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发帖数: 492 | 1 ----- DHS requests public comment and the submission of empirical data in
relation to this proposition. In addition, DHS requests public comment
regarding the length of research, development, testing and other projects
for which STEM graduates (regardless of nationality) from U.S. universities
are typically assigned in the workplace。
----- DHS requests public comment on the proposed 24-month STEM OPT
extension and the ability for qualifying students to receive an additional
such STEM OPT extension based on a second STEM degree. In particular, DHS
requests comment from STEM students, educational institutions, and employers
on the appropriate STEM OPT extension length to ensure that practical
training for STEM students is most meaningfully
educational and beneficial to them, and less disruptive for institutions and
employers.
----- DHS is particularly interested in public input regarding whether 24
months is the appropriate duration for STEM OPT extensions, or whether a
shorter or longer duration (e.g., 17 months or 36 months) is preferable, and
why.
----- DHS seeks comments on these and other options for addressing pending
applications if a final rule is not in place prior to the court’s vacatur,
including comments on the harm that such a gap may cause.
----- DHS welcomes comments regarding each of the proposed transition
procedures described above, including alternatives to the potential courses
of action identified here.
----- DHS requests comment from the public on the academic benefit of the
STEM OPT extension for STEM students generally as well as for specific STEM
fields. DHS also requests comment on whether changes to the current content
or structure of the list may be helpful or appropriate.
----- If the employer does not employ and has not recently
employed more than two similarly situated U.S. workers, the employer would
be required to ensure that the terms and conditions of a STEM practical
training opportunity are commensurate with those for similarly situated U.S.
workers in other employers of analogous size and industry and in the same
geographic area of employment. “Similarly situated U.S. workers” would
include U.S. workers performing similar duties and with
similar educational backgrounds, employment experience, levels of
responsibility, and skill sets as the STEM OPT student. The student’s
compensation would be reported on the Mentoring and Training Plan and the
student would be responsible for reporting any adjustments. DHS requests
public comment, especially from employers and labor organizations, on all
aspects of this provision, including the types of business factors employers
would use to evaluate whether their workers are similarly situated.
----- DHS requests comment on the feasibility and effectiveness of each of
these provisions, including the obligations to confirm (1) that the terms
and conditions of a STEM OPT student’s employment are commensurate with
those for similarly situated U.S. workers, and (2) that no U.S. worker will
be terminated, laid off, or furloughed as a result of a STEM OPT opportunity.
----- DHS requests comment from universities, DSOs, and other interested
members of the public on how DHS can most effectively ensure an appropriate
level of participation in this program by educational institutions.
----- DHS requests comment from the public on all aspects of this proposal,
including the feasibility and effectiveness of imposing a firm accreditation
requirement as a condition of participation in the STEM OPT extension.
----- DHS believes that removing unemployment limits would be inconsistent
with the agency’s role of overseeing and ensuring OPT program integrity.
DHS also believes that the proposed 150 days for students granted a STEM OPT
extension would provide additional flexibility when compared to the 120
days permitted under the current
program’s 17-month extension. With this change, DHS acknowledges the
concerns of commenters who described the challenges that international
students face in locating and obtaining training experiences in the United
States. DHS welcomes comments on this issue. |
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