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Comments to USCIS on Memo Concerning the Accrual of Unlawful Presence for F, J, and M Nonimmigrants

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Comments to USCIS on Memo Concerning the Accrual of Unlawful Presence for F, J, and M Nonimmigrants

June 11, 2018

​ACE joined six other higher education associations in submitting comments on a U.S. Citizenship and Immigration Services (USCIS) policy memorandum concerning the “Accrual of Unlawful Presence for F, J, and M Nonimmigrants.”

The comments express concerns that the USCIS ​memo “obscures and conflates” the important distinction between “unlawful presence”—illegal presence in the United States—and “maintenance of status” as defined under the Immigration and Nationality Act, which could lead to severe consequences for foreign students and exchange visitors and cause significant disruption and harm to educational and research programs at American colleges and universities. 

Along with ACE, the following associations signed on to the comments: the Association of Public and Land-grant Universities, Association of American Universities, the American Association of Community Colleges, American Association of State Colleges and Universities, Association of Jesuit Colleges and Universities, and National Association of Independent Colleges and Universities. ​

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