老美写的DHS反对意见小作文，供大家参考 －－－－－－－－（请版主移至工作签证OPT...

楼主男票是老美，楼主F1。在详细跟他阐明DHS新规的利害关系之后，我们共同撰写了这份反对评论。
主要立场是站在“local student”的立场阐述新规对教育和工业体系的损害，以及本措施并不能达到维护美国国家安全的目的，并提出了一些替代建议。

给大家提供一些视角

本文重点：１．于学生个人而言，revalidation会造成学术中
２．于政府机构而言，无法高效锁定high－risk student，反而会因处理大量low risk case分散精力
３．于教育体系而言，损失国际学生会对美国教育产业造成重大打击
４．于企业而言，缺少OPT来源会造成经济影响，让美国与国际对手竞争产生不利影响

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Re: HS Docket No. ICEB-2019-××××

To whom it may concern,

I strongly disagree with the proposed rules put forth in document 2020-20845. Effort should be directed at refining the current SEVIS system.

The current D/S system with I-20 form validation has successfully been able to track international students. That is, they are unable to use it come and go from their homeland to the US iteratively, but only use it to legally finish their educational program in the U.S. Perhaps additional steps could be taken to address those who may have found ways to abuse however, fundamentally, the current D/S policy is a stable policy and the foundation on which international students are able to thrive and contribute to the greatness of the U.S.  

The proposed rule would ultimately detract from the U.S. economy and put a significant burden on our academic institutions who rely on international students financially and for their talent. Additionally, this would impede the growth of new ideas and integration of foreign talent into U.S. based corporations. The modifications to FI-visas and OPT would deter talented and skilled minds from pursuing work with U.S. companies. This talent pool is known to contribute to the groundbreaking technologies that our greatest companies produce. I will elaborate in more detail below how this policy detracts from the U.S. educational system and the U.S. economy.

• Regarding Section 6) on page  250, the new rules require a 2 to 4 year mandatary extension/revalidation of a student’s legal status, which means they have to go back to their home country to apply for VISA in the midst of their program. This will only bring tremendous uncertainty to the continuity of the program (especially harmful to the research projects at Universities). Additionally, the average length of a PhD program extends well beyond 4 years in the vast majority of cases and not just due to the exceptions stipulated in this policy update.
• The new rules will exacerbate the overstay backlog. The current D/S program with I-20 can successfully track the overstay students efficiently by comparing their I-20 valid date to their I-94 duration. However, if the new policy comes true, DHS must spend a tremendous time on validating low-risk students but will not have enough concentration on the high-risk students. It may in fact make tracking high risk students more difficult and, at an increase cost to the tax payer.
• The new rules will cause a huge loss for the U.S. higher education system and tech sector. International students have been a large component of revenue in higher education. The tuition of international students helps subsidize the costs for U.S. citizens. COVID-19 has already caused layoffs and dysfunction for the majority of universities. The decrease in international student enrollment because of these policies will cost universities millions of dollars, exacerbating the impacts of COVID and negatively impacting the economy.
• The new rule will destroy the OPT program that US companies heavily rely on for unique and diversified talent. Industry is gradually recovering from the pandemic. However, The new policy will force those OPT holders to leave the U.S. and negatively impact the U.S. tech sector. The new policy will destroy the infrastructure of current industries without cultivating local talent, forcing companies to seek talent elsewhere as well as talent pursuing careers in other countries at a detriment to the U.S. U.S. companies will lack of skilled labor and our enemies will have greater access to it as a result.
  

Thus, I urge the DHS to forgo this proposed rule in favor or one that is more beneficial to the U.S. educational system, U.S. industry and U.S. taxpayers.

Lastly, there are alternative solutions that will both benefit the U.S. educational system, industry and limit visa overstays.

Such as:

1.        Implement new ICE programs to improve compliance:
    a.        Make contact with suspected overstayers, beginning with call-in letters;
    b.        Send emails and texts prior to expiration of duration of stay to warn of consequences;
    c.        Target investigations based on patterns and clusters of violators; and
    d.        Locate, prosecute, and remove those who run fraud schemes, and the visa holders involved in them.

2.        Mandate enhanced vetting for groups with disproportionate numbers of overstays, such as countries, categories, schools, and exchange programs. Consider disqualifying certain types of educational programs, such as public elementary and secondary schools, community colleges, and certain vocational schools, especially if such programs exist in the applicant's home country. Direct the State Department to issue fewer visas to nationals of countries with high overstay rates, informed by empirical data on overstays and other patterns. Develop a red-flag system for consular officers warning of suspect educational institutions or exchange sponsors.

https://cis.org/Vaughan/Foreign-Students-and-National-Security-Student-Visa-Overstays

I appreciate your time in reviewing my comment. For the sake of the U.S. economy please take it into consideration.
Respectfully yours,