AACRAO's Reaction

AACRAO's Initial Response to CIPRIS Fee Regulation

--The following message was sent via e-mail broadcast to members 12-21-99.

The proposed regulation for collection of the CIPRIS (Coordinated Interagency Partnership Regulating International Students) fee was issued in the 12-21-99 Federal Register. A 60-day comment period, with a deadline of February 22, 2000, is stipulated.

To view the CIPRIS fee regulation as printed in the Federal Register, go to http://www.aacrao.org/federal_relations/cipris/regulation.cfm

AACRAO's position has remained supportive of the CIPRIS project for the relief it may provide international admissions officers who currently maintain paper records of visa status and who would benefit from electronic, real-time transmissions of event notifications affecting international student/scholar visa status. However, AACRAO opposes, both philosophically and logistically, that institutions of higher education must collect the $95 fee on behalf of INS as mandated in the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA). The Association has additional concerns not immediately contained by the proposed rule; these concerns center around INS' capability to implement a reliable nationwide system and the additional burdens imposed on institutions as a result.

The proposed regulations appear to conform with the statutory language mandating the fee collection, but AACRAO members are encouraged to comment on other aspects of the rule as presented. Any comments on the basis for calculation of the fee would be particularly welcome.

Many AACRAO members plan to comment on the CIPRIS fee rule and will work with the AACRAO Office on the formation of an Association comment. AACRAO welcomes opinions from all members as to the Association's position on this matter. If it is the broad consensus of the commentators that AACRAO opposition to the fee collection mandate is appropriate, AACRAO will seek a legislative remedy from the Immigration subcommittees of the Judiciary Committees of the House and Senate.

To link to the CIRPIS Web page, go to http://www.ins.usdoj.gov/graphics/services/cipris/.