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Understanding Experiential Learning and Risk to Institution and International Students

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Understanding Experiential Learning and Risk to Institution and International Students

Santa Clara University’s risk is unique to our institution based on: geographic location; size; immigration sponsorship profile; academic profile, e.g., Carnegie Classification; staffing and resources; and international student program compliance history, as well as how these elements are understood within the context of rapidly changing local, regional and national immigration trends and institutional “Request for Evidence” (RFE) trends.

When evaluating curricular and experiential opportunities the Global Engagement Office must weigh two important institutional responsibilities:

  1. Ensure that SCU is in compliance with immigration regulations and is able to continue to successfully sponsor and host international students.

If SCU earns a reputation for non-compliance we can expect the rate of visa denials and requests for evidence (RFE’s) to increase.  Impact would be both at the university level, e.g., tuition loss, and the individual student level, e.g., entry bars to the US.  Further context:

  • Recent, local examples of visa denials and border rejections have occurred at universities that are substantially compliant but who have students that are unable to demonstrate that they are bonafide students.
  • SCU is located in a region that has a reputation with the Department of Homeland Security (DHS) for fraudulent schools and, as a result, universities in our area are under greater scrutiny.
  • Each time SCU is visited by the government, or our non-governmental liaison, SEVP, we are questioned about our CPT policy and the number and frequency of CPT cases.
  • During SCU’s last re-certification application with DHS – this is the license that allows SCU to issue immigration documents to international students -- DHS highlighted CPT and indicated CPT is an area that will continue to be scrutinized. 
  • Regulations change frequently. As part of our regular responsibility for university compliance, we monitor trends and guidance on a daily basis and calibrate ISS policies to adjust in the direction we see the regulations trending.

2.  Ensure SCU students are fully advised of immigration options and risks and are able to make well-informed personal decisions.

It is critical when SCU faculty and staff design experiential learning opportunities, e.g., CPT, that international students fully understand and can communicate about their experience accurately.  This includes:

  • Whether or not the specific experiential learning opportunity requires ISS authorization (CPT) or not. 
  • Students should be mindful of their communication of experiential learning resumes; their LinkedIn profile, on their phone; and in conversation with an immigration official when entering the U.S.  
  • If a student communicates about their experiential learning opportunity in a way that sounds like it could possibly be employment - or if the government determines that a student has engaged in unauthorized work - this can have devastating consequences for the student. 
  • Consequences may include being denied visas and entry into the U.S. or denial of post-graduation employment, “Optional Practical Training”, (OPT), STEM OPT, H-1B or other work visas, lawful permanent residence (“green card”) or naturalization (citizenship).

Faculty and staff designing curricular experiential learning opportunities should:

  1. Understand what does or does not require ISS authorization - CPT does; non-CPT does not.  
  2. Provide student advising in partnership with ISS that makes this distinction clear.
  3. Provide guidance to students on presenting experiential learning on a resume or in social media in a way that makes it clear it is not a job.
  4. Advise students about the risk of government searches of their electronic devices and social media postings.
  5. Advise students that if the government perceives they worked without authorization, the student could be denied a visa, denied entry to the U.S., or receive Request for Evidence (RFE) and/or denial on OPT, STEM OPT, H-1B (or other work visas), lawful permanent resident (“green card”) and naturalization (citizenship) applications.
  6. Partner wtih ISS on student advising and/or information sessions with specific cohorts of students engaged in experiential learning.