The Administration


    Community Letter Requests Fall 2020 Guidance from State, DHS (7/2/20)

    On July 2, CGS signed a community letter to Dept. of State and Dept. of Homeland Security requesting updated guidance on international students for Fall 2020.


    CGS Joins Community Letter to Agencies on Value of International Students (4/30/20)

    On April 30, 2020, CGS joined 61 additional higher education associations on a letter to the Departments of Homeland Security, State, and Labor expressing the value international students bring to the United States. This letter follows President Trump’s executive order to temporarly suspend immigration.


    Higher Education Community Requests Regulatory Relief from Dept. of Ed. (3/24/20)

    CGS signed onto a community letter urging the Department of Education to temporarily halt further regulatory action with respect to Title IX and Sec. 117 foreign gift reporting. The letter acknowledges the challenges institutions would face in attempting to comply with additional regulations given the COVID-19 pandemic.


    CGS Joins Community Public Comments Regarding Sec. 117 Reporting (3/11/2020)

    On March 11, CGS signed onto public comments by the higher education community in response to the Department of Education’s proposed information collection request related to Foreign Gift Reporting (Section 117).


    CGS Comments on the American Research Environment (1/28/2020)

    On January 28, CGS submitted comments to the White House Office of Science and Technology Policy in response to a Request for Information (RFI) regarding actions federal agencies can take to maximize the quality and effectiveness of the American research environment.


    CGS Joins Community Public Comments Regarding Sec. 117 Reporting Requirements (11/5/2019)

    On November 5, public comments were submitted by the higher education community in response to the Department of Education’s proposed expansion of foreign gift and contract reporting requirements (Sec. 117, Higher Education Act).


    Community Letter in Support of NSF GRFP Awards (10/25/2019)

    On October 25, CGS joined a community letter addressed to National Science Foundation Director France Cordova encouraging the agency to allocate at least as many fellowships through the Graduate Research Fellowship Program as it did last year.


    CGS Joins Public Comments to IRS on Excise Tax (9/30/2019) 

    CGS, along with nine other organizations, sent public comments to the IRS in response to a Notice of Proposed Rulemaking on the net investment income tax (endowment excise tax).


    Coalition Letter on PSLF Implementation Concerns (6/24/2019)

    On June 24, CGS signed onto a coalition letter to Secretary of Education Betsy DeVos urging the department to waive the requirement that borrowers who qualify for the Public Service Loan Forgiveness program (PSLF) must still be working in the public sector when granted loan forgiveness. This requirement has significantly slowed the administration of PSLF for qualified borrowers.


    Community Letter on Overtime Regulation (5/21/2019)

    On May 21, CGS signed onto a higher education community letter to the Department of Labor regarding its proposed rule updating the salary threshold for the “white collar” exemptions to the Fair Labor Standards Act’s (FLSA) overtime pay requirements. The letter also includes previous comments the community had submitted—which CGS also joined—highlighting the potential impacts of the proposed rule on postdoctoral researchers and graduate research assistants at colleges and universities.


    Community Letter on Dept. of Ed. Title IX Regulations (1/30/2019)

    On January 30, CGS signed onto public comments submitted to the Department of Education regarding its notice of proposed rulemaking on Title IX campus sexual assault guidance. The comments note that the proposed rule is extremely complex in nature and highlights several concerns and questions.


    CGS Comments on H-1B Visa Lottery Proposal (1/2/2019)

    On January 2, CGS submitted public comments to the Department of Homeland Security (DHS) regarding its proposed changes to the H-1B visa lottery process. The comments acknowledge DHS’ efforts to increase the number of H-1B recipients who have graduate degrees from U.S. colleges and universities and also seeks clarification on potentially unintended consequences.


    Community Letter to DHS on Public Charge Proposal (12/10/2018)

    On December 10, CGS signed onto comments submitted by the higher education community to the Department of Homeland Security (DHS) on a proposed rule regarding inadmissibility of immigrants and non-immigrants on public charge grounds. Specific to higher education, the letter asks that the final regulation explicitly state that it does not apply to Title IV student aid programs or to F-1 and J-1 visas.


    Community Letter to HHS on Proposed Definition of Sex (11/29/2018)

    On November 29, CGS signed onto a higher education community letter to the Department of Health & Human Services (HHS) voicing concerns around a potential proposal to establish a narrow legal definition of sex. The letter highlights the implications this would have on transgender and gender non-binary students, faculty, and staff at institutions of higher education and urges HHS to not proceed with this action. 


    Community Letter on Proposed Visa Fee Increases (9/17/2018)

    On September 17, CGS joined the higher education community on comments and feedback submitted to the Department of Homeland Security around its proposed fee increases for the Student and Exchange Visitor Program (SEVP) calling attention to the potentially adverse impact on international students and faculty as well as U.S. institutions of higher education.


    CGS Comments on SEVP Fee Increases (9/16/2018)

    On September 16, CGS submitted comments to the Department of Homeland Security in response to a Notice of Proposed Rulemaking regarding proposed fee increases for the Student and Exchange Visitor Program (SEVP), voicing concerns around the potential unintended consequences of this proposal. The letter also addressing other recent changes to policies impacting international students, highlighting how in totality, these actions could impede the ability of U.S. colleges and universities to attract top international talent. 


    Community Comments on Borrower Defense Rule (8/30/2018)

    On August 30, CGS signed on to comments from the higher education community sent to the Department of Education around its proposed final rule on borrower defenses to repayment. The letter specifically addresses proposed changes to the process for granting borrowers relief due to the closure of, or misrepresentations by, their institution. 


    CGS Comments on USAID Education Policy (8/2/2018)

    On August 2, CGS submitted comments and feedback to the U.S. Agency for International Development (USAID) around a set of questions posed at a discussion on the U.S. Government Basic Education Strategy and the impending USAID Education Policy. CGS provided several recommendations that USAID can implement with respect to this critical issue, including: strengthening the academic workforce; partnering with institutions to advance research; improving student support services; and bolstering connections with employers and industry.


    Community Letter on Proposed Changes to Visa Applications (5/14/2018)

    On May 14, CGS signed onto comments submitted by the higher education community to the State Department over its proposed changes to the application for nonimmigrant visas, including student visas, work visas, and tourist visas, which would require the reporting of five years of identifiers for social media platforms, previously used telephone numbers, email addresses, and international travel. The letter highlights the community’s concerns with the message this action would send to international scholars and the impact it would have on the ability of U.S. colleges and universities to attract the world’s top students and researchers.


    Community Letter to FBI Director on Higher Ed National Security Issues (4/24/2018)

    CGS signed onto a higher education community letter sent on April 24 to FBI Director Christopher Wray expressing concern over the disbanding of the National Security Higher Education Advisory Board (NSHEAB). The letter cites a recent congressional hearing regarding heightened security concerns around international students and theft of intellectual property. It also requests a meeting with relevant national security agencies to discuss national security issues that intersect with higher education.


    Community Letter on DACA Renewal Process (4/13/2018)

    CGS signed onto a higher education community letter sent on April 13 to the Homeland Security Secretary Kirstjen Nielsen expressing support for the Department of Homeland Security’s (DHS) effort to process renewal applications for current Deferred Action for Childhood Arrivals (DACA) registrants. The letter stresses the importance of expediting the process and encourages DHS to promptly review submissions that have recently expired or will expire in the coming days and weeks, to avoid a backlog of applications which may result in a loss of protections for DACA recipients whose status many soon lapse.


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