EnglishUSA ELP-Specific Recommendations To Federal Agencies

Post-secondary, accredited U.S. intensive and pathway English language programs are essential to serving the diverse linguistic needs of international students and scholars and play an important role in the U.S. commitment to international education. Some serve as an access point into the U.S. higher education system, while others offer short-term opportunities to learn English for personal or professional development. However, all create innovative English language offerings that support U.S. higher education institutions, businesses, and international partnerships.

EnglishUSA supports NAFSA’s policy priorities and federal agency recommendations, including the focus on establishing a White House coordinating council to provide leadership on international education across federal agencies to create more welcoming visa and immigration policies to help restore the United States’ attractiveness as a destination for international students and scholars. This council would develop a national strategy on international education and include collaboration from the Departments of State, Homeland Security, Education and Commerce along with diverse international education associations that support institutions and programs that welcome students.

Advancing international education priorities in the U.S. includes a strong commitment to policies and regulations that support English language study in the U.S. and would require reaffirming a dedication to English language study in the U.S. through administrative and congressional action. EnglishUSA advocates for the following policy priorities to support English language study in the U.S.

1. Inform Consular Affairs officers that attendance at English language programs is not in itself a reason for refusing a student visa application (Department of State-Bureau of Consular Affairs).

English language program administrators continue to hear reports from students that have been denied an F-1 visa specifically because they are planning to attend an English language school or program. Questions of academic choice and qualifications and admission criteria are decided between the student and the SEVP-certified institutions/programs; the consular officials should focus instead on evaluating whether the applicant meets the requirements of a bona fide student. Furthermore, denial of a visa should not be based on English-language competency, as it is the purview of the institutions to evaluate language proficiency and to provide English-language training programs (either in-house or outsourced), if necessary, to help students succeed.

2.  Include Language Training student data in the SEVIS by the Numbers report from the Department of Homeland Security-SEVP.

The SEVIS by the Numbers annual report needs to include data about students enrolled in Language Training.  Although this education level is included as an election for an I-20, along with all other education levels identified in SEVIS (Secondary, Associates, Bachelor's, Master's, and Doctorate), Language Training students are omitted from the report. SEVP should identify the number of Language Training students in SEVIS by the Numbers as they do with the other education levels.

The Institute of International Education (IIE) reports that almost 40,000 international students studied in English language programs in 2021.  SEVIS by the Numbers does not directly provide data on the Language Training students and therefore impedes understanding of current and potential market data for English language programs. 

3. Report on entry/exit overstay rates should include country and education level data to help Language Training schools be aware of and strengthen their role in identifying fraudulent applications (Department of Homeland Security).

Consular operations have an obligation to reduce the overstay rate of F-1 students and deny the visa if applicants do not overcome the presumption of immigrant intent. Consular officers view F-1 applicants with Language Training I-20s with higher scrutiny because of lower fees and limited testing requirements for English language programs. 

EnglishUSA member programs are equally concerned about high overstay rates and potentially fraudulent applicants. Our members work to identify and admit legitimate students during the admissions process. To better understand the connection between language training students, immigrant intent, and overstay rates, the DHS report on Entry/Exit Overstays should identify F visa overstays by education level and include Language Training, along with Secondary, Associates, Bachelor's, Master's, and Doctorate levels, to help schools further their efforts to identify and dissuade fraudulent applications.

4. Provide financial resources for all states to be represented by the Study State Consortia and collaborate with EnglishUSA to encourage English language programs to join (Department of Commerce, U.S. Commercial Services). 

The U.S. International Education Study State Consortia initiative was started in 1999 with the integral support from the U.S. Department of Commerce, U.S. Commercial Services, International Trade Administration launched by colleges and universities exploring ways to market their location and member programs.  The work is labor-intensive and relies on long-term institutional volunteers, although a few states have limited support from state governors’ administrations and state departments of commerce. However, with 18 states still lacking (or having lost) the leadership of a state consortia, national efforts to enhance the U.S. international competitiveness and economic development are hindered.  A national international education strategy needs to include financial state support for all state consortia.

5. Permit limited opportunities for F-1 students, including language training students, to earn money while studying in the U.S. (Department of Homeland Security).

This option would be an important step toward providing students with access to resources that could support their enrollment. The current restriction on work makes it harder for foreign students to consider study in the U.S. and brings the U.S. in line in competition with other native English-speaking markets around the world.  Such a change in policy would contribute to greater diversity in sending countries and income levels of students, address workplace shortages in the U.S.