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Zelig Gets a Visa: J-1 Visitor Status in Immigration Law November 2002 Or, to extend the analogy to the game of baseball, the J-1 serves as the utility infielder of the immigration world. The J-1 Exchange Visitor visa classification presents itself as somewhat of an anomaly in immigration law. It is possible to gain a fundamental understanding of the nature of an alien’s activities in the United States based solely on a foreign national’s “letter” designation of nonimmigrant status (“A” through “V”) in every nonimmigrant classification except for J-1. In the J-1 context, the activity of the alien is subordinated to the furtherance of U.S. foreign policy interest through the development of international exchanges, and the individually designated J-1 Programs are derived from this sweeping, macro concern. As such, the J-1 Exchange Visitor classification embraces highly disparate activities running from professors and research scholars to camp counselors; from au pairs to lecturers/short term scholars; from physicians to trainees. The maximum period allowed for these varying activities ranges from four months to seven years and the location of the authorized J-1 activity embraces academic institutions of higher learning to summer camps in rural America. Similarly, the funding sources of a J-1’s period of residence varies widely, given that Exchange Visitors may receive government grants, private salaries, or be self-funded. What above all emerges, therefore, is the extreme diversity of J-1 activities to the point that it is simply not possible to discern a common, baseline denominator from the standpoint of the Exchange Visitor. Rather, the unifying principle of the J-1 Exchange Visitor classification is a national objective of advancing U.S. foreign policy interests through the development of international exchanges. Yet, despite its protean quality and extraordinary flexibility, the J-1 Exchange Visitor classification is often overlooked by the immigration practitioner. To a certain extent, this is probably due to the fact that operationally, the administration of J-1 activities is largely controlled by J-1 sponsors, which are thoroughly vetted and cleared by the U.S. Department of State as part of its designation process.1 In short, there is a high concentration of J-1 Program expertise residing within the program sponsors themselves so as to obviate the need for ongoing counsel from the immigration bar. In spite of what appears to be the self-executory nature of the J-1 Program, the immigration bar should have an understanding of the fundamentals of the J-1 Exchange Visitor classification, in part owing to the fact that while most J-1 Exchange Visitors do indeed complete their underlying exchange and return to their home countries, using their U.S. experiences to further their career abroad, many J-1 Exchange Visitors transition into various temporary, nonimmigrant visa classifications or into permanent residence. In addition, there are various, discrete areas of J-1 practice that require focused legal services such as J-1 waiver strategy and practice, identification of appropriate J-1 Programs to meet client needs, program designation, and program sanctions, as well as a myriad of miscellaneous issues related to whether an alien’s proposed actions exceed or are consistent with the parameters of J-1 authorization. In addition, the attention now being allocated to foreign students and, more broadly, to J-1 Exchange Visitors in terms of monitoring status, visa issuance, and border entry procedures make it even more important for the immigration practitioner to have increased awareness of J-1 practice issues.2 NATURE OF THE EXCHANGE VISITOR PROGRAM Essentially, the J-1 Exchange Visitor Program is a creation of the Cold War in which a special, temporary, nonimmigrant visa classification was established so as to enable emerging elites in foreign countries to enter the United States to engage in designated educational and cultural exchanges which would further the foreign policy objectives of the United States. The antecedent of the J-1 Exchange Visitor Program appears in the Smith-Mundt Act, which initially was restricted to business visitors.3 However, it was not until the enactment of the Fulbright-Hays Act that the modern J-1 Exchange Visitor Program was established which created a special nonimmigrant visa classification to develop a broad range of educational and cultural exchanges that would promote international understanding.4 Such international cooperation was meant to further the foreign policy interests of the United States. As a direct corollary of this emphasis on international exchange/foreign policy interest, many J-1 Exchange Visitors become subject to a mandatory legal obligation of returning to their home countries for two years in order to impart both the substantive knowledge as well as the cultural values derived from their time spent in the United States. The two-year home residence obligation is not a blanket attribute of the J-1 Exchange Visitor Program; rather, the two-year home residence obligation attaches only in the following three specific instances:
If a J-1 Exchange Visitor is in fact subject to the two-year home residence obligation, he or she is barred from qualifying for an H visa, an L visa, or permanent residence unless the J-1 alien either resides and remains physically present in the country of nationality or last residence for a mandatory two-year period of time or, in the alternative, gets a waiver of the two-year home residence requirement. 6 At the outset, it should be noted that the two-year home residence requirement serves as a bar to obtaining stipulated enumerated immigration benefits—i.e. , a change of status in the United States from the J-1 classification to any other nonimmigrant status except A or G, or to adjust to permanent residence 7, an H or L visa, or permanent residence. Conversely, the home residence obligation does not serve as a bar to obtaining any other immigration status 8 (generally speaking, any other nonimmigrant visa or even H or L status for an alien who is visa exempt— i.e., a Canadian citizen). Bars for “unlawful presence” generally do not apply to J-1 visa holders.9 The vast preponderance of J-1 Exchange Visitors are admitted under duration of status (D/S) as opposed to having a date specific affixed to the I-94 Form. As such, J-1 overstays generally do not accumulate unlawful presence so as to become subject to the three- or ten-year bars. In addition, J-1 overstays are generally not barred from third country processing. Violations of J-1 status (including overstays) will subject the Exchange Visitor to removal exposure, but the Exchange Visitor is not subject to either the §212(a)(9) bars or the §222(g) third country processing restrictions of the INA unless the INS*** or an immigration judge makes a formal finding of a status violation (including overstay).10 The INA contains various provisions enabling an Exchange alien to receive a waiver of the two-year home residence obligation. While waiver strategy and practice is discussed somewhat more extensively below, the Act specifies four grounds for obtaining a waiver:
The J-1 Exchange Visitor Program is administered by the U.S. Department of State (DOS), which essentially privatized its administration of this program through the designation of various program sponsors that are charged with the direct, hands-on administration of the various programs. At present, there are about 1,400 designated program sponsors that have been approved by the U.S. Department of State as meeting the criteria required for J-1 Exchange Visitor sponsorship.14 Once an entity has been designated as a program sponsor, it undertakes a broad range of responsibilities to ensure that the overall objectives of the program are being met, and that entity receives the right to issue the underlying J-1 sponsorship authorization form, the DS-2019 (formerly IAP-66), which essentially sets forth the basic terms, conditions, and duration of the alien’s authorized activities. 15 The J-1 Exchange Visitor Program embraces a wide range of activities in the United States. The specifically enumerated J-1 Programs include: college and university students,16 secondary school students, 17 au pairs,18 summer student travel/work programs,19 professors and research scholars,20 short-term scholars,21 teachers,22 physicians,23 specialists,24 trainees,25 camp counselors,26 international visitors,27 and government visitors.28 Again, it is not sufficient simply to show that the alien’ s proposed activities fall within these designated vocations; rather, the alien needs to receive sponsorship from a designated program sponsor that is committed to ensuring that the alien’ s participation in any of these specified activities is conducted in a manner intended to facilitate international exchange. It could certainly be argued that the passage of time has eroded the initial justification for the J-1 Exchange Visitor Program, which is to develop educational and cultural exchanges in order to further the foreign policy of the United States. Certainly, within today’s globalized world, we see a vastly increased flow of international travel and a vast expansion – if not endorsement – of U.S. cultural values, which, in essence, may obviate the continuing justification for the J-1 classification. Yet, each year, roughly 200,000 foreign nationals enter the United States under the J-1 Exchange Visitor Program, making this particular visa classification one of the most frequently utilized nonimmigrant visas by foreign nationals entering the United States. 29 PROGRAM DURATION One of the principal questions involving J-1 practice simply relates to the duration of authorized stay under the various J-1 Programs. Given the above-noted diversity of program category, the following chart is intended to outline the existing allowed duration of program participation. Professor or research scholars HOW TO OBTAIN J-1 STATUS – FOR THE FOREIGN NATIONAL Each J-1 participant must be sponsored by an Exchange Visitor Program sponsor designated by the DOS. A prospective sponsor must be a local, state or federal government agency, an international agency or organization of which the United States is a member and which has an office in the United States, or a reputable organization that is a “citizen of the United States.” 38 (This last category includes the American Immigration Law Foundation (AILF). See www.ailf.org for information about AILF’s Exchange Visitor Program.) The citizenship requirement precludes organizations controlled by foreign corporations or individuals.39 The sponsor issues a Certificate of Eligibility, Form DS-2019, to eligible aliens who may use it to apply for a J-1 visa or admission, or to apply to change to J-1 status. In June 1997, the INS*** initiated a Student/Exchange Visitor Tracking pilot program in accordance with §641 of Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRAIRA),40 which mandates the Coordinated Interagency Partnership Regulating International Students (CIPRIS) program for tracking F, J, and M aliens. Twenty-one higher education facilities were selected to participate. Participating sponsors issued new versions of the IAP-66, known as IAP-66P, which included certain machine-readable data placed on the right-hand side of the document. Also tested was a student identification card, Form I-868, which could be presented by students instead of the IAP-66. CIPRIS formally ended in October 1999. In December 1999, the INS issued a proposed rule 41 to implement fees to be dedicated to underwrite the costs of a permanent CIPRIS-type program, which then was renamed as the SEVP (Student and Exchange Visitor Program) data collection program. This rule required that each J-1 participant, except those in U.S. government sponsored programs, who registers or enters a J Program after the effective date of the final rule pay a fee of $95 within 90 days after the first date on the Form IAP-66 to the Exchange Visitor sponsor. The sponsor would, in turn, be responsible for collecting and submitting the fees to the INS, along with proposed Form I-901. The fees would go toward covering the cost of the CIPRIS program. The fee would have to be paid again when a new IAP-66 is issued for transfer of sponsors, commencement of a new J Program, or for a change of J-1 category. The sponsor would be obliged to inform each J-1 participant to pay the fee, to complete and verify Form I-901, and to collect and remit the form and fee to the INS. Failure of the J-1 participant to pay the fee would place the J-1 participant out of status, requiring reinstatement. Failure of the sponsor to remit the fee could result in revocation of services of an Exchange Visitor Program if DOS funding is involved. The SEVP, a partnership between INS and DOS, has developed SEVIS, the Student and Exchange Visitor Information System. Legislation signed into law on October 30, 2000, directed that user fees to pay for SEVIS should be collected from scholars, in connection with applications for visas or changes of status.42 The legislation also limited the amount of the fee to a $40 maximum for participants in certain J Programs. The DOS issued instructions to Consular Posts about how the fee will be collected from J-1 participants applying for visas abroad. However, according to the DOS cable, although INS is “hard at work developing a simple, no-frills system for collecting the F/M/J fee,” the INS has not completed its plans.43 Following enactment of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act ), INS withdrew the pending SEVIS fee collection regulation since the anti-terrorism legislation specifically authorizes appropriated funding to create the system.44 The SEVIS program will require all J-1 Program sponsors and institutions sponsoring F-1 students to document a variety of data on all J-1 participants and F-1 students in a real-time, interactive system accessible only by authorized users.45 Under SEVIS, every J-1 Program sponsor will be obligated to provide the following data on program participants: (1) name, (2) date of birth, (3) place of birth, (4) country of citizenship, (5) current address, (6) visa classification, (7) date of visa issuance, (8) date classification granted, (9) academic or program status of alien, (10) dates of work authorization, termination of program.46 Under the USA PATRIOT Act, SEVIS also must include data on port of entry and date of entry,47 but presumably the sole source of this information will not be the J-1 Program sponsor. The USA PATRIOT Act requires that SEVIS be on-line prior to January 1, 2003, and it was anticipated that the pilot schools were to be testing the program by summer 2002, with the rest of program sponsors going on-line by the end of 2002. In spring 2002, Congress passed the Enhanced Border Security Act that specifically mandated that within 120 days of passage, F, M, and J visa issuance would be predicated upon receipt of secure electronic notification confirming the bona fides of the sponsoring organization.48 Although the above referenced Act specifically applied to students, the DOS has extended SEVIS/ISEAS (Interim Student Exchange Authentication System) clearance to include all J-1 Exchange Visitor visa applicants.49 Effective September 11, 2002, Consular Posts can only issue J-1 visas pursuant to electronic notification per the new ISEAS system. Owing to the understandable inability of many Program sponsors to register program acceptance in the ISEAS system, the DOS has granted a 30-day period in which Consular Posts can receive alternative notification from the program sponsor. Very possibly, this 30-day period for alternative notification will be extended for an additional period of time until all program sponsors are up and running on the electronic ISEAS program.50 Upon receipt of a DS-2019, the alien beneficiary then possesses the required document to seek J-1 benefits. Effective September 1, 2002, the underlying J-1 sponsorship form changed from the IAP-66 Form to the DS-2019. IAP-66 Forms executed prior to September 1, 2002, will still be accepted at Consular posts for purposes of J-1 visa issuance. At least facially, there does not appear to be major substantive changes on the DS-2019 Form; the new form was created to facilitate ease in electronic collection of J-1 data. If in the United States, the alien within the parameters of §248 of the Act can request a change into J-1 status. If, as more frequently occurs, the alien is abroad, he or she will present the DS-2019 to the U.S. Consulate for purposes of receiving a J-1 visa. The essential visa application procedure at the Consulates remains unchanged, although delays and increased scrutiny now characterize (or plague) the system. The J-1 visa applicant bears the burden of establishing his or her intention to reside in the United States in a manner consistent with the requested visa coverage, as appearing on the sponsorship document. J-1 visa applicants do need to establish nonimmigrant intent since they are fully subject to §214(b) considerations. However, as a practice matter, the existence of a two-year home residence obligation is an important consideration to Consular Officers since it establishes a legal compulsion to depart the United States upon the conclusion of the J-1 Program. As such, the mere existence of a home residence requirement is a probative (though not determinative) factor in confirming non-immigrant intent. Once in valid J-1 status in the U.S., according to IRS publication 519 (U.S. Tax Guide for Aliens), the J-1 participant is exempt from all U.S. tax withholdings for FICA and FUTA (Federal Medicare, Social Security and Unemployment) for two calendar years (two tax years). In addition, the spouse of a J-1 may seek employment authorization provided that the income is not used to support the J-1 principal alien. Rather, the J-2 applicant filing Form I-765 for an EAD card needs to show the employment will be used to support various recreational and nonessential objectives.51 Changes to the employment and tax related obligations may be on the horizon for J-1 status holders and their families. In spring 2002, it was reported that the Internal Revenue Service was seeking to take a census of foreign visitors through Form 8843 by stating in its training manuals that even nonresident J-1s and F-1s who had no income must still file Form 8843 and that Form 8843 must be filed for every family member who is in the United States on an F-2 or J-2 status.52 In the past, Form 8843 was filed only by aliens who were documenting that they were excluding days present in the U.S. under the substantial presence test because of their J-1 or F-1 status (or their status as an alien professional athlete or alien with a medical problem).53 HOW TO OBTAIN J-1 DESIGNATION – FOR THE PRIVATE ENTITY SEEKING ITS OWN PROGRAM The DOS designates program sponsors and their authorized representatives (entitled “Responsible Officers” and “Alternative Responsible Officers”) after review and approval of applications filed with the DOS’s Exchange Visitor Program Designation Office.54 Such applications consist of Form IAP-37 (Exchange Visitor Program Application) and supporting documents. Applications may be obtained by calling or writing: Exchange Visitor Program Designation Staff, Bureau of Educational & Cultural Affairs, U.S. Department of State, 301 4th Street SW, Washington, DC 20547; telephone: (202) 401-9810. As of April 14, 2000, the initial application for program designation requires a fee of $779. The regulations indicate that program designation is within the DOS’s discretion and that only sponsors of bona fide “educational and cultural exchange programs,” as described in the Fulbright-Hays Act 55 may be considered for designation as Exchange Visitor Programs. In addition to the U.S. citizenship requirement, other criteria for program designation include: reciprocity of exchange wherever possible; a minimum of five Exchange Visitors per year, except for short-term scholars; a minimum Exchange Visitor stay of three weeks; for nongovernmental sponsors, proof of financial responsibility; adequate staffing and sufficient support services; and mandatory insurance coverage for participants covering health, accident, dismemberment, and repatriation of remains.56 This insurance coverage must cover both the principal J-1 and any accompanying J-2 dependents. Program designation is effective for a period of five years, though the DOS may designate programs for fewer than five years.57 At least four months before the end of the designated period, the sponsor must seek re-designation for another five-year term.58 The program sponsor is responsible for: selecting Exchange Visitor participants; providing pre-arrival information; offering orientation; controlling the completion and issuance of Forms DS-2019; monitoring Exchange Visitor participation; cooperating in DOS investigations; making annual and other required reports; and retaining records.59 The responsible officer (RO) and his or her alternates take on certain responsibilities on behalf of their program sponsors. These responsibilities include: being familiar with DOS regulations; providing guidance and assistance to participants regarding the governing regulations and procedures; conducting official communications with the DOS and the INS; serving as custodian of Form DS-2019;60 and ensuring compliance with insurance and other program requirements. DOS regulations state that a sponsor probably will not be penalized except for knowing violations of the regulations.61 NATURE OF THE TWO-YEAR HOME RESIDENCE REQUIREMENT For many aliens, the two-year home residence requirement serves as a major disincentive to come to the United States under a J-1 visa. As noted above, should this obligation indeed apply, the Exchange Visitor is barred from obtaining an H visa, L visa or permanent residence unless and until he or she has either resided and is physically present in the country of last residence or country of nationality for two years or, in the alternative, has received a waiver of the two-year home residence obligation. There are several points that immediately bear comment on this issue. First, not every J-1 Exchange Visitor is subject to the two-year home residence requirement. Rather, in order for the residence obligation to attach, the Exchange Visitor needs to be working in a field of endeavor appearing on the home country’ s Skill List, to have received, either directly or indirectly, government funding from either the home country or the U.S. government, or to be enrolled in a program of graduate medical education. All other Exchange Visitors simply are not subject to this home residence obligation and therefore have considerable flexibility in pursuing other immigration objectives in the United States.62 Second, some people believe that the “home residence requirement” must be a misnomer and that the Exchange Visitor is simply required to depart the United States for a mandatory two-year period of time. In truth, the home residence obligation needs to be completed specifically in either the Exchange Visitor’s country of nationality or country of last residence prior to his or her entry under a J-1 visa.63 Third, perhaps the first obligation of the practitioner in dealing with a J-1 Exchange Visitor is to determine whether the two-year home residence obligation actually applies. As an initial, preliminary determination, the practitioner needs to examine the IAP-66 or DS-2019 Form which essentially constitutes the existing written record of key facts pertaining to the Exchange Visitor– particularly, the country of nationality and/or last residence, the funding sources, and the field of endeavor. However, as a practice pointer, regardless of the information appearing on the sponsorship forms, there can still exist considerable uncertainty as to whether an Exchange Visitor is indeed subject to the two-year home residence obligation. In appropriate instances, it is possible to contact the DOS to correct erroneously stated information, such as an incorrectly stated country of last residence. In addition, it may be possible to further clarify the specific, actual field of endeavor in which the Exchange Visitor is engaged which could establish that this field of endeavor does not fall on the home country’s Skill List. What is quite certain, though, is that notations regarding 212(e) applicability on the J-1 sponsorship form and/or on the J-1 visa stamp do not conclusively establish whether or not the two-year home residence requirement actually applies to the Exchange Visitor. All too often, the Consular Officer makes an erroneous assertion regarding 212(e) applicability which in equal measure, in the authors’ experience, misstates the existence of this home residence requirement in a manner favorable and unfavorable to the alien’s interests. Therefore, it becomes extremely important to make a well-reasoned, thorough, independent judgment as to whether the alien is subject to a home residence obligation. In this regard, we would refer you specifically to an article co-authored by Ronald Klasko and William Stock, which lays out a series of creative and provocative concepts in determining the existence of the home residence obligation. In our opinion, this article is a mandatory reference document for any practitioner in this area.64
It is very much open to question whether these fulfillment standards accurately track the statutory language. It is, in fact, the position of the authors that many of the DOS positions enumerated above are contrary to the statutory language of the INA. For example, nothing in the INA seems to bar the J-1 Exchange Visitor from splitting time between the country of last residence and country of nationality, and nothing in the INA suggests that the term “country of residence” equates to the narrow definition of permanent residence.68 Traditionally, the judiciary has been quite deferential to both the DOS and the INS on 212(e) issues,69 but we would, nevertheless, maintain that there is a very plausible basis for considering that the congressional intent was to create a greater level of flexibility and personal choice in the fulfillment of the two-year home residence requirement than appears in the above-stated policy. WAIVER BASICS First, for all J-1 Exchange Visitors with the sole exception of J-1 physicians, only a federal agency can serve as an Interested Government Agency (IGA), and the various federal agencies maintain their own procedures and standards in order to determine whether a waiver is merited as serving the public interest. In the case of physicians, each state’s Department of Health can serve as an IGA.70 Pursuant to what may soon be the Conrad State 30 Program, each state will have available an allotment of up to 30 waivers per fiscal year so as to facilitate the relocation of a physician into fulltime practice in a designated medically underserved area.71 Second, as a practice pointer, No Objection Statements issued by the alien’s home country do not necessarily result in an approved Waiver Application. If an Exchange Visitor has received U.S. government funding, the home country’s No Objection Statement will be balanced against the competing interest of the funding agency in having the alien return to the home country for two years. Particularly in instances in which the Exchange Visitor has received U.S. government funding, the sponsoring agency normally (and successfully) objects to the issuance of a waiver. Therefore, in such instances, it is extremely desirable to arrange some type of a release statement with the Exchange Visitor’s funding organization. Third, whereas there had previously been a de minimus rule in which minimal, inconsequential government funding grants (principally for travel purposes) would not create a two-year home residence obligation, the current standard is that any level of government funding – even an inconsequential amount – will vest upon the Exchange Visitor a two-year home residence obligation.72 Fourth, whereas the issuance of a waiver normally makes the alien beneficiary eligible for permanent residence, physicians receiving J-1 waivers based upon clinical medical service in either a designated medically underserved area or within a VA Medical facility need to fulfill a three-year period of employment working specifically in H-1B status in order to gain eligibility for permanent residence. Conversely, if the physician does not fulfill his or her three-year H-1B service obligation working specifically within the sponsoring medical entity (other than instances involving extraordinary circumstances accompanied by relocation to another designated medically underserved area or VA Medical facility) the alien fails to gain eligibility for permanent residence status and, indeed, violates a core term of the Wavier.73 Fifth, we should also note in passing that not all J-1 physicians are mandatorily subject to the two-year home residence obligation. Rather, this mandatory, across-the-board home residence requirement applies specifically to all J-1 physicians coming to the United States to enter programs of “graduate medical education,” which is defined as clinical residency or fellowship training programs. Also, such J-1 physicians require the sponsorship of the Educational Commission on Foreign Medical Graduates (ECFMG). Conversely, J-1 physicians coming to the United States under non-clinical programs normally involved in teaching and research activities would fall subject to the two-year home residence requirement based solely upon Skills List or government funding considerations and can receive their Program sponsorship either from their employing institution or from the ECFMG.74 Sixth, as noted previously, an unwaived and unfulfilled two-year home residence requirement will serve as a bar to permanent resident status. Although the INS has the final authority to issue the waiver, it is now established policy that the INS will adjudicate an adjustment of status application once the DOS has issued a Waiver Recommendation, rather than awaiting the issuance by the INS of its Form 612.75 The apparent rationale for this policy is that once jurisdiction for waiver processing passes to the INS, it is simply senseless to postpone adjudication of an adjustment of status application pending final processing of the waiver, particularly given the extremely high likelihood – bordering on a certainty – that the waiver will be approved by the INS. It has further been the experience of the authors that using this exact same rationale, the INS will process and approve applications to change an alien’s status from J-1 to H-1B upon presentation of a Waiver Recommendation from the DOS. * Robert D. Aronson is a principal in the Minneapolis-based immigration law firm of Ingber & Aronson, P.A. He is a widely recognized authority on immigration law pertaining to foreign physicians, and was the immigration consultant to the Commission on Graduate Medical Education (COGME), the U.S. government’s advisory board on healthcare reform. He is a member of AILA’s liaison committee with the Department of State and serves as AILA’s liaison on J-1 Waiver matters. He holds his J.D. from Indiana University and was a Fulbright Fellow at the Schools of Law at Moscow University and Harvard University. The author wishes to thank Susan Arefe and Salima Khakoo for their assistance in the preparation of this article. ** Amy Marmer Nice practices immigration law with the firm of Dickstein, Shapiro, Morin & Oshinsky where she heads the firm’s immigration practice. She is a Phi Beta Kappa graduate of Tulane University, and she earned her J.D. from the George Washington University. Ms. Nice has been a co-chair or committee member of AILA’ s National Exchange Visitor Liaison 1994-present, including participation on the Exchange Visitor Programs Reinventing Government panels in 1999. She is active in advising U.S. organizations who have obtained or are seeking designation as J-1 Program sponsors. *** At the time this article was written, the Immigration and Naturalization Service (INS) served as the main immigration body of the U.S. Government. Since March 2003 immigration processing functions are a part of the Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS) from the legacy INS. 1 22 CFR §62.10(a). |
Aronson & Associates, P.A. |