Guidelines for Writing Government Comment Letters

Purpose of a Government Comment Letter

Federal agencies regularly solicit public input on proposed regulations, policy changes, or rulemakings that affect international students and scholars. A comment letter is a formal way for institutions, advocates, and individuals to shape those policies. By providing clear, evidencebased feedback, ISSS can help ensure that regulations support academic excellence, protect vulnerable populations, and align with U.S. diplomatic goals.

When to Submit a Comment

• During the official publiccomment period (usually 3060 days after a notice is published in the Federal Register).
• When a draft rule directly addresses visa issuance, SEVIS reporting, D/Jvisa employment authorizations, or research funding restrictions.
• When an agency proposes changes that could increase administrative burden on campuses or reduce student mobility.

Missing a comment deadline means the agency can proceed without your input, potentially locking in unfavorable language.

Preparation Steps

1. Identify the docket. Locate the Federal Register notice and note the docket number (e.g., 202412345).
2. Gather evidence. Compile enrollment data, economic impact studies, and case examples that illustrate the realworld effects of the proposed rule.
3. Coordinate internally. Involve the Office of the Vice President for Research, the International Office, and legal counsel to ensure consistency.
4. Draft an outline. Decide which sections of the proposed rule you will address, and prioritize the most consequential provisions.
5. Assign responsibilities. Designate a primary author, a reviewer, and a final approver.

Recommended Letter Structure

While agencies do not enforce a single format, the following layout is widely accepted:

1. Header Include your institutions name, address, docket number, and date.
2. Salutation Address the specific agency or rulemaking officer (e.g., Dear Chairperson, Office of Immigration and Customs Enforcement).
3. Opening paragraph State who you are, your affiliation, and the purpose of the comment.
4. Summary of position Provide a concise statement (one sentence) of your overall stance (support, oppose, or suggest modification).
5. Detailed comments Use numbered paragraphs that correspond to the sections of the proposed rule. For each point:
   • Quote the exact language you are commenting on.
   • Explain why the language is problematic or beneficial.
   • Offer specific alternative wording or policy suggestions.
   • Support your argument with data, citations, or anecdotal evidence.
6. Impact statement Quantify how the proposed rule would affect enrollment, employment, research funding, or campus operations.
7. Conclusion Restate your main request and thank the agency for the opportunity to comment.
8. Signature block Include the name, title, and contact information of the signatory.

Tone and Style Guidelines

• Professional and courteous. Even if you strongly disagree, avoid confrontational language.
• Clear and concise. Aim for 12 pages (500800 words) unless the rule is extremely complex.
• Evidencebased. Cite reputable sources (e.g., ICE data, Institute of International Education reports, peerreviewed research).
• Nonpartisan. Focus on the policy implications rather than political ideology.
• Consistent terminology. Use the same terms as the proposed rule (e.g., F1 student, J1 scholar) to avoid confusion.

Submission Process

Most agencies accept comments via:

• Online portal. Usually the Regulations.gov website. Upload the letter as a PDF and enter your contact information.
• Email. Some agencies provide a dedicated comment email address; keep a copy of the sent message.
• Mail. If you prefer hard copy, send the signed letter via USPS with the docket number on the envelope.

After submission, you will receive a confirmation number. Retain this number for future reference or if you need to submit additional comments.

Helpful Resources

• U.S. Department of State Student Exchange Programs
• U.S. Immigration and Customs Enforcement SEVIS Guidance
• Institute of International Education Open Doors Report
• Legal Reference USCIS Policy Manual
• Comment Writing Workshop PDF guide available from the National Association of International Educators (NAFSA).