BU Expands Opposition to DHS Four-Year Visa Limit Proposal

(BOSTON, MASSACHUSETTS) Boston University is pushing back against a federal proposal that would end the long‑standing “duration of status” (D/S) policy for F‑1 and J‑1 holders and replace it with a fixed four‑year limit on most international student visas and research scholar stays. The Department of Homeland Security published the draft rule in the Federal Register on August 28, 2025, opened a public comment window through September 29, 2025, and is now reviewing feedback. The rule remains a proposal; it has not been finalized or implemented.

BU filed a formal comment on September 25 urging DHS to withdraw the plan outright, arguing the change would cut the flexibility that students depend on and inject new risk into academic timelines that often shift for valid reasons. The university says the policy would lessen the appeal of the United States 🇺🇸 for top students and scholars and could weaken research and local economies that benefit from international enrollment.

Policy proposal and timeline

At the heart of the plan is the move away from duration of status (D/S)—the current policy that lets F‑1 and J‑1 visitors remain as long as they are enrolled and making normal progress—toward fixed end dates on I‑94 records. DHS has framed the shift as a way to create clearer oversight and prevent status abuse with set expiration points rather than open‑ended D/S.

Key elements of the draft rule include:

• Fixed Four‑Year Limit: Most students and scholars would receive up to four years, regardless of program length.
• Extension Requirement: Anyone needing more time would have to file an extension of stay with U.S. Citizenship and Immigration Services (USCIS), creating added cost, paperwork, and wait times.
• Limits on Flexibility: F‑1 students could face restrictions on transfers and major changes, especially in the first year—limits domestic students do not face.
• Shorter Grace Period: The post‑completion grace period would drop from 60 days to 30 days.
• English Language Programs: Students in English training programs would be capped at 24 months, plus a 30‑day grace period.
• OPT / STEM OPT Impact: Students using Optional Practical Training and STEM OPT would need to plan for possible extensions tied to the new end dates.

According to analysis by VisaVerge.com, the move from duration of status to fixed terms would ripple through every stage of the student lifecycle—from initial admissions planning to graduation and work authorization. While some extensions may be approved, the uncertainty and timing of requests could prompt students to alter course loads or delay academic opportunities to avoid falling out of status.

DHS has not issued a final rule or implementation date. The public docket, listed as ICEB‑2025‑0001, drew heavy engagement from universities, associations, and advocacy groups. The official docket remains accessible at Regulations.gov docket ICEB-2025-0001.

Campus and industry impact

BU’s submission says the fixed four‑year limit does not match real academic pathways. Many degree tracks exceed four years or require extra time because of capstone projects, thesis research, part‑time co‑ops, or lab work that moves at a slower pace than the calendar suggests. Architecture, some undergraduate programs, and nearly all Ph.D. tracks are common examples.

Under a fixed‑term model, students in these programs would often have to stop mid‑degree to request more time—precisely when academic intensity peaks.

University officials also warn the rule would constrain normal academic choices. First‑year students frequently switch majors after testing different fields, and many students transfer to find a better academic fit. Under the proposal, those routine changes could risk status if they trigger stricter checks or new filings.

BU argues this would put international students on a tighter leash than their U.S. peers, creating unequal treatment in the same classrooms.

Grace periods, OPT, and timing risks

The proposal’s shorter grace period—from 60 to 30 days—could catch graduates in a tight squeeze while they prepare for travel, pursue graduate school admissions, or file for work authorization. For students on OPT or STEM OPT, coordinating extensions with fixed end dates adds another layer of timing risk.

A delay could push a student into unlawful presence despite good‑faith efforts to comply.

Broader reactions and economic concerns

BU’s concerns echo a broad higher education response. More than 50 associations, including the American Council on Education, have urged DHS to pull back, citing flawed data and the risk of chilling international enrollment.

University leaders point to well‑documented benefits international students bring to:
– on‑campus research and labs
– start‑ups and local businesses
– local job markets and community spending

They warn that extra red tape could push students to choose other countries with simpler rules.

The debate is not new. During the Trump administration, DHS floated a similar plan to end duration of status; that effort was dropped in 2021 under President Biden. The current proposal comes amid renewed scrutiny of student mobility under President Trump’s second term, with DHS and ICE stating the need for clear end dates and more direct oversight.

Practical guidance for students and universities

For students already in the United States 🇺🇸, the practical question is what to do now. BU’s International Students & Scholars Office (ISSO) is urging calm and careful planning.

Because the measure is still a proposal, the existing duration of status policy remains in force. Advisors are preparing for two tracks: helping students succeed under current rules, and mapping exact steps if DHS finalizes the change.

Preparation steps include:

1. Reviewing academic plans that exceed four years.
2. Flagging transfer or major changes that might face added checks.
3. Tracking program end dates and OPT timelines well in advance.
4. Setting reminders for any future extension windows if required.

University counsel warn that processing backlogs could magnify the impact. If thousands of students seek extensions at once, even modest delays could create gaps in work or research—particularly harmful to lab‑based fields and funded research teams that rely on steady staffing and time‑sensitive experiments.

Employers are watching as well. Firms that count on OPT and STEM OPT to bring in skills say uncertainty around end dates could disrupt hiring. Shorter grace periods could complicate:
– start dates,
– travel plans, and
– onboarding schedules.

Some companies may hesitate to make offers if they fear last‑minute status problems, which could shrink the job market for new graduates.

The stakes are personal for students and families. Many plan for years, invest savings, and travel far to study in the U.S. A fixed clock, even with an extension option, adds the stress of possible denials beyond their control. BU and peer schools argue that timing risk belongs to the government’s workflow, not on students’ shoulders.

Next steps and recommendations

DHS will decide next steps after reviewing comments and may:

• revise the proposal,
• issue a final rule, or
• take no action.

If finalized, universities say they will need more advisors and stronger compliance systems to help students file on time and avoid status gaps. Students in longer programs would be urged to set internal checkpoints to consider extension filings earlier than they normally would.

For now, campus leaders advise:

• Keep following current rules under duration of status.
• Stay in close touch with your international office.
• Watch for federal updates from DHS, BU’s federal relations team, and ISSO.

Important reminder: the draft rule is not final. Continue to rely on existing D/S rules and consult your ISSO or university counsel for personalized guidance. National associations and university teams are coordinating responses in case DHS moves ahead.