Nicholas Arrindell (pictured at right), director of the Office of International Student and Scholar Services at Homewood, is no marksman, but he now knows what it's like to hit a moving target.
For the past year, Arrindell has been a member of a task force, made up of 13 representatives from various departments at Hopkins institutions, that has been responsible for implementing policies and procedures for the university to be in compliance with the Immigration Reform and Immigrant Responsibility Act of 1996.
The act, which went into effect on Jan. 1, 1998, places increased responsibilities on institutions such as Hopkins to track foreigners associated with them and imposes severe sanctions on those who do not comply with the legislation. The law was passed in response to the growing concern about illegal immigration, illegal workers and the threat of terrorism.
To date, the task force has implemented some procedural changes required of them by law, drafted a list of 19 recommendations for the university to be in compliance with the act and thoroughly examined the university's current tracking and services system for its roughly 3,300 international students, scholars and staff. The Planning Task Force on the Immigration Reform and Responsibility Act of 1996, chaired its first year by Edgar Roulhac, vice provost for academic services, was established in May 1997 by Provost Steven Knapp to coordinate all those who hire, enroll and track the presence of non-U.S. citizens.
However, many of the deadlines imposed by Immigration and Naturalization Services, the federal agency responsible for the act's implementation, have come and gone without INS delivering necessary materials. For instance, by the beginning of this year the university was to receive new I-9 guidelines and forms, but to date this material has not arrived. The I-9 document is one that establishes the identity of any person, foreign or citizen, working in the United States. Arrindell also says that some of the regulations, such as fingerprinting all foreigners, have been temporarily abandoned.
Yet the trick, says Arrindell, who on Jan. 1 will assume the chairmanship of the standing task force, is for Hopkins to be ready for any eventuality in regard to the new laws.
"The beauty of this task force thus far is that it has positioned this institution where it needs to be. We now know what our weaknesses are, and we know at this point how to close those gaps. We also know if the government decides that some regulation is too cumbersome, that is fine, too," Arrindell says. "We are doing whatever we can do to protect this institution from being penalized. But we are ready to go. If they ask us for a change tomorrow morning, we can move."
The penalties to which Arrindell refers constitute the major impact on institutions such as Hopkins. For example, if an international visitor to Hopkins doesn't have the correct documents at the port of entry, he or she can be refused admission into the country and be barred from entering for a period of time. Or if a visiting researcher has a work visa valid for two years but stays more than 180 days past expiration without renewing the visa, he, too, can be barred from entering the country for a period of time.
Murray Welsh, a task force member representing JHMI, says that although such occurrences would likely be rare, the repercussions of losing one particular person can be devastating to a research project.
"The researcher might be the only person with training in that specific area; he is essential to that project's success," says Welsh, manager of the Office of International Student, Faculty and Staff Services at the School of Medicine.
Also, the government can revoke federal grants and contracts if the university knowingly fails to follow regulations.
"We stand to lose millions," Arrindell says.
"If we allow [our international population] to engage in activities they are not allowed to do, we are placed in a situation of great risk. Just like that, you could lose all your key researchers and grants. That is certainly a motivation to get it right," Welsh says. "If the university's goal is to reduce its risk and liability, we need to look at this population very carefully. It's just good business."
To that end, one of the safeguards already in place is to identify foreign visitors whose work eligibility is going to terminate. University Payroll will send a letter 90 days prior to termination to notify the individual of the upcoming deadline. If the person intends to stay, he or she then must contact the international office and make certain the paperwork is being advanced. If the person misses the deadline, he or she will automatically be taken off payroll. And if he or she stays a certain number of days after the deadline, other penalties will be involved.
The university is being required to keep in a centralized database full and up-to-date records on every international student, staff, faculty member and visitor. However, the official date for the database's implementation has been pushed back as the university is still waiting for the CIPRIS software program that will allow the school to transmit data to the INS.
Arrindell says that under the new INS tracking system, foreign visitors will receive a card with a coded bar sequence upon their arrival in the United States.
"Everything about this person's eligibility can be accessed with just a swipe of the card," Arrindell says. "Information we provide will be automatically input into the database and forwarded to the INS. If that person has changed majors, fallen below full-time status or registered for school but not shown up, that information will be transmitted to INS." Arrindell says that a person can be stopped if he or she tries to leave or re-enter the country.
To educate all departments' administrative assistants about these changes, the task force has recently finished a handbook that includes common terms of immigration policies, locations of the university's various international offices and procedures that need to be followed.
"It gives everybody a heads-up in terms of what to do in a what if' situation, such as what they should do if they have a visiting scholar coming in tomorrow morning," says Arrindell.
Hopkins also will begin in January an institution-wide pilot training program that will walk people through the handbook and get them caught up with all the changes in immigration law.
Not all divisions are finding it necessary to make broad changes, however.
"For the moment we haven't made any changes," says Betty Beauchamp, registrar and foreign services administrator at SAIS. "We are either already doing it, or the changes don't apply to us."
Janice Shannon, international student adviser at Peabody, says the only major change for her is that she has moved into a new suite and hired a receptionist to accommodate the increased number of students and faculty who have questions about the new laws and their status.
At Homewood, however, Arrindell says it's been a very busy year. Having to track foreign visitors more closely, he says, changes the role of those who work in international offices.
"It has changed what we do drastically," Arrindell says. "I have dual responsibilities now.
"A good portion of our role before was to advise, but now we are part of the system. If someone has changed his status or is not in compliance, we are not going to call the van to pick him up, but we do have to report it."