Comment Deadline: Proposed Subpart A J-1 rules- November 23, 2009
On September 22, Department of State staff published a pending rule proposing substantial
administrative and financial burdens to Exchange Visitor Program regulations (22 CFR 62) in the
Federal Register / Vol. 74, No. 182 - pages 48177 to 48190 - Public Notice 6767, RIN 1400-AC36.
Click on links below or on side toolbar for digests of the complex new rules. Links in each section
connect to corresponding page nos. in the Federal Register. Deadline for official comment on this
proposal was November 23, 2009 and has passed, but the provisions are not yet part of the J-1 visa
regulations. Members of Congress, designated exchange visitor sponsors, schools, and advocacy
organizations raised many objections to this complicated set of proposals.
Link for full proposal in Acrobat Reader: http://edocket.access.gpo.gov/2009/pdf/E9-22822.pdf
Or download from this website: New_Prop_Regs.pdf
For over forty years, CHF has been privileged to observe first-hand tremendous positive effects of J-1
visas for foreign exchange teachers gained from actual experience visiting American schools and
teachers. We do not wish to see this vehicle diminished.
It is time to figure out ways to simplify oversight of existing rules rather than continue to burden
exchange programs with unnecessary new regulations and costs. We must expand the scope of
international exchange created in 1961 and adapt it to the 21st century by repealing existing regs that
limit expansion.
Over the years we have seen a tendency to add on more visa rules and procedures. We believe it is
worthwhile to pause and seriously consider whether navigating the shoals of increasingly abundant red
tape will not only discourage exchange program growth but also engender inefficiency–the opposite of
the desired effect. Inevitable mistakes result from a seemingly overwhelming number of ever-
lengthening regulations and give the impression to foreign nationals that the US government is too
demanding.
US immigration agencies are implementing more and more rules without collaborating with the
stakeholders who are impacted. There is a crucial need for related agencies to visit exchange program
sites before writing regulations, to learn firsthand possible negative impacts on the human side, apart
from judging programs by looking at data alone. We are headed toward huge bureaucratic bottlenecks.
Click on this link for excerpts from State Department Secretary Hillary Clinton's remarks at the November
6, 2009 Public Policy Luncheon stressing a central tenet of her tenure: the importance of “people-to-
people” to U.S. Diplomacy.
In recent years, the two Cabinets overseeing U.S. Immigration--The State Dept. and Dept. of Homeland
Security--have imposed an increasing flow of new visa rules, making the J-1 visa process more difficult,
time-consuming, and expensive, starting with the State Dept.'s decision in 2003 to require personal
interviews for all J-1 teacher visas and their family dependents, whether applying for a new J-1 visa
stamp or renewing it for the second or third year. The "visa entrance fee" was $80, then rose to $100,
then to $131. The SEVIS fee was added in 2002, first $100, then rose dramatically last year to $180,
with the justification that it had not been raised in five years.
Sample comments are organized by issue on the left toolbar. Also, we would appreciate your sharing
any additional points and information to strengthen and document our position - or correct errors - by
emailing: chfny@aol.com
administrative and financial burdens to Exchange Visitor Program regulations (22 CFR 62) in the
Federal Register / Vol. 74, No. 182 - pages 48177 to 48190 - Public Notice 6767, RIN 1400-AC36.
Click on links below or on side toolbar for digests of the complex new rules. Links in each section
connect to corresponding page nos. in the Federal Register. Deadline for official comment on this
proposal was November 23, 2009 and has passed, but the provisions are not yet part of the J-1 visa
regulations. Members of Congress, designated exchange visitor sponsors, schools, and advocacy
organizations raised many objections to this complicated set of proposals.
Link for full proposal in Acrobat Reader: http://edocket.access.gpo.gov/2009/pdf/E9-22822.pdf
Or download from this website: New_Prop_Regs.pdf
For over forty years, CHF has been privileged to observe first-hand tremendous positive effects of J-1
visas for foreign exchange teachers gained from actual experience visiting American schools and
teachers. We do not wish to see this vehicle diminished.
It is time to figure out ways to simplify oversight of existing rules rather than continue to burden
exchange programs with unnecessary new regulations and costs. We must expand the scope of
international exchange created in 1961 and adapt it to the 21st century by repealing existing regs that
limit expansion.
Over the years we have seen a tendency to add on more visa rules and procedures. We believe it is
worthwhile to pause and seriously consider whether navigating the shoals of increasingly abundant red
tape will not only discourage exchange program growth but also engender inefficiency–the opposite of
the desired effect. Inevitable mistakes result from a seemingly overwhelming number of ever-
lengthening regulations and give the impression to foreign nationals that the US government is too
demanding.
US immigration agencies are implementing more and more rules without collaborating with the
stakeholders who are impacted. There is a crucial need for related agencies to visit exchange program
sites before writing regulations, to learn firsthand possible negative impacts on the human side, apart
from judging programs by looking at data alone. We are headed toward huge bureaucratic bottlenecks.
Click on this link for excerpts from State Department Secretary Hillary Clinton's remarks at the November
6, 2009 Public Policy Luncheon stressing a central tenet of her tenure: the importance of “people-to-
people” to U.S. Diplomacy.
In recent years, the two Cabinets overseeing U.S. Immigration--The State Dept. and Dept. of Homeland
Security--have imposed an increasing flow of new visa rules, making the J-1 visa process more difficult,
time-consuming, and expensive, starting with the State Dept.'s decision in 2003 to require personal
interviews for all J-1 teacher visas and their family dependents, whether applying for a new J-1 visa
stamp or renewing it for the second or third year. The "visa entrance fee" was $80, then rose to $100,
then to $131. The SEVIS fee was added in 2002, first $100, then rose dramatically last year to $180,
with the justification that it had not been raised in five years.
Sample comments are organized by issue on the left toolbar. Also, we would appreciate your sharing
any additional points and information to strengthen and document our position - or correct errors - by
emailing: chfny@aol.com
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| Cordell Hull Foundation for Fax: 646.349.3455 cordellhull@aol.com www.cordellhull.org www.cordellhull.net 501 Fifth Avenue Suite 300 New York, NY 10017 |