, 2006, which is the end of the 10-working-day timeframe.

In Phase I, approximately 10% of schools were selected. SEVP has said that Phase II is on a much smaller scale.



Phase I Validation Project



On September 29, 2006, the Student and Exchange Visitor Program (SEVP) sent a message to all SEVIS users that "At the request of the Department of Homeland Security (DHS), SEVP is conducting a validation exercise to measure SEVIS data integrity." The project involved SEVP "providing selected schools with a list of F/M nonimmigrant students at their school that have a SEVIS record that is either active or shows that the student was expected to report to the school prior to September 30, 2006," and asking that the school’s Principal Designated Official (PDSO) respond within 10 working days of receiving the list, with the enrollment status of the student records listed.

SEVP stated that all e-mails to selected Phase I schools had been sent out as of October 4. The list of students was provided in a Microsoft Excel spreadsheet. Only selected schools that received an Excel spreadsheet e-mailed from SEVP had to participate.



NAFSA Liaison with SEVP



Despite having regular liaison calls with SEVP, NAFSA had not been apprised by SEVP of either Phase I or Phase II of this project prior to their inception.

When Phase I began, NAFSA spoke with SEVP on Tuesday, October 3, 2006, to inquire about the nature of the exercise, to express the challenges it creates for selected schools, and to express members' frustration in being asked to provide data that they believe has already been submitted as part of the regular SEVIS reporting requirements. At the same time, NAFSA reiterated schools' desire to maintain accurate SEVIS records.

SEVP told NAFSA that the Department of Homeland Security (DHS) asked SEVP to initiate this exercise, and that DHS specified a fast turn-around time.

Can More Tme Be Given to Respond?

SEVP cites 8 CFR 21 4.3(g)(1) as the regulatory basis for the requests and for the 10-day response period. NAFSA said that schools that were asked to respond about large numbers of students (some larger schools have reported being sent lists of between 2,000 to more than 5,000 students) have asked for more time to respond. NAFSA suggested, for example, a period of at least 30 days. SEVP stated, however, that the Department of Homeland Security's request did not leave room for extensions. (Note: federal holidays do not count as one of the 10 days)

Can a School Respond in an Electronic Format Other than Excel?

NAFSA also questioned the need to respond on the same Microsoft Excel spreadsheet that was sent to the school. Some schools, for example, have said that they might be able to respond within 10 days, but only if they can send the data in a format that is more consistent with the school's electronic systems. SEVP stated that a school that feels it will be unable to comply using the Excel spreadsheet should e-mail SEVP at [email protected] as soon as possible to inform them of the format that they would like to use. SEVP said they will respond schools on a case-by-case basis.

If I Have a Specific Question on How to Respond, Whom Do I Contact?

The SEVP e-mail notification states that inquiries should be sent via e-mail to SEVP at [email protected], with SEVIS Validation Project Participant Inquiry in the subject line.

Some questions might be answered in the Frequently Asked Questions prepared by SEVP and referenced above. SEVP consolidated these FAQs from questions submitted to [email protected] by schools selected to participate in the validation exercise.

How Was My School Chosen?

NAFSA does not know how schools were chosen, but being selected should not be understood as an indication that the school's compliance is at issue. The SEVP instructions state that "The data from this exercise will influence future policy, but will not effect [sic] the school's SEVP certification."

SEVP says that in Phase I, approximately 10 percent of SEVIS-certified schools were selected to participate, but that Phase II is on a much smaller scale. For both Phase I and Phase II, SEVP confirms that "If your school did not receive an e-mail with attachment, you were not selected to participate in this exercise."

What Other Steps Can I Take Right Now?

Selected schools may want to contact their general counsel to advise them of this request, particularly if they believe that the 10-day turn-around time cannot be met.