2024 EnglishUSA ELP-Specific Recommendations to Federal Agencies

Association Updates, Resources,

EnglishUSA ELP-Specific Recommendations to Federal Agencies
Approved by the EnglishUSA Board: September 25, 2024


Post-secondary, accredited U.S. intensive and pathway English Language Programs (ELPs) play an important role in the U.S. commitment to international education. ELPs serve as an access point into the U.S. higher education system providing English language training or pathway programs that prepare students for degree-program study at U.S. higher education institutions. They also offer short-term opportunities for English language training to visitors and students looking to improve their English for personal and professional reasons. Stronger English language skills not only empower careers but also build confidence in all areas of life.
ELPs contribute to the overall U.S. economy and local communities. EnglishUSA’s annual report on U.S. ELPs estimates that English language training students contributed over $1.7 billion to the U.S. economy in 2023 (Bonard, 2023). ELPs create innovative English language offerings that support U.S. higher education institutions while helping the U.S. remain a top English language training destination in a global market of 1.5 billion English language learners worldwide.

EnglishUSA works closely with other international education associations and advocacy groups like NAFSA, TESOL, the Alliance for International Exchange, and the U.S. for Success Coalition, for which EnglishUSA was an early partner. EnglishUSA remains focused on its mission as the voice of English Language Programs. While we support a variety of advocacy efforts, we also maintain our focus on English language programs. Advancing international education priorities in the U.S. includes policies and regulations that support English language study in the U.S. This support requires a dedicated commitment through administrative and congressional action. EnglishUSA advocates for the following recommendations to federal agencies to support English language study in the U.S.

1. Provide greater clarity, predictability, and consistency to resolve visa processing issues, including long wait times for visa appointments at many consulates, and improve transparency around visa processing and adjudication protocols and procedures (Department of State-Bureau of Consular Affairs).

A large number of F-1 students are facing excessively long interview wait times, and high visa denial rates, specifically for English language programs. These students are seeking English language training in the U.S. to further their academic, professional, and personal goals and have been accepted into accredited and SEVP-approved schools. Clear and consistent visa processing is essential to ensure the U.S. remains competitive in attracting global talent for the benefit of our campuses, communities, and society. English language training is often a first and necessary step for many F-1 visa applicants.

2. Issue consular officer guidance 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).

To ensure all qualified F-1 visa candidates can access English language training in U.S. English language programs, we urge the State Department to issue consular guidance clarifying that English language training students should not be denied a visa based on English language competency, choice of English language school, or choice of duration of study. As currently written, the Foreign Affairs Manual (FAM) may not adequately ensure Department of State officials exercise that discretion fairly and consistently. Further, English language training students should have the option to conduct the visa interview in their primary language. 

3.  Include language training students in the annual SEVIS by the Numbers report from the Department of Homeland Security-SEVP.

The SEVIS by the Numbers annual report should include data about students enrolled in English language training. As all language training programs must identify themselves on the form I-20 as providers of language training, SEVP should be able to easily identify the number of language training students in SEVIS by the Numbers, as they do with the other education levels.  The omission of English language training students from SEVIS by the Numbers impedes understanding of this category of student and how they relate to overall trends in F & M student visa numbers for the year. 

4. 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.

5. Provide resources for all states to be represented by Study State Consortia and to be included in U.S. International Education Stakeholder Roundtables (Department of Commerce).
 
The U.S. International Education Study State Consortia initiative was started in 1999 with the support of the U.S. Commercial Service, which is the trade promotion arm of the International Trade Administration (ITA) in the Department of Commerce. The “USA: A Study Destination” global marketing campaign, launched in 2021, promotes the U.S. as a premier destination for international students; those marketing materials and assets, created by the Department of Commerce, are available to the 35 states with Study State Consortia. 
 
However, fifteen states do not have a Study State Consortium, which means that national efforts to enhance the U.S. international competitiveness and economic development are hindered.   With U.S. Commercial Service offices located in every state, the Department of Commerce should take the lead in ensuring that the remaining fifteen states are provided resources to initiate or develop their participation. This includes ensuring that all states are represented at the U.S. International Education Stakeholder Roundtables convened by the U.S. government, regardless of whether they have an established Consortia.  A national international education strategy must include a coordinated effort with and from all states.