Last month, the United States Department of Homeland Security (DHS) unveiled a sweeping proposed regulation that could fundamentally reshape the experience of international students and scholars in the country. If enacted, the rule would replace the long-standing “duration of status” policy with fixed admission periods for F, J, and I visa holders, requiring students and scholars to periodically apply for extensions and undergo biometric screening. The proposal also introduces new restrictions on academic flexibility, including limits on changing programs, majors, or levels of study, particularly for graduate students.
Brown University ’s Office of Global Engagement submitted a formal comment to the DHS on September 29, 2025, urging the department to withdraw the regulation, warning of its potential consequences for both students and higher education broadly, according to an announcement reported by The Brown Daily Herald on Friday.
Fixed visa periods: A growing concern
Under the proposed rule, the “authorized admission and extension periods” for F and J visas would be tied to the length of the student’s or scholar’s program, not to exceed four years. The regulation would also introduce tighter oversight of visa extension requests and impose a series of limits on modifications to academic programs or objectives.
In the letter submitted to the DHS, Associate Provost for Global Engagement Asabe Poloma highlighted the impacts of these changes on the Brown community and higher education nationwide. “These changes would deter talented individuals from choosing the United States as a destination for study and scholarship, undermining the competitiveness of American higher education, weakening the research innovation enterprise and disrupting workforce pipelines in critical areas of national need,” Poloma wrote, as reported by The Brown Daily Herald.
Financial and logistical burdens
Poloma’s letter detailed how the proposed regulation would increase costs for students, scholars, and institutions, noting that international students may need to file multiple visa extensions and hire legal counsel to ensure compliance. Universities, meanwhile, would face heightened administrative demands, including the ongoing tracking of visa expirations. Beyond these challenges, the proposed rule also constrains academic flexibility in ways that could disrupt students’ educational trajectories.
Impact on academic flexibility
The regulation introduces broader restrictions on program changes. Undergraduate F-1 students would be barred from changing their program, major, or education level during their first year except under rare circumstances, such as school closures. Graduate F-1 students would face stricter limitations, including no ability to change their program or field of study. Additionally, students completing a program at a certain level would no longer be allowed to pursue another program at the same or lower level under F-1 status, a provision Poloma described as “arbitrary and harmful,” with potential consequences for Ph.D. students seeking a master’s degree or dual-degree students requiring additional time to complete their studies. The letter also emphasized that current criteria for visa extensions are too narrow, urging the DHS to consider program length and design when evaluating extension requests.
A cautionary note for the future of US education
Brown University’s submission reflects wider concerns across American higher education. Fixed visa periods, reduced academic flexibility, and additional procedural requirements could create uncertainty, deter international talent, and place significant burdens on universities.
“The proposed regulation threatens to disrupt educational and research pathways that are essential to innovation and workforce development in the United States,” Poloma’s letter concluded, as reported by The Brown Daily Herald.
The debate underscores a broader tension in US policy: balancing immigration enforcement with maintaining the nation’s appeal as a global hub for higher education. For students, scholars, and institutions alike, the stakes are high, and the outcome could reshape the landscape of international education in America.
Brown University ’s Office of Global Engagement submitted a formal comment to the DHS on September 29, 2025, urging the department to withdraw the regulation, warning of its potential consequences for both students and higher education broadly, according to an announcement reported by The Brown Daily Herald on Friday.
Fixed visa periods: A growing concern
Under the proposed rule, the “authorized admission and extension periods” for F and J visas would be tied to the length of the student’s or scholar’s program, not to exceed four years. The regulation would also introduce tighter oversight of visa extension requests and impose a series of limits on modifications to academic programs or objectives.
In the letter submitted to the DHS, Associate Provost for Global Engagement Asabe Poloma highlighted the impacts of these changes on the Brown community and higher education nationwide. “These changes would deter talented individuals from choosing the United States as a destination for study and scholarship, undermining the competitiveness of American higher education, weakening the research innovation enterprise and disrupting workforce pipelines in critical areas of national need,” Poloma wrote, as reported by The Brown Daily Herald.
Financial and logistical burdens
Poloma’s letter detailed how the proposed regulation would increase costs for students, scholars, and institutions, noting that international students may need to file multiple visa extensions and hire legal counsel to ensure compliance. Universities, meanwhile, would face heightened administrative demands, including the ongoing tracking of visa expirations. Beyond these challenges, the proposed rule also constrains academic flexibility in ways that could disrupt students’ educational trajectories.
Impact on academic flexibility
The regulation introduces broader restrictions on program changes. Undergraduate F-1 students would be barred from changing their program, major, or education level during their first year except under rare circumstances, such as school closures. Graduate F-1 students would face stricter limitations, including no ability to change their program or field of study. Additionally, students completing a program at a certain level would no longer be allowed to pursue another program at the same or lower level under F-1 status, a provision Poloma described as “arbitrary and harmful,” with potential consequences for Ph.D. students seeking a master’s degree or dual-degree students requiring additional time to complete their studies. The letter also emphasized that current criteria for visa extensions are too narrow, urging the DHS to consider program length and design when evaluating extension requests.
A cautionary note for the future of US education
Brown University’s submission reflects wider concerns across American higher education. Fixed visa periods, reduced academic flexibility, and additional procedural requirements could create uncertainty, deter international talent, and place significant burdens on universities.
“The proposed regulation threatens to disrupt educational and research pathways that are essential to innovation and workforce development in the United States,” Poloma’s letter concluded, as reported by The Brown Daily Herald.
The debate underscores a broader tension in US policy: balancing immigration enforcement with maintaining the nation’s appeal as a global hub for higher education. For students, scholars, and institutions alike, the stakes are high, and the outcome could reshape the landscape of international education in America.
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