The AHA has submitted a comment on a proposed revision to Department of Education rules governing student and visiting scholar visas. The proposal would limit the length of such visas for both undergraduate and graduate students to a maximum of four years. The revision, writes the AHA, “will likely result in a larger proportion of international students who never graduate” from undergraduate programs and “would undermine the globally dominant position that American PhD programs have earned in the past century—indeed enfeebling American PhD programs in history and rendering their graduates uncompetitive for employment against PhD graduates trained in other countries.”

The American Historical Association submits the following comment on the proposed changes. The AHA is the largest association of professional historians in the world. Our almost 11,500 members include college professors, secondary school teachers, advanced students, and public historians working in museums, national parks, and innumerable other venues.

The proposed revision to federal rules governing student and visiting scholar visas includes the following language:

(i)Application for Admission in F or J Nonimmigrant Status

Aliens applying for an admission in either F or J status who, under this proposal, would be eligible to be admitted for the length of time indicated by the program end date noted in their Form I-20 or DS-2019, not to exceed 4 years, unless they are subject to a 2-year admission proposed in 8 CFR 214.2(f)(20) or (j)(6), plus a period of 30 days following their program end date, to prepare for departure or to otherwise seek to obtain lawful authorization to remain in the United States. See proposed 8 CFR 214.1(a)(4)(i)(A) and (ii)(A).

This proposal includes significant measures that are neither necessary nor useful. Current procedures and regulations provide substantial benefits to both international students and American higher education institutions. There is little evidence of abuse of these procedures other than by a small handful of for-profit higher education institutions whose improprieties can be more effectively controlled through direct regulation. At colleges and universities across the United States the presence of international students enriches intellectual and cultural environments while enabling citizens of other nations to appreciate American culture and develop networks that benefit our nation's place in the world.

Why would this change diminish the presence of international students in the United States?

Completing an undergraduate degree in four years is a struggle for many students, whether history majors or students focusing on other disciplines. This is true of U.S. nationals and international students alike. The proposed regulation will likely result in a larger proportion of international students who never graduate, which in the short run will result in negative recollections of their American experience. In the longer run it will discourage enrollment.

The impact would be similar at the graduate level. In our discipline, four years is not a realistic time frame for completing a PhD. According to the Survey of Earned Doctorates, conducted by the National Center for Science and Engineering Statistics (NCSES), the average time to degree for History PhD students is between seven and eight years. Students typically undertake two years of coursework and several months of independent reading for examinations before embarking on their PhD dissertation. Often they need to learn additional languages to perform their research. Many must acquire other skills as well, such as paleography or expertise in Geographic Information Systems.

It would be possible for students to complete History PhDs inside of four years only if American universities lowered their standards for preparation and accepted dissertations that were, on average, based on far less research than has been the prevailing expectation for the past 100 years. Such a change would undermine the globally dominant position that American PhD programs have earned in the past century—indeed enfeebling American PhD programs in History and rendering their graduates uncompetitive for employment against PhD graduates trained in other countries.

It seems especially odd that a Department of Education that professes faith in markets would promulgate rules likely to diminish the ability of American colleges and universities to compete in international markets for students, and that would handicap our own students who seek to cultivate the relationships and cultural skills necessary to success in a globalizing world.