Dodging SEVIS Snafus: are IHEs surprised by the demands of SEVIS? Perhaps not. Unprepared? Absolutely! (On The Money).

INS. The State Department. Campuses. Lobbyists. Higher education associations. Foreign student advisers. Software vendors. IT staff. Third-party providers. Have there ever been more actors on the higher education stage, all with different scripts? With the date of SEVIS implementation set by law (January 30) less than two months away, there is still much unknown, even more undone.

So, what's the big deal? Haven't colleges and universities been collecting the same information on foreign students for years, in order to issue I20s (the forms upon which student visas are issued)? Isn't this the same drill, just in an electronic format? Isn't this just an IT issue? No, no, and NO! There are, in fact, some new data requirements. More significant, however, is the fact that schools will now review student status changes as they occur and within a set time period, rather than upon request as in the past. The need to change business practices (such as notification processes, data collection, and entry activities, etc.) in order to know when a reportable event occurs, may dwarf the IT issues at many institutions.

But, you may say, the financial aid community has for years had to process information electronically with the Department of Education. It withstands annual changes to what needs to be collected and how it needs to be transmitted. What's the difference with SEVIS?

The difference is that for those same years, it was the financial aid world--not the international-student advisory world--that was under the spotlight. Up until last fall, international-student advisers faced no such notoriety. On many, many campuses, the international-student officers have been relegated to a corner of the basement in "Old Main," unknown and unseen by senior administration--save, perhaps, the vice president for Student Affairs. So, part of the challenge on campus may be just getting the attention of the administration tong enough for everyone to understand the immediate and significant impact SEVIS will have. That's why a good place to start a SEVIS discussion is with ...

WHAT IS SEVIS--REALLY?

To quote the American Council of Education's Terry Hartle in his testimony last fall before the Committee on Judiciary, "SEVIS is an extraordinarily large and complex information technology system. When fully operational, it will link all US embassies and consulates, all INS ports of entry in this country, the State Department's Office of Exchange Coordination and Designation, the Bureau of Educational and Cultural Affairs, every institution of higher education that sponsors international students, and every exchange visitor program." The Internet-based solution maintains critical, up-to-date information about foreign students and exchange visitors and their dependents, and allows for electronic access to the information so that INS can track students faster and more accurately. SEVIS will be used to issue an I20 by INS, and for tracking extensions, transfers, authorized employment, and reduced course toads. Notification of the following events, for instance, must be made within 21 days: student enrollment at school, start date of next term or session, student failure to enroll, dropping below full time without prior designated school official (DSO) approval, failure to maintain status or achieve completion, changes in student or dependent name and address, and certain disciplinary actions taken.

LOOKING AT THE SEVIS TIMELINE

The development of a system such as SEVIS should have come as no surprise. In September 1996, in response to the bombing of the World Trade Center three years earlier, Congress passed the Illegal Immigration Reform and Immigrant Responsibility Act, mandating by the year 2003 the creation of an electronic reporting and tracking system for international students. Progress ground forward, but no wholesale changes were implemented, and not too many people were paying attention. The original deadline date was abandoned in 2000.

Then came 9/11. Within a month, Congress passed the USA Patriot Act. The Act reinstated a January 2003 deadline for colleges to get INS authorization to use SEVIS, in order to be able to continue to serve international students. But it was not until July 2002 that INS released SEVIS Web screens for colleges to use to hand-enter international-student data. And the specifications for a batch process were only released in late fall. This batch process will accept electronic feeds from institutional student databases--provided the school or the vendor develops the proper interface. But the turnaround window for creating such interfaces is very tight; hence the IT challenge that was so much discussed in the autumn.

DIFFERENT (KEY) STROKES FOR DIFFERENT FOLKS

How institutions will respond to the SEVIS requirements depends on the number of international students enrolled and the type of student information system employed.

Institutions with small numbers of international students won't need to worry about a batch process, although they will still need to develop procedures for knowing when reportable changes have occurred. Institutions with more than 200 international students, however, will likely need to employ the batch solution.

For institutions served by one of the major vendors that make student information systems--PeopleSoft (www.peoplesoft.com), SCT (www.sct.com), Datatel (www.datatel.com), etc.--upgrades to current systems are being provided. However, these are in all likelihood not going to be "smart" systems, according to David Clubb, director of International Services at the University of Pittsburgh. In fact, Clubb suggests you should ask your vendor a number of questions in order to determine what remains to be done after the upgrade. Questions such as:

* Will the system be able to store an electronic copy of all the forms?

* Does the system provide automated alerts that protect my internationals and help ensure institutional compliance?

* Does the system have an event-reporting module to deal with compliance during the semester?

* Does the system enforce the immigration law, therefore cutting down on data entry errors and protecting the students and the school?

Many institutions are turning toward third-party providers that would automate all the required rules to comply with SEMIS. The companies Windstar Technologies (WWW.windstar-tech.com), Newfront Software (www.newfrontsoftware.com), and i1440 (www.i1440.com) are creating such products. A Massachusetts firm, FolderWave (www.folderwave.com), has put together an offering that is intended to be very simple for the school. Using FolderWave's Web-based application generator--coupled with a variety of implementation services that enable rapid development and deployment of complex applications--the company has created a solution that will accept data in any format (paper, electronic, voice, etc.), enter it into the application, and apply business rules For alerts and reminders of SEVIS events.

SEE SEVIS FIRST

SEVIS requires that each school receive a site visit from INS prior to certification. However, in the summer and early fall, INS granted full SEVIS access prior to a site visit to schools that submitted an electronic petition and that met preliminary enrollment criteria (a site visit will be necessary eventually). Almost 1,000 schools participated. Later in the fall, INS indicated that other "low risk" institutions would be able to use SEVIS before a site visit. But INS didn't define what it meant by "low risk"--or "high risk" for that matter. Glen Fine, inspector general of the U.S. Department of Justice, testified earlier in the fall that although INS was making great progress, his office's continuing concern centered on the physical and logistical practicality of INS being able to certify thousands of sponsoring institutions in so little time. An INS rule requires schools to submit an application for SEVIS certification at least 75 days prior to the January 30 SEVIS implementation date--and that means the now-passed date of November 16, 2002.

WHAT TO DO

As we spoke with stakeholders, their analogies of the SEMIS implementation came fast and furious, ranging from "a train wreck" to "musical chairs." From where we sit, however, an iceberg seems the more apt analogy.

How can you avoid a sinking implementation of Titanic proportions? If you're fortunate enough to have a team on campus that has been working for months, if not years, to bring your record-keeping of foreign students into the electronic age, you're probably in decent shape. If not, here's the best piece of advice we can give you:

Run, do not walk, to that basement corner office in "Old Main" and get to know your DSO.

Kathy Kurz and Jim Scannell are partners in the enrollment management consulting firm, Scannell & Kurz, Inc. (www.scannellkurz.com).