SEVP releases final guidance for ESL pathways in the US

On 28 October, the Student and Exchange Visitor Program (SEVP) released its long-awaited policy guidance for pathway programmes in the US. The announcement put an end to a more-than-two-year wait for US educators who have been anticipating new policies and processes governing pathways - that is, those programmes that enroll international students in English preparation courses leading to full degree study. SEVP’s S7.2: Pathway Programs for Reasons of English Proficiency provides educators with a road map as to the steps needed for pathway programme certification, but it leaves open some questions, or at least items for interpretation, as well. The now-final pathway guidance comes into immediate effect and focuses on English preparation pathways. It effectively treats such programmes as language training programmes, and, in that context, it requires that pathway providers:

• ensure that candidates that successfully complete the preparatory requirements of the programme are guaranteed admission to degree study; and
• incorporate for-credit academic courses that count towards the pathway students’ degree requirements.

SEVP also requires that each pathway must now receive SEVIS certification in order to issue Form I-20s (the document that international students need to acquire a study visa) to prospective students. Established pathway programmes must secure this certification within the next year in order to continue issuing I-20s. New programmes must now be certified before they can do so. Pathway programmes are instructed to apply for this certification by filing their programme details on the school’s Form I-17 (“Petition for Approval of School for Attendance by Nonimmigrant Student”), including the following:

• Programme length, dates, location(s), and modes of learning (with the guidance stipulating that online or distance-learning courses cannot make up any part of the course of study)
• Proof that the courses equate to full-time study, whether measured in credit hours or clock hours or both
• Admissions standards for both the preparatory and degree programmes, including any language requirements, along with standards for marking progress and completion of pathway steps
• Full course of study requirements for the degree programme

In terms of the institutions or schools offering the pathway:

• providers must also verify that the degree programme is offered by an accredited institution of higher learning; and
• similarly, providers must also verify that the English language course provider is accredited by a US Department of Education-recognised accrediting agency as outlined in the Accreditation of English Language Training Programs Act. This requires regional accreditation of the parent institution for university-governed schools or accreditation through the Commission on English Language Program Accreditation (CEA) or the Accrediting Council for Continuing Education and Training (ACCET).

Submissions for programme certification will be accepted, denied or issued a “remedial action plan” from SEVP, although no further information was given regarding the timing or time required for the certification process.

Adapting to the new guidance: questions remain

SEVP’s final guidance updates a draft pathways policy published in September 2014. In the years since, many universities and English language schools have postponed starting up or making significant changes to pathway programmes while awaiting this final guidance. The guidelines of the final document are much briefer than in the September 2014, and some of that brevity will now lead to further questions. In the 2014 draft version, for example, SEVP stated that any pathway programme must contain “at least one [academic, for-credit] course per session,” but that language is omitted in the final version in favour of a more general provision that, “All pathway programmes must contain credit-bearing coursework that is transferrable to the curricular requirements of a certified degree programme at the school.” As such, the timing or amount of for-credit coursework required is not clearly set out. Another question comes from the statement that all pathway programmes must be accredited. The 2014 draft wording was that “schools involved in the ESL portion of the programme must be in compliance with the Accreditation of English Language Training Programs Act,” whereas the final version wording is that schools “must possess institutional or programmatic accreditation for the pathway programme.” But many schools running or hoping to begin pathway programmes have been accredited as intensive English programmes without their pathway programmes being reviewed. If it is determined that pathway programmes are considered as separate entities needing accreditation apart from that of already-accredited basic Intensive English Programmes (IEPs), many will be further delayed as they go back to accrediting bodies for further approvals. (Accreditation for language programmes through either of the two main accrediting bodies (CEA or ACCET) typically takes at least two to three years.) Lisa Besso, director for pathway programmes at ELS Educational Services, points out that many programmes are set up with dual governance structures reporting to two different accrediting types and asks, “How will (SEVP) consider jointly governed and jointly delivered programmes where the content is accredited by the university’s own accreditation and the ESL accredited by ACCET or CEA?” Another grey area concerns the definition of full-time study. Most IEPs measure full-time study in clock hours while degree programmes measure in credit hours. SEVP has clear guidelines for each - programmes using clock-hours must verify that students basically attend classes at least 18 hours per week, while degree-granting undergraduate programmes must ensure students register for a minimum of 12 credit-hours each term. However, when a full course of study mixes credit-hour and clock-hour classes, the decision of what constitutes full-time study has been left in the past to the Designated School Official of each school. Nadia Redman, assistant director at the IEP of the University of Delaware, notes that SEVP field representatives may be able to offer guidance but the real answer for schools will likely come only by submitting their updated I-17 form. “The full-time study issue is the elephant in the room,” said Ms Redman, while adding that overall she found the guidance “really sensible.” If submitting and receiving replies for I-17 changes were a simple and easy matter, most of these questions would be trivial or at least, quickly answered. However, waiting for adjudication of I-17 changes has long been a perilous adventure for schools. Often very simple changes such as adding a major or updating admissions requirements can take weeks or months before being processed. The I-17 is used to update SEVP on any changes at an institution, such as new fields of study or location changes, so pathway programmes at larger universities could be stuck in the queue, so to speak, waiting in line behind other requests for I-17 approvals. Still, after a two-year wait and with the pathway plans of many providers in something of a holding pattern, having a concrete list of steps for moving forward has to be seen as a positive step. Cheryl Delk-Le Good, executive director of EnglishUSA, issued a statement after the document’s release saying, “EnglishUSA members have been awaiting this final guidance for quite a while. Once they have fully digested the new guidance, programmes can move forward with reinforcing changes they have made or were planning to make.” There are clearly aspects of the guidance that have been left open to second-guessing or that require some interpretation when it comes to practical implementation. SEVP may issue further guidelines if stakeholders press for more detail or as the certification process unfolds, but there is no doubt that pathway providers and other stakeholders will be studying this document and their programme models closely in the weeks and months ahead. For additional background on pathway programmes and recent policy developments in the US, please see

• “Mapping international pathway programmes in the US”,
• “More US universities establishing joint venture pathways”, and
• “US confirms visa policy for conditional admissions”.