ISSA Announcements

Issue at a Glance

The U.S. Department of Homeland Security (DHS) proposed a federal rule change to end “duration of status” (D/S) for nonimmigrants granted entry to the U.S. in F, J, or I status. Duration of status refers to the period of lawful stay a nonimmigrant in F, J or I status is granted upon entry to the U.S. on the Form I-94. 

Only F-1 and J-1 international students (including interns) and scholars, and their accompanying F-2 and J-2 dependents, are within the scope of Bryn Mawr's likely exposure to this proposed rule change. Dependents include one legal spouse and unmarried children up to the age of 21.

The Association of International Educators (NAFSA) has provided the following summary: “DHS proposed rule change would replace the D/S admission with a fixed I-94 end date, require students and scholars to file a formal extension application with USCIS, shorten grace periods, and impose new limits on academic program changes. DHS argues the changes will improve oversight, program integrity, and national security, but institutions would face higher compliance costs and legal risks, enrollment impacts, and heavier advising burdens.”

Current Status of the Proposed Rule

The proposed rule change was published in the Federal Register on August 28, 2025. Public comments were accepted through September 29, 2025. Public comments are reviewed by DHS, then a final rule is submitted to the Office of Management and Budget (OMB) for review before DHS publishes its final rule in the Federal Register. On May 5, 2026, the Department of Homeland Security finalized its review of the final rule. The Office of Information and Regulatory Affairs within OMB concluded its review of the proposed rule on June 17, 2026. The rule change may be published in the Federal Register at any time. The effective date of the final rule is 60 days after it is published in the Federal Register.

The ISSA Office is closely monitoring this proposed regulatory change. Representatives from key offices across the College are collaborating with academic and administrative units to assess its potential impact and ensure the campus community understands the proposed changes and their implications.

We will continue to provide updates and share additional information as it becomes available.

The proposed DHS rule change would:

1. Replace the Form I-94 Arrival/Departure Record “admit until date” of “duration of status” with a specific end date that aligns with the academic program length or four years, whichever is shorter. The “admit until date” is the period of lawful stay in the U.S. The current D/S “admit until date” allows students and scholars to remain in the U.S. until their F-1/J-1 activities end, without a fixed or defined end date.
2. Require students/scholars to file formal Extension of Stay (EOS) application and filing fee to U.S. Citizenship and Immigration Services (USCIS) as part of a multi-step application process to extend lawful stay in the U.S. The current program extension process is completed by a Designated School Official (DSO) or Alternate Responsible Officer (ARO) at a student’s/scholar’s U.S. university and does not require a formal government application.
3. Shorten the current F-1 student grace period from 60 days to 30 days. The grace period is a period of lawful stay in the U.S. after completing an academic program during which an F nonimmigrant may prepare for departure from the U.S. Current rules allow an F-1 student to change education level, transfer schools, or apply for a change of immigration status or benefit during the 60-day grace period. Under the proposed rule, this period would be shortened to 30 days. There is no change to the J-1 student or scholar grace period as it is already set at 30 days.
4. Cap the duration of English Language Training study to 24 months in aggregate.
5. Restrict F-1 undergraduate students from changing “educational objective” or transferring to another U.S. higher education institution during their first year. Educational objective refers to a student’s education level or major.
6. Prohibit F-1 graduate students from changing “educational objective” or transferring to another U.S. higher education institution at any point in their studies.
7. Prohibit F-1 students from pursuing another academic program at the same or lower education level. Students who previously completed an academic program in F-1 status in the U.S. would not be allowed to matriculate at the same or lower education level.

If implemented as proposed, U.S. higher education institutions will face greater compliance costs and legal risks; need to reorganize administrative and operational processes; and face potential increases in immigration and academic advising responsibilities. Bryn Mawr College is carefully reviewing the proposed rule and assessing its potential implications for the institution. 

Academic and administrative offices are encouraged to consider how the proposed changes may affect international student enrollment, academic programs, research and scholarly activities, and the recruitment and retention of international students, scholars, faculty, and staff.

If you have any questions, please reach out to ISSA Office at intl@brynmawr.edu.