COMPLIANCE • ISSS OPERATIONS • PART 2 OF 2

The 60-Day Clock: 7 Things Every ISSS Office Should Do Before the Rule Takes Effect

DHS's final rule to end Duration of Status has cleared White House review and is awaiting Federal Register publication. Once it appears, the rule is expected to take effect 60 days later. That's your prep window — and you don't need to wait for the public text to start using it.

In Part 1 of this series, we covered what NAFSA's latest tracking confirmed: OMB/OIRA completed review of the final rule on June 17, 2026, with the status “Consistent with Change.” That means the rule is on the runway, but the final public text may differ from the August 2025 proposal — and schools should be careful about treating every proposed detail as final until it's published.

Here's the good news. The operational habits that will protect your students under a fixed-admission framework are the same habits that make your office stronger today. You can start the work now, while the rule is pending publication, and avoid scrambling once the 60-day effective date starts running.

This is the punch list we've been talking through with ISSS leaders this spring and summer.

Step 01

Audit student timelines against the four-year mark

Pull a list of currently enrolled F-1 and J-1 students. How many have already exceeded four academic years? How many will by next May? That number is your baseline exposure under a fixed-admission framework — and it's almost certainly larger than your team expects, especially if you support nursing, PhD, dual-degree, MBA, contact-hour, or medical school programs.

Once you have the number, sort by program and by academic standing. Students with delays from probation, retakes, or major changes may have a harder time qualifying for an extension under the proposed framework, so flag them separately for academic advising follow-up.

Step 02

Run an OPT and STEM OPT pipeline review

OPT timing is going to be the conversation that defines this fall. Under a fixed-admission framework, the connection between employment authorization timing and the student's underlying period of admission becomes much more important. For students currently in or approaching the post-completion grace period, separate them into three buckets: OPT approved and clean (lowest exposure), OPT pending with a short runway (medium exposure), and OPT not yet filed (highest exposure).

The shorter grace period in the proposal means students need to file earlier than they're used to. Build the advising script now — what students should know, when they should file, and what happens if their employment authorization timeline runs past their admission period.

Step 03

Map your SEVIS-to-SIS data flow

If your platform doesn't pull degree progress, enrollment status, and admit-until dates from your SIS in real time, you don't have a way to flag students approaching their four-year cap. You need that visibility before extension volume hits.

The test is simple: can you produce, in under five minutes, a list of every active F-1 and J-1 student with their admit-until date, expected completion date, and current academic standing? If the answer is “no, that takes a week,” your tooling is the bottleneck.

Step 04

Forecast extension volume against the USCIS backlog — not your team's capacity

This is the assumption most offices get wrong. Your team will not be the binding constraint. USCIS adjudication time will be. USCIS is already managing historically high backlogs, and a new population of F, J, and I extension filings would add cases to an already strained environment.

Build your forecast around USCIS processing windows, then layer in your own throughput. Identify the students whose extensions would need to be filed earliest to land before peak congestion — and start documenting their files now so you're not scrambling later.

Step 05

Move your workflows to admit-until, not program end date

Under a fixed-admission framework, admit-until becomes the field that drives I-20 issuance, extension triggers, and grace period calculations. Today, most ISSS workflows are anchored to program end date. The day the rule takes effect, those automations stop being reliable.

Update your alerts, reports, and student communications now to key off admit-until. If your platform supports it, configure automations against the admit-until field directly. This is a small change that protects against a much larger compliance gap — and it costs you almost nothing to do today.

Your team will not be the binding constraint. USCIS adjudication time will be.

Step 06

Build a student and advisor communication plan

Students need to understand what may change: the shorter grace period, the OPT and STEM OPT timing trade-offs, the then-current USCIS filing fee for any extension, and what an extension application actually involves. Faculty and academic advisors need to understand what may count as a valid reason for an extension under the new framework — and what won't.

Get ahead of the FAQ. Draft a one-page student explainer now, get it through legal review, and have it ready to publish the day the rule appears in the Federal Register. The same applies to internal training for advisors, registrars, and the financial aid office.

Step 07

Stress-test your tooling — and identify any gaps before publication

If your current platform can't sync with SEVIS and SIS, can't alert on a four-year cap, or can't model an extension workflow that mirrors a USCIS-driven filing, you have a tooling gap, not a process gap. Identify it now, while the rule is still pending publication, not in the fall when your queue is full.

The schools that come out of this in good shape will be the ones that consolidated onto a platform built for this regulatory environment, not one that's been retrofitted. Buying time before the 60-day clock starts is the cheapest move you can make.

Start with the cheapest moves

If your office is stretched thin (and whose isn't), the highest-leverage starting points are Steps 1, 2, and 5 — the timeline audit, the OPT pipeline review, and moving workflows to admit-until. Those three give you the most visibility for the least effort, and they pay off whether the rule takes effect in late summer, fall, or early next year.

Steps 3, 4, and 7 are where Via International can do the heaviest lifting. Our platform was designed by former ISSS professionals around exactly this kind of regulatory pressure — SEVIS and SIS integration in real time, admit-until automations available today, and a roadmap built to absorb whatever the final EOS workflow ends up looking like once the rule is published.

Read the full white paper for context on the rule: Facing the Four-Year Wall →

Or see how Via International handles each of these steps in practice: Book a walkthrough with a former PDSO →

Missed Part 1?
Read “The Four-Year Wall Is No Longer Theoretical: What NAFSA's Latest Tracking Shows.”

Sources: U.S. Federal Register, August 28, 2025 (Document 2025-16554); OMB/OIRA review completion, June 17, 2026; NAFSA tracking, June 2026.