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sponsoring organizations will shut down and will not be able to afford the personnel and expense that would be
bureaucratic organizations that can afford the extra costs and overhead, and risk blocking the flow of new and
innovative ideas into the vital exchange program arena.
CHF suggests that before we pile on additional burdens and tasks for sponsors that we consider the big picture and
whether it will block new players from participating and bringing fresh energy to the plate.
Suggested alternatives for insuring sponsor compliance in lieu of Management Audits
CPA firm McLean, Koehler, Sparks & Hammond, has determined this cost estimate of $6-$10,000 “optimistic” (i.e.,
higher) but impossible to determine without a specific audit template. CHF suggests two more practical and
affordable methods of obtaining data:
1. Build additional capacity into the SEVIS database for program officers to produce reports for each sponsor:
a) Sites where exchange visitors are located (listed by sponsor)
b) List of names of exchange visitors by each site
c) Salaries of exchange visitors
d) Host families
e) Third party companies
f) (Accurate) list of no. of exchange visitors per country
g) (Accurate) list of names of countries listed per sponsor
The Exchange Visitor Compliance Section could request more detailed reports and lists as part of the annual
sponsor report form to better monitor exchange visitor sponsors. Neither a committee or study is necessary to
determine what information to request: simply list each category 's requirements and ask for reports on those areas.
2. For each annual report, add a list of required documents, and have them reviewed and formally evaluated by an
EV compliance officer for accuracy and completeness:
a) One-to-two pager describing the organization’s vetting procedures
b) Schedule of orientation meetings including dates, times, and agenda
c) Copies of Exchange Visitor orientation meeting sign-in sheets
d) Pre-arrival materials sent to EVs
e) Orientation manuals and booklets
f) Program brochures, handouts, fact sheets
g) Forms used by the sponsor in the operation of EV program
h) Lists of all third parties that perform sponsor functions
i) Sample agreement with third parties
j) Comprehensive lists of all schools, companies and/or exchange visitors
k) Sample agreement with schools, constituents and exchange visitors
l) Fee schedule of charges to schools, constituents, exchange visitors, and J-2 dependents
m) One-pager describing how the sponsor complies with health-insurance requirement
n) Lists and schedules for all other documents or procedures required by the category
o) Tax return for most recent fiscal year or Non-profit 990 report
p) Audited financial statements for all organizations who obtain elective audits or required by individual state
regulation (i.e., in NY, all non-profit orgs with income of $250K or higher)
3. Many sponsors have expressed the desire to have an annual meeting in Washington, DC where the division
heads would meet with all their sponsors, make presentations, explain operating procedures, SEVIS updates and
answers questions. This practice would give sponsors a more even playing field, would give everyone an
opportunity to be on the same page. Sponsors now pay a $1738 designation fee every two years. There should be
sufficient funds in the budget to rent facilities and allocate one day of staff time once a year. If not, sponsors would
probably not mind paying a fee to defray the costs of organizing annual meetings. It would not add substantially to
their travel costs. Many sponsors arrange annual visits to the office every year anyway.
Site Reviews
On-site reviews are the most important oversight tool and need to be a normal, mandatory routine part of the work of
related designation officers for both new programs and existing programs. Secretary Clinton recently underscored a
central tenet of her tenure: the importance of “people-to-people” international interactions to US Diplomacy in her
remarks at the November 6, 2009 Public Policy Luncheon. It is a paradox that, though the thrust of the Mutual
Exchange Act stresses people-to-people exchanges, State Dept. designation staff imbued with oversight
responsibility do not make routine people-to-people visits to sponsor sites /offices.
Unfortunately, program designation officers miss out on the most fascinating aspect of exchange programs without
personally observing them in action. Until seeing first-hand individual exchange programs in operation, they cannot
obtain a clear picture as to the enormous value derived. Otherwise, they risk forming a distorted view by relying on
negative complaints received by phone and email, hearsay from other sponsors, other designation officers, and/or
sometimes inaccurate, incomplete industry publications by advocacy groups such as by AFT in June 2009.
A hands-off approach is not called for. Hand-in-hand with these visits, the department must establish a policy to
listen to those officers who are monitoring programs and accept their input into the governing process. We should
all work together in a team effort, not an adversarial relationship.
bureaucratic organizations that can afford the extra costs and overhead, and risk blocking the flow of new and
innovative ideas into the vital exchange program arena.
CHF suggests that before we pile on additional burdens and tasks for sponsors that we consider the big picture and
whether it will block new players from participating and bringing fresh energy to the plate.
Suggested alternatives for insuring sponsor compliance in lieu of Management Audits
CPA firm McLean, Koehler, Sparks & Hammond, has determined this cost estimate of $6-$10,000 “optimistic” (i.e.,
higher) but impossible to determine without a specific audit template. CHF suggests two more practical and
affordable methods of obtaining data:
1. Build additional capacity into the SEVIS database for program officers to produce reports for each sponsor:
a) Sites where exchange visitors are located (listed by sponsor)
b) List of names of exchange visitors by each site
c) Salaries of exchange visitors
d) Host families
e) Third party companies
f) (Accurate) list of no. of exchange visitors per country
g) (Accurate) list of names of countries listed per sponsor
The Exchange Visitor Compliance Section could request more detailed reports and lists as part of the annual
sponsor report form to better monitor exchange visitor sponsors. Neither a committee or study is necessary to
determine what information to request: simply list each category 's requirements and ask for reports on those areas.
2. For each annual report, add a list of required documents, and have them reviewed and formally evaluated by an
EV compliance officer for accuracy and completeness:
a) One-to-two pager describing the organization’s vetting procedures
b) Schedule of orientation meetings including dates, times, and agenda
c) Copies of Exchange Visitor orientation meeting sign-in sheets
d) Pre-arrival materials sent to EVs
e) Orientation manuals and booklets
f) Program brochures, handouts, fact sheets
g) Forms used by the sponsor in the operation of EV program
h) Lists of all third parties that perform sponsor functions
i) Sample agreement with third parties
j) Comprehensive lists of all schools, companies and/or exchange visitors
k) Sample agreement with schools, constituents and exchange visitors
l) Fee schedule of charges to schools, constituents, exchange visitors, and J-2 dependents
m) One-pager describing how the sponsor complies with health-insurance requirement
n) Lists and schedules for all other documents or procedures required by the category
o) Tax return for most recent fiscal year or Non-profit 990 report
p) Audited financial statements for all organizations who obtain elective audits or required by individual state
regulation (i.e., in NY, all non-profit orgs with income of $250K or higher)
3. Many sponsors have expressed the desire to have an annual meeting in Washington, DC where the division
heads would meet with all their sponsors, make presentations, explain operating procedures, SEVIS updates and
answers questions. This practice would give sponsors a more even playing field, would give everyone an
opportunity to be on the same page. Sponsors now pay a $1738 designation fee every two years. There should be
sufficient funds in the budget to rent facilities and allocate one day of staff time once a year. If not, sponsors would
probably not mind paying a fee to defray the costs of organizing annual meetings. It would not add substantially to
their travel costs. Many sponsors arrange annual visits to the office every year anyway.
Site Reviews
On-site reviews are the most important oversight tool and need to be a normal, mandatory routine part of the work of
related designation officers for both new programs and existing programs. Secretary Clinton recently underscored a
central tenet of her tenure: the importance of “people-to-people” international interactions to US Diplomacy in her
remarks at the November 6, 2009 Public Policy Luncheon. It is a paradox that, though the thrust of the Mutual
Exchange Act stresses people-to-people exchanges, State Dept. designation staff imbued with oversight
responsibility do not make routine people-to-people visits to sponsor sites /offices.
Unfortunately, program designation officers miss out on the most fascinating aspect of exchange programs without
personally observing them in action. Until seeing first-hand individual exchange programs in operation, they cannot
obtain a clear picture as to the enormous value derived. Otherwise, they risk forming a distorted view by relying on
negative complaints received by phone and email, hearsay from other sponsors, other designation officers, and/or
sometimes inaccurate, incomplete industry publications by advocacy groups such as by AFT in June 2009.
A hands-off approach is not called for. Hand-in-hand with these visits, the department must establish a policy to
listen to those officers who are monitoring programs and accept their input into the governing process. We should
all work together in a team effort, not an adversarial relationship.
| Foundation for Education Phone: 212.300.2138 Fax: 646.349.345co rdellhull@aol.com www.cordellhull.net Suite 300 New York, NY 10017 |