Protect International Scholars: Oppose DHS Rule on Duration of Status

DHS Docket No. ICEB-2025-0001, Attention: Desk Officer for U.S. Immigration and Customs Enforcement, DHS

The Department of Homeland Security has proposed a harmful rule that would shorten to four years the length of time international students and scholars on F and J visas may remain in the U.S. before applying for a visa renewal. For PhD students—especially in fields where programs last six years or more—this change would create huge obstacles to completing degrees. Instead of focusing on their studies, students would be forced to pay hundreds of dollars in annual fees just to extend their stay, with the constant risk of denial that could end their academic and professional careers overnight.

This rule is not only an attack on international students, but on research and higher education itself. By trapping students in legal precarity, subjecting them to invasive scrutiny, and overwhelming an already backlogged immigration system, it will drive top talent away from the U.S. and weaken global research collaboration. At a time when international research partnerships are essential, this rule would harm students, universities, and the country’s leadership in science and scholarship.

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To: DHS Docket No. ICEB-2025-0001, Attention: Desk Officer for U.S. Immigration and Customs Enforcement, DHS
From: [Your Name]

I am writing to urge DHS not to implement the proposed changes to 8 CFR and to maintain the current Duration of Status framework.

The proposed changes in Docket No. ICEB-2025-0001 would force international students and scholars to undergo frequent, costly visa extensions with no right to appeal. Each filing increases the risk of denial, heightening precarity and instability, while adding significant financial, emotional, and academic strain on scholars simply on the basis of their nationality.

Just as new USCIS screenings have expanded to include social media and vague “anti-American activity” checks, the risks are especially severe. Many PhD programs exceed the proposed stay limits, leaving students in constant fear and deterring top scholars from pursuing education and research in the United States.

This would put further strain on the U.S. institutions, faculty, and communities that rely on the valuable contributions international scholars make in critical research fields and in advancing high-quality teaching for hundreds of thousands of students nationwide.

At a time when international research partnerships are essential, increasing precarity for international students not only harms students' wellbeing, but also undermines U.S. leadership in research, weakens global collaboration, and sends a hostile message to talented scholars worldwide.

For the well-being of international students, the integrity of U.S. higher education, and the nation’s continued leadership in research and innovation, I urge DHS to reject these proposed changes and preserve the current Duration of Status framework.