02/25/00 11:21

-llmtEd Statts Sniau

WASHINGTON. DC 20510

February 22, 2000

The Honorable Doris Meissncr, Commissioner

U.S. Immigration and Naturalisation Service
42S I Street, NW
Washington, D.C. 20536

Dear Commissioner Meissncr:

We. Hie writing to urge the Immigration and Naturalization Service to postpone
implementation of proposed rule 1991-99 authorizing the collection of fees levied on foreign
students and exchange visitors to fund the INS studenMracking system.

We have heard the concerns of many universities and other organisations across ibe
country and we arc troubled by these regulations, which would create several new requirements,
increase university coats, and place schools and exchange programs in an inappropriate rote.
Colleges and universities have expressed the view that this rule would undermine the education
of U.S. students, the resources of U.S. institutions and their local communities, and the U.S
leadership in international education.

Requiring U.S. institutions to collect fees to fund a federal program is an inappropriate

role for higher education institutions, which are not third party financial organizations equipped
to fulfill such a fiduciary responsibility. The large amounts of money, time, work, resources, and
personnel needed to collect INS fees would directly impair the abilities of colleges and
universities to educate all students as well as compete for students in the global marketplace,
which brought Si 1 billion into the U.S. economy last year. At a time when the U.S. is in fierce
competition with Australia. Japan, and the UK for the world's best students, this proposal would
place the U.S. at a disadvantage. Loss of foreign students to the U.S. means a loss of thousands
of dollars and dozens of talented students and academics in each local university community.

After carefully reviewing the concerns raised by the academic community, we have
deuided that if there is to be a fee assessed, the federal government, not schools or other private
sector organizations, should be designated as responsible agents for foreign student tec
collection.
The Immigration Service and Student Tracking.

9/11 hijackers use of student status

Mohammad Atta (alleged pilot AA #11), Hani Hanjour (alleged pilot AA#77), and
Marwan AlSehhi (alleged pilot UA #175), and Ziad Jarrah (alleged pilot UA #93)
were all students in the U.S. during the course of their U.S. stays.
• Atta received a change of status from tourist to vocational school two days
prior to his last arrival in the US in July of 2001, seven months after acquiring
his commercial pilot license from Huffman Aviation and six months after
being permitted entry as a student under a tourist visa in January 2001.
• Hanjour received an academic student visa prior to his last arrival in the US
in December 2000. His intended address was the ELS Language Center in
Orlando. Hanjour entered the US on that student visa in December 2000.
Hanjour had previously requested a change of status from a tourist visa to
academic student status in June 1996 to attend English-speaking school. He
re-entered on an academic student visa in 1997, and in 1998, applied for a
change of status from academic to vocational student. Hanjour received a
commercial pilot license from the FAA in 1999 without ever obtaining
approval for his 1998 vocational status until January 2001.
• Al Shehhi entered the US on a tourist visa in May 2000, applied for a change
of status from tourist to vocational student in September 2000 at the same
time as Atta, and was approved in August 2001. In the intervening time, he
was admitted twice on a business/tourist visa, having completed his schooling
with Atta in December 2000.
• Jarrah came in to the U.S. for the first time on June 27, 2000. The next day
he began flight school, which he attended through January 2001. He left and
re-entered three times during his studies, never applying for a change of
status.

History of student tracking

An Old Regulation and an Outdated Database Receive an Inquisitive Look

The requirement for U.S. academic, vocational and exchange institutions to maintain
current information on their foreign students dates back to 1984, when the Attorney
General issued a rule that all schools report termination for disciplinary action to the
Immigration and Naturalization Service (INS). Noncompliant schools, under the rule,
were to be disciplined, meaning loss of INS accreditation to receive foreign students. To
comply with the INS rule, schools and foreign students worked their way through a
myriad of paperwork: certification to accept foreign students under INS rules,
applications to the schools, INS 1-20 forms from the school for the student to present to a
visa officer, visa application to attend the school, U.S. entry documents, and school
registration information.1

Regulations governing students are: 8 CFR 214.2 (f), (m), and (j); 214.3 re approval of institutions;
Search - 3 Results - 8 use 1372 Page 1 of 6

Source: Legal > FederalLega\-_U,S, > United States_CMe_SeryiceXUSCS)_MateriaJs > United States Code Service -
Titles 1 through 50 - Selected Documents GO
TOC: UnitedLStatesL^d^^.rvjce...-iTit!eAJJhiojjgJl5Q > /..,..,.,_/ > MJ_SCJLLANEQUS > § 1372. Program to collect
information relating to nonimmigrant foreign students and other exchange program participants
Terms: 8 use 1372 (EdJlSearch)
•f Select for FOCUS™ or Delivery

8 USCS § 1372

UNITED STATES CODE SERVICE

Copyright © 2003 Matthew Bender & Company, Inc.,
one of the LEXIS Publishing (TM) companies
All rights reserved

*** CURRENT THROUGH P.L. 108-198, APPROVED 12/19/03 ***

*** WITH A GAP OF 108-173 ***

TITLE 8. ALIENS AND NATIONALITY

CHAPTER 12. IMMIGRATION AND NATIONALITY
ADJUSTMENT AND CHANGE OF STATUS
MISCELLANEOUS

* GO TO CODE ARCHIVE DIRECTORY FOR THIS JURISDICTION

8 USCS § 1372 (2003)

§ 1372. Program to collect information relating to nonimmigrant foreign students and other
exchange program participants

(a) In general.
(1) Program. The Attorney General, in consultation with the Secretary of State and the
Secretary of Education, shall develop and conduct a program to collect from approved
institutions of higher education, other approved educational institutions, and designated
exchange visitor programs in the United States the information described in subsection (c)
with respect to aliens who--
(A) have the status, or are applying for the status, of nonimmigrants under
subparagraph (F), (J), or (M) of section 101(a)(15) of the Immigration and Nationality Act [8
USCS § 1101(a)(15)(F). (J), or (M)]; and
(B) are nationals of the countries designated under subsection (b).
(2) Deadline. The program shall commence not later than January 1, 1998.
(3) Aliens for whom a visa is required. The Attorney General, in consultation with the
Secretary of State, shall establish an electronic means to monitor and verify--
(A) the issuance of documentation of acceptance of a foreign student by an approved
institution of higher education or other approved educational institution, or of an exchange
visitor program participant by a designated exchange visitor program;
(B) the transmittal of the documentation referred to in subparagraph (A) to the
Department of State for use by the Bureau of Consular Affairs;
(C) the issuance of a visa to a foreign student or an exchange visitor program
participant;
(D) the admission into the United States of the foreign student or exchange visitor
program participant;
(E) the notification to an approved institution of higher education, other approved
educational institution, or exchange visitor program sponsor that the foreign student or
exchange visitor participant has been admitted into the United States;

http://www.lexis.com/research/retrieve?_m=e3dle926808819786e617865d918a250&docn... 1/22/2004
 H. JM W r u , -".

HWUhii •. :.BLF. Niuih O.iruku,

LAM.- .. ...;.«ri.. I.:,** ONE HUNDHLO SEVENTH CONGRFSS
'
' V".,.....i

Congress of the Hnited;

'

House of Representation
COMMITTEE ON THE JUDICIARY
HOUSE Ortict
WASHINGTON. DC 20515-6216
(202) 225-3951

October 9, 2001

MEMORANDUM

TO: Members, Subcommittee on Immigration and Claims

FROM: Keith Ausbrook, Chief Counsel for Oversight and Investigations

Brian Zimmer, Senior Investigator /I' •:

RE. Subcommittee Oversight Hearing on INS Information Technology

Chairman Gekas has scheduled an oversight hearing on the Immigration and

Naturalization Service's (INS) use of information technology in enforcement for October 11th, at
10;00 a.m. in Room 2141 of the Raybum House Office Building.

Purpose of the Hearing

The purpose of this hearing is to review INS implementation of the information

technology systems that it uses for enforcement. The hearing will examine INS's performance in
managing large new investments in information technology, including the $111 million for new
investment proposed in the FY2002 INS appropriation bill.

The hearing will also provide Members with an opportunity to evaluate the agency's lack
of progress in implementing specific automated systems, such as the automated element of the
biometric Border Crossing Card (to permit scanning of border crossing documents for
verification of biometric information and prevent duplicate admissions on a single card) and the
Student and Exchange Visitor Information System (SEVIS) (to track foreign students enrolled in
American colleges and universities). Although these systems were required by statute to be
implemented, INS has failed to do so, raising serious questions about the INS's capacity to
secure the Nation's borders according to Congressional mandates.
 /
<? o

/;
/
 U.S. Department o
Immigration and Nai on Service

Office of the Commissioner 425 Eye Street N. W.

Washington, D.C. 20536

MAY I I (995
EXECUTIVE SUMMARY
TO: THE DEPUTY ATTORNEY GENERAL
FROM: THE COMMISSIONER
IMMIGRATION AND NATURALIZATION SERVICE
SUBJECT: Immigration Controls on Foreign Students
PURPOSE: To provide information regarding the current process of
admission and control of foreign students in the United
States.
TIMETABLE: Information due to DAG May 11, 1995.
DISCUSSION: I have directed that responsible managers and staff
within the agency initiate a top-down review of the current process
of scrutinizing, admitting, and monitoring foreign students in the
United States, assessing risks and vulnerabilities relative to
issues of security, and to specify the resources and requirements
for a tight and effective process for controlling, monitoring and
tracking foreign students. The team, comprised of representatives
from the Service, Enforcement, and Information Resource Management
components from INS headquarters and field offices will conduct the
top-down review and make recommendations for improvement and
action. The team will also consult with the appropriate components
of the Federal Bureau of Investigation, the U.S. Information
Agency, and the Department of State, to solicit their detailed and
comprehensive views and comments on tightening foreign student
controls.
RECOMMENDATION: No action is recommended. This transmittal is
informational.

APPROVE Concurring components:

None
DISAPPROVE Nonconcurring components :
None

OTHER
 United States Department of State

Washington, D.C. 20520

May 17, 2000

TO WHOM IT MAY CONCERN:

I have had the pleasure of working with Morrie Berez

over an extended period of time during my two-year tenure
as Director, Office of Field Support and Liaison, in the
Bureau of Consular Affairs' Visa Directorate. Professional
and results-oriented, Mr. Berez is one of the most
effective inter-agency players with whom I've worked in
twenty years of Foreign Service experience. He is a
natural leader particularly adept at managing complex
policy and procedural issues. As demonstrated below, Morrie
brings a wealth of expertise to any job.

Mr. Berez and I worked closely together on CIPRIS

(Coordinated Interagency Partnership Regulating
International Students), the congressionally-mandated
automated system for tracking foreign students and exchange
visitors. This was a massive undertaking requiring
effective coordination of different parts of INS, State,
the former USIA, the Department of Education, and US
learning institutions. I was continually impressed by
Morrie's skilled leadership of this process. His strategic
planning and abilities in leading the development, design
and pilot test implementation, and for setting the course
for development of the national CIFRI3 pro-gran; demonstrated,
a broad understanding of both INS's and other agencies'
missions and business processes.

Mr. Berez' professionalism, technical expertise, and

enthusiasm for his work helped build the alliances needed
to make progress on CIPRIS. He was a catalyst for positive
change within the INS-led interagency Task Force on CIPRIS.
His vision was tc create a multi-faceted program that would
use today's technologies to leverage collective resources,
enhance border security, and provide good ciistomer service.
A CIPRIS strategy paper prepared by Morrie clearly
demonstrated his abilicy to balance competing goals such as
 U. S. Department of Justice

Office of Investigative Agency Policies

Washington, D.C. 20530

September 26, 1994

MEMORANDUM
TO: Jamie S. Gorelick
Deputy Attorney General
FROM: Louis J. Freeh, Director
Office of Investigative Agency Policies

At your request, the Office of Investigative Agency Policies

("OIAP") has considered "current procedures, policies and
practices relating to aliens' entry into and departure from the
United States," and addressed ways "to improve the Department's
law enforcement capabilities in these areas." In making this
request, you noted the participation of aliens in two heinous
crimes: the World Trade Center bombing and the killings outside
of the Central Intelligence Agency Headquarters.
After consulting with the members of the OIAP's Executive
Advisory Board ("EAB"),1 I make the recommendations contained
herein. AThe recommendations, if fully implemented, would require
an infusion of funds and personnel.

Visa Applications

The members of the EAB stressed the need for coordination

and cooperation in determining whether the United States
Government should issue a visa to an alien. In this regard, it
was noted that, when agencies provide information to the State,
Department which suggest that a visa should not be issued, the'
State Department should not specify the reason for the visa's
denial. Such information often results from criminal
investigations and, thus, its disclosure could jeopardize them.
Accordingly, the EAB recommends, and I endorse, the establishment
of a uniform system for the State Department's communication of
visa denials.

'The EAB consists of representatives from the Drug

Enforcement Administration ("DBA"), United States Marshals
Service ("USMS"), Immigration and Naturalization Service ("INS"),
Federal Bureau of Investigation ("FBI"), and the Department of
Justice's Criminal Division.
 HQ214f-C

Status Report on the Foreign

Student Controls Task Force
SEP 2 6 1995

Amy D. Jeffress Office of the 'Deputy

Special Assistant to the Commissioner
Deputy Attorney General Immigration and
Naturalization Service

Attached is the status report responding to your September 7

request for information on the progress to date and plans of our
task force on foreign student controls.
Please do not hesitate to contact me if you need further
information.

Chris Sale
Deputy Ccmmiss-u ner
Attachment
 STATUS REPORT OF THE FOREIGN STUDENT CONTROLS TASK FORCE

Jtem l: Has the INS specifically addressed the concern about the
need for more thorough scrutiny and control of foreign students
expressed in a September 26, 1994 memorandum to the Deputy Attorney
General (DAG) from Louis Freeh, Director of the Office of
Investigative Agency Policies (OIAP)?
• Yes. Addressing OIAP Director Freeh's concern has been a
primary aim of the review. We have fully coordinated this Task
Force effort with the Office of Enforcement. Also, Senior
Special Agents from both the Intelligence and the
Investigations divisions are active members of the Task Force.
• A major recommendation of the Task Force is to transform the
foreign student administration process from one of rare
contact via adjudication to one of Information Technology-
based registration, monitoring, tracking and control through
mandatory event-based notification. At present, foreign
students in the U.S. are not subject to any process of
continuing scrutiny, tracking, or monitoring, and schools are
not required to notify INS when students depart, drop out,
transfer, or violate their status. There is no system or
process for reporting or maintaining current addresses of
students. Currently, it is only at the point of adjudication
for employment related student benefits, reinstatement (at .the
student's initiative), or granting of a change of status to
student that a nonimmigrant student contact with the Service
may occur.
• The Task Force's major recommendation at this preliminary
point of its effort is that all foreign students be subject to
a mandatory ADP-supported registration process upon admission
to the U.S., and that INS institute "event-based" notification
(i.e., timely notification by the schools to INS) for such
things as no-shows, violation of status, academic probation,
arrest by campus or local police (if known), graduation,
transfer out/in, and the like). Another key recommendation is
that the direct mail process at the Service Centers ensure
improved scrutiny via lookout checks on nonimmigrants applying
for a change to (or extension of) student status, seeking
reinstatement to status, and other benefits.
• The Task Force Coordinator recently briefed the INS
representative to the OIAP on the focus and initial draft
recommendations of the Task Force regarding ADP supported
registration, tracking and monitoring, the process of
mandatory "event-based" notification by schools, and effective
lookout checks by the Service Centers incident to
adjudications via direct mail. The INS' OIAP representative,
 J

it
 Memorandum

HQ 70/6.2.6

Subject Receipt of Final Report of Date

the Task Force on Foreign
Student Controls '01 M 1995

To From
Chris Sale Michael L. Aytes
Deputy Commissioner HQADN

Through: T. Alexander Aleinikoff

Executive Associate Commissioner for Programs
\Jb^ l-i/l 13 far
Through: Louis -D. Crocetti, Jr.
Associate Commissioner for Examinations

We have received the formal memorandum transmitting the final

report of the Task Force on Foreign Student Controls. The report
is comprehensive in scope, and it contains far reaching
recommendations for major program and data system changes, as well
as inter-agency coordination concerns. The Task Force report must
be given full and' serious consideration by cognizant program
officials in light of the major changes proposed.

Although we are forwarding the package to your office in accordance

with the December 29 delivery deadline for the report, we must
have time to study and consider the major programmatic and resource
implications presented in the Task Force's ambitious reinvention
proposals. We are committed to making the necessary determinations
and management decisions by January 31, 1996 with respect to the
issues addressed by the Task Force.

We are aware that Amy D. Jeffress,. Special Assistant to the Deputy

Attorney General, has requested regular progress reports on the
Task Force effort, and we expect that she most likely will want a
copy of the Task Force report in the near future. Should you
forward the report to the Deputy Attorney General's Office, please
advise . them that the responsible program officials are now
considering the report recommendations with the aim of initiating"
a formal reinvention initiative to address the issue of foreign
student controls.

Form G-2
 Memorandum

HQ 70/6.2.6

Subject Date
Formal Report of the Task
Force On Foreign Student Controls
DEC 2 2 1995

To From
Michael L. Aytes Task Force on
Acting Assistant Commissioner Foreign Student
HQADN Controls

Through: vonne M. Lafleur

:hief, Nonimmigrant Branch
HQADN

I am pleased to transmit the formal report prepared by the Task

Force on Foreign Student Controls. The Task Force conducted a
comprehensive review and analysis of current controls over foreign
students in the United States. Based on its review, the Task Force
determined how to strengthen the process of scrutinizing,
monitoring and controlling foreign students to effectively address
concerns regarding weak foreign student controls which were raised
by the Director, Office of Investigative Agency Policies. The Task
Force hopes that its report may serve as the blueprint to guide the
Service in re-engineering the student and schools control process.

Addressing the OIAP Director's concerns has been a primary aim of

the Task Force effort, and the Task Force has kept the Service's
representative to the OIAP apprised of its findings and progress.
The Task Force was comprised of the following individuals.

Immigration and Naturalization Service (INS) members: Maurice

Berez, Coordinator, Senior Adjudications Officer,
Adjudications Division; Clair Seglem, Assistant Chief
Immigration Inspector, Inspections Division; Linda Loveless,
Assistant Chief Inspector, Inspections Division; Mark McGraw,
Senior Special Agent, Investigations Division; Albert
Diplacidi, Senior Special Agent, Intelligence Division;
William McNamee, Senior Adjudications Officer, Office of Field
Operations; Paul Arthur, Senior Computer Specialist, Data
Systems Division; Kurt Andolsun,. Senior Computer Specialist,
Data Systems- Division; Kathleen Sheeran, . District
Adjudications Officer, Miami .district; Bruce Gawtry, Special
Operations Immigration Inspector, St.Paul district; Lauren
Mack, District Adjudications Officer, San Diego district/-

G-2
{Rev. 1-2-80)
 U.S. Department of Justice

Immigration and Naturalization Service

425 Eye Street N. W.

Washington, D.C. 20536

DEC I 0 1998

MEMORANDUM FOR THE DEPUTY COMMISSIONER

THROUGH: EXECUTIVE ASSOCIATE COMMISSIONER FOR

POLICY AND PLANNING

FROM: Maurice R. Berez

CIPRIS Project Lead

SUBJECT: Coordinated Interagency Partnership Regulating International

Students (CIPRISX

PURPOSE: To provide background for the Deputy's briefing on CIPRIS

scheduled for Monday, December 14 at 11 AM.

TIMETABLE: CIPRIS is required by law to be initially deployed and operational

in five countries by January 1, 2002. Full deployment in all
countries is required by January 1, 2003.

SYNOPSIS: Background

1. In 1995, the INS convened a Task Force to review the process

by which F,M, and J aliens are admitted into the United States.
The task force recommended the development and pilot test of
a reengineered business process and system to be followed by
development and implementation of reengineered systems and
business process covering students and exchange visitors.

2. On September 30, 1996, Nine months after the Task Force

Report, Pub.L 104-208 (IIRIRA) was enacted. Section 641 of
IIRIRA requires that INS, in consultation with the U.S.
Information Agency (USIA), Department of State (DOS), and
Department of Education (DoEd), establish a program for
monitoring and reporting on foreign students and exchange
visitors from schools and exchange programs. The statute also
requires the process to be electronic wherever feasible.
 CONTROLS GOVERNING FOREIGN
STUDENTS: and Schools That Admit Them

Final Report by the Task Force

on Foreign Student Controls

U.S. Immigration t<:Hd Naturalization Service

December 22,1995
w
December 1999
RESEARCH NOTES
1828 L Street NW, Suite 1050, Washington, DC 20036 • Phone (202) 452-0650 • Fax (202) 223-5364 • Internet: wwwwashingtoninstitute.org

Tracking Students from Terrorism-Supporting

Number 9

Middle Eastern Countries: An Update

Benjamin Orbach
Foreign students and scholars contribute greatly to U.S. higher education. Yet, a very small number have exploited the
student visa process either to commit acts of terrorism (such as the World Trade Center bombing) or to pursue studies that
directly benefit their countries' pursuit of weapons of mass destruction (WMD).'
This phenomenon can be explained, in part, by the U.S. government's lack of an effective system for monitoring and
tracking students, exchange visitors, and scholars from terrorism-supporting countries.2 The 1996 Illegal Immigration
Reform and Immigrant Responsibility Act (IIRA/IRA) mandates that such a program be developed and implemented by
January 1, 2003. But until an appropriate electronic tracking system is implemented—and it is unlikely that a national
system will be in place before 2003—the U.S. government will lack comprehensive data describing what students from
terrorism-supporting countries study, where they study, and who pays for their studies. For at least three more years, this
problem will continue, virtually unchecked.

Background issued 9,767 visas to students of TSMECs between

In September 1997, The Washington Institute pub-
lished Open Admissions: U.S. Policy Toward Students from
Terrorism-Supporting Countries in the Middle East, by
Hillary Mann (Policy Focus no. 34). Open Admissions
focused on the difficulties the United States" has in
tracking and monitoring students from terrorism-sup-
porting Middle Eastern countries (TSMECs) in U.S.
colleges, universities, and other advanced academic
programs. Specifically, Mann analyzed the trends of
study and sources of funding for students from Iran,
Iraq, Libya, Syria, and Sudan—countries on the U.S.
Department of State's list of "state sponsors of terror-
ism." Her research revealed that the United States
For instance, a key scientist in Iraq's nuclear weapons pro-
gram earned a doctorate in nuclear engineering at Michigan
State University, and three Iranian scientists involved in de-
veloping the Iranian nuclear program also studied in the
United States. See Hillary Mann, Open Admissions: U.S. Policy
Toward Students from Terrorism-Supporting Countries in the Middle
East, Policy Focus no. 34 (Washington: The Washington In-
stitute for Near East Policy, 1997), p. 1.
Most students are in the Fl visa class; scholars and exchange
visitors,Jl; and nonacademic (vocational) students, Ml.The
term "student" will apply generally to all foreign students,
exchange visitors, scholars, and nonacademic students study-
ing in the United States on Fl, Jl, or Ml visas.
1991 and 1996. Mann's research also brought to light
the fact that a high number of these students study
subjects that could help their respective countries to
develop programs of biological, chemical, and
nuclear weapons and ballistic missiles.
To address the problem, Mann recommended the
following:3
• Tightening security procedures, including apply-
ing the most comprehensive background check
available to all students and visitors from TSMECs.
• Denying entry to any student from a TSMEC who
intends to study a subject that could aid in the
production of chemical, biological, or nuclear
weaponry or missile technology.
• Refusing visas to individuals whose studies are fi-
nanced by the governments of Iran, Syria, or
Sudan. This is already the practice in the cases of
students from Iraq and Libya.
• Implementing and expanding the Immigration
and Naturalization Service (INS) pilot program
that would screen and monitor foreign students
(as well as their spouses and children) from the
3. Mann, Open Admissions, pp. 9-10.

The opinions expresst J herein are solely those of the authors and should not be construed as representing
those of The Washington Institute for Near East Policy, its Board of Trustees, or its Board of Advisors.
 A database of current international
student and EV information.
& A database of easily shared data.
**

**
A tool to monitor and track F, M, and
J non-immigrants.
A tool that can recognize, predict and
report trends and anomalies.
 OFFICIAL JAN 8 1997

BILLING CODE: 4410-10

DEPARTMENT OF JUSTICE

Immigration and Naturalization Service

[INS No. 1800-96]

Request For Volunteers to Participate in a Foreign

Student/Exchange Visitor Program Pilot

AGENCY: Immigration and Naturalization Service, Justice.

ACTION: Notice.

SUMMARY: The Immigration and Naturalization Service (INS),

consistent with its statutory authority to regulate foreign

students and exchange visitors under sections 101(a)(15)(F),

(J) and (M) of the Immigration and Nationality Act as amended

(the Act), and in consultation with the United States

Information Agency (USIA), the Department of State (DOS), and

the Department of Education (DoE), is initiating a pilot

program (hereinafter referred to as "the pilot") for the

1997/1998 academic year, commencing with the 1997 fall

semester, to redesign and improve the collection and reporting

of information regarding foreign students and exchange

visitors as required under Subtitle D, section 641, of the