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October 7, 2020 Proposal to Replace Duration of Status

Wednesday, October 7, 2020

Dear Students, Staff and Faculty,

The Department Homeland Security (DHS) has proposed a regulation that will restrict international students' ability to secure visas and reduce the time they can remain in the US after graduation. RISD will be submitting a letter in opposition of this change.

If you would like to submit feedback to DHS on the proposed regulation steps can be found below.

Summary of the proposed regulation:

On Friday, September 25, 2020, the US Department Homeland Security proposed a regulation that would eliminate “duration of status” (“D/S”) admission to the US for students on the F1 visa and their dependents and exchange visitors (scholars, professors, students, etc.) on the J1 visa and their dependents and instead establish shorter, fixed periods of admissions to the US. You can also read the full text of the regulation here.

In summary, the proposed rule would:

* Eliminate admission to the US for "D/S" (duration of status) for F students and dependents, as well as J exchange visitors and dependents.

* Establish a shorter, fixed period of admission of two - four years for F students.

* Require students needing additional time to complete their degree to submit an application for extension of stay (EOS) to USCIS.

* Shorten the "grace period" to remain in the US after program completion from 60 days to 30 days.

In addition, as written in an email by Richard L. Iandoli, Esq on October 3,

...the list of the countries which DHS is openly targeting:

“Afghanistan, Benin, Bhutan, Burkina Faso, Burma, Burundi, Cameroon, Cape Verde, Central African Republic, Chad, Congo-Brazzaville, Congo-Kinshasa, Côte d'Ivoire, Djibouti, Equatorial Guinea, Eritrea, Ethiopia, Gabon, the Gambia, Ghana, Guinea, Guinea-Bissau, Guyana, Haiti, Iraq, Kenya, Kosovo, Kyrgyzstan, Liberia, Libya, Malawi, Mali, Mauritania, Moldova, Mongolia, Nepal, Niger, Nigeria, Papua New Guinea, the Philippines, Rwanda, Samoa, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tajikistan, Tanzania, Togo, Tonga, Turkmenistan, Tuvalu, Uganda, Uzbekistan, Vietnam, Yemen and Zambia.

The citizens of these targeted countries are almost exclusively persons of color and are disproportionately nationals of African countries.

The proposed rule will frustrate, discourage, complicate, and make far more expensive the F & J visa processes for these people of color. Its intent and effect are to reduce their numbers, interrupt their studies and truncate their tenure in the U.S.

It is particularly hurtful that in the era of BLACK LIVES MATTER, this administration boldly rolls out a policy designed to restrict equal access by people of color to American higher education This roll out must be named for what it is: “Institutional Racism”.

American schools simply cannot allow DHS to restrict the international diversity which the schools have worked so hard to build.

How to Submit a Comment to DHS:

The proposed rule is subject to a 30-day comment period, through October 26, 2020, to provide input to DHS regarding the impact of the proposed rule on our students. Comments received from constituents will be reviewed by DHS and could lead to modifications before a final rule is published. Rhode Island School of Design will sign a letter that opposes this change.

If you would like to individually submit a comment, please read, “So you want to comment on a regulation? Here’s how” from the Brookings Institute.

As always, please don’t hesitate to reach out to the Office of International Student Services team with any questions or concerns that you may have at We will continue to monitor the immigration and travel situation along with the Admissions Office and information will be sent out soon regarding Wintersession and Spring terms. We are here to support our campus.



Kate Sacco, Director

Jennifer Dressen, Assistant Director

Amy Andrea Iglesias, International Student Advisor

Sachi Tan, Administrative Coordinator

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