USCIS Alien Registration Explained: What it Means for Exchange Students

Since the beginning of the second Trump administration, there has been growing confusion within the exchange community surrounding recent developments related to the Alien Registration Requirement and their potential implications for exchange participants. While these requirements do not apply to the majority of international students or exchange visitors, and no additional registration is necessary for individuals in these categories, it remains important to understand what they entail. Below is more information on what the Alien Registration Requirement is and to whom it applies. 

Background

On Inauguration Day, one of President Trump's first Executive Orders (EOs) instructed the Department of Homeland Security to enforce Section 262 of the Immigration and Nationality Act (INA), also known as The Alien Registration Act of 1940. This longstanding provision requires all foreign nationals aged 14 and older who reside in the U.S. for more than 30 days to register and be fingerprinted—unless they have already completed this step during their visa application process. 

Following this EO, U.S. Citizenship and Immigration Services (USCIS) published a page on their website outlining the details of the Alien Registration Requirement, sharing which individuals must register or re-register with the Federal government and how they can do so. USCIS also published an Interim Final Rule effective April 11, 2025 that requires nonimmigrants who turn 14 while in the U.S. to re-register within 30 days of their birthday, even if they were previously registered and issued an I-94 Form when entering the country. 

Impact

These updates have sparked questions about what this means for international students and exchange visitors. The good news? Most won’t be affected—but here’s what you need to know about the Alien Registration Requirement and the new USCIS rule: 

Are there any new changes to the Alien Registration Requirement?

Yes, there are two key updates to the Alien Registration Requirement:  

• The new requirement for young foreign nationals to re-register once they turn 14 (codified in the Interim Final Rule); and, 

• Individuals who have not been registered in the past must now also register with the Federal government, including visa-exempt Canadian nationals who enter at land borders without an I-94 and stay 30+ days and foreign nationals who entered without inspection (EWI) and are in the U.S. 30+ days (i.e. those who crossed the border illegally) 

Do international students and exchange visitors need to register under this policy?

No, most nonimmigrants (including F-1s and J-1s) are already registered when they enter the United States. When an individual receives a visa, is inspected at a U.S. port of entry, and receives an I-94 Form, this automatically counts as their registration and will not require them to re-register under this DHS program. Generally, re-registration will not be required if the participant entered the U.S. at age 14 or older and they received an I-91 Form on entry. See “Who is already registered” section on the USCIS Alien Registration Requirement web page. 

Will the USCIS Interim Final Rule impact international students and exchange visitors?

This may affect J-2 dependents and any young F-1 and J-1 students who entered the U.S. prior to age 14 (e.g. boarding school students), but in most cases, no.  

The Department of State Memo That Leaked: Let’s Talk About the Budget Process

This week in Washington began abuzz, first with rumors and speculation about a damaging memo possibly coming from the Department of State, and then real alarm when The Washington Post published a piece about a memo that was leaked to them proposing to slash the agency’s funding by nearly half, including the elimination of the Bureau of Educational and Cultural Affairs (ECA). The coverage of this memo has been breathless and dire. We at the Alliance saw the full memo, and it is very concerning. 

What the press only mentions as a footnote, though, is this: the leaked memo is a step in the beginning of the very long process that exists to write, authorize, and appropriate the federal funding legislation. The memo in and of itself has no immediate or tangible impact on the Department of State, ECA, or Alliance members’ programs. Below is an overview of the long, arcane, and complex process that explains why this memo is nothing more than a memo right now.

“Regular Order”, a.k.a. the way things should be done and aren’t

The Congressional budget process was established under the Congressional Budget and Impoundment Control Act of 1974, and that process takes place after the President’s Budget Request (PBR) is submitted to Congress. Below is a chart that outlines what the “regular order” of the federal budget process should look like each year. 

On or before: Action to be completed:

October-December Federal agencies create budget requests and submit them to the White House Office of Management and Budget (OMB) OMB refers to the agencies’ requests as it develops the budget proposal for the president.

First Monday in February The president submits the budget request (PBR) to Congress.

February 15 Congressional Budget Office (CBO) submits report to House and Senate Budget Committees.

Within 6 weeks after the PBR is submitted Authorizing committees submit views and estimates to Budget Committees for each federal agency. House and Senate Budget Committees hold hearings on the PBR.

April 1 Senate Budget Committee reports concurrent resolution on the budget, which outlines targets for congressional committees to propose legislation directly appropriating funds or changing spending and tax laws. The budget resolution is not law and does not get signed by the President.

April 15 Congress completes action on the budget resolution, meaning the House and Senate agree on exact text language.

May – June House and Senate complete action on 12 appropriations bills guided by the targets outlined in the budget resolution. These bills do become law by going to the president for signature. Appropriations bills are the vehicle through which federal agencies receive funding.

October 1 Fiscal Year begins

Source: House Budget Committee: https://budget.house.gov/about/budget-framework/time-table-budget-process/; Center on Budget and Policy Priorities: https://www.cbpp.org/research/federal-budget/introduction-to-the-federal-budget-process  

Since the Congressional Budget Act of 1974 was passed, Congress was able to complete this process for the first 23 years, however since 1999, they have failed to complete it the majority of the time. As Congress become more polarized, agreement on any legislation, but especially appropriations, has become more difficult. In 42 of the last 45 years, Congress has failed to agree on and pass appropriations bills by the start of the fiscal years. [1] In these instances, Congress is forced to pass short-term stopgap funding in the form of a Continuing Resolution (CR), or they put all 12 appropriations bills into one giant omnibus legislation to fund the full government or risk a government shutdown (which has happened several times). As might be clear at this point: neither of these processes for funding the government that have become the norm are considered “regular order” per the Congressional Budget Act. 

What does the President’s Budget Request really mean?

What does all of this have to do with the leaked memo? The memo represents what seems like a draft for the first step in the above chart where federal agencies create budget requests to submit to OMB. However, there is a lot of uncertainty surrounding this memo, including whether it is in fact the Department of State’s actual budget request for FY26. Subsequent reporting has noted that the memo is not expected to “pass muster with either the department’s leadership or Congress”. [2]

The president’s budget request in any given year is simply an overview of an Administration’s priorities and values. Congress can take it, take portions of it, or take none of it as they work through their own process to appropriate and authorize the federal agencies and programs. More often than not, Congress goes against the PBR during their appropriations process. It’s important to remember that the previous Trump Administration’s proposed budgets for ECA were cuts of anywhere from 55-75%. These were all rejected by Congress and funding for exchanges ended up growing by 17% over those four years. While a funding increase for ECA is not expected, it’s important to take heart that Congress has the final say on funding the federal government. 

Because the appropriations process is so broken (often ending in an omnibus or Continuing Resolution), and the legislative filibuster still exists, bipartisan agreement, at least in the Senate, is required to pass any kind of legislation to fund the government. Additionally, the House ultimately has to agree with whatever the Senate passes for it to go to the president to become law. 

All of that is to say, bipartisan support continues to exist for the Department of State, for ECA, and for international exchange programs writ large. Terminating ECA and eliminating all exchange programs is very unlikely to get the bipartisan support required to become law.

 ______________________________________________________

[1] Center for Budget Policy and Priorities, https://www.cbpp.org/research/federal-budget/introduction-to-the-federal-budget-process

[2] PBS news, https://www.pbs.org/newshour/politics/watch-live-state-department-briefing-may-address-proposed-budget-cuts-el-salvador-deportations

Exchanges Aren’t Going Anywhere: Leaked State Department Memo and What It Means for Exchanges

On Monday, April 14, The Washington Post broke the news that a leaked internal Administration memo proposed cutting the State Department by 48% and eliminating the Bureau of Educational and Cultural Affairs (ECA) and its exchange programs. 

While the memo is concerning and must be taken seriously, context is key: the memo is a proposal of a potential proposal and doesn’t mean the imminent elimination of ECA and exchange programs. 

This memo is a part of an annual process for creating the President’s Budget Request, or PBR. The memo is the State Department’s response to the Office of Management and Budget’s (OMB) request for input on funding levels as it creates the PBR for FY26. And ultimately, it’s Congress that determines final funding numbers. If you’re interested in learning more about this process, I highly encourage you to read Alliance Assistant Director and Head of Advocacy and Government Relations Adrienne Jacobs' excellent analysis here.  

Exchange programs aren’t going anywhere, not if we have anything to say about it. We at the Alliance, along with our members, supporters, and partners, are working tirelessly to promote and protect international exchange programs. For those interested in staying up to date on the latest policy news and advocacy opportunities, visit our 47th Presidential Administration webpage. 

Action Alert: Tell Congress International Students are Essential to America’s Safety, Economy, and Global Strength

The U.S. for Success Coalition, of which the Alliance is a founding member, is calling on Congress to press the administration to avoid immigration actions and travel restrictions that jeopardize America’s global strength in attracting the world’s best and brightest to U.S. colleges and universities. Advocates can take up this call to action by reaching out to their members of Congress with the message that the administration should make it a national priority to welcome international students and scholars to study and succeed in the U.S.

Advocacy Update: Exchange Funding Begins to Flow After Pause

As of Friday, March 28, Alliance members have received over 85% of outstanding State Department payments that had been withheld due to the ongoing funding freeze. This is a major victory in an advocacy effort that began when on Thursday, February 13 when the State Department informed grantees that a temporary 15-day pause on federal funding for all current and future State Department FY25 grant disbursements had gone into effect as of Wednesday, February 12.

In response, the Alliance, along with NAFSA and The Forum on Education Abroad, launched an advocacy campaign urging Congress to restore funding to ECA program implementers. Exchange champions sent 25,000+ letters to more than 500 Congressional offices. 

Just days after the campaign launch, 160 Alliance members went to Capitol Hill to meet with over 140 Congressional offices on Advocacy Day, delivering the same urgent message.

These meetings led to a House sign on letter co-sponsored by Rep. Chellie Pingree (D-ME, 1) and Rep. Madeleine Dean (D-PA, 4) with 47 signatures urging Secretary of State Rubio to immediately stop the freeze.

We also generated strong media attention in major outlets like the New York Times, the Washington Post, and the Associated Press.  

Action Alert: Urge Congress to Restore Vital International Exchange Funding

The Alliance for International Exchange, on behalf of its more than 90 U.S.-based members who implement international exchange programs, and in conjunction with NAFSA and the Forum on Education Abroad, is launching a campaign to urge Members of Congress to demand that the U.S. Department of State lift the freeze on international exchange funding. 

The Department of State still has not lifted what was described as a 15-day temporary pause of all international exchange program funding that went into effect on Wednesday, February 12. This pause has paralyzed an array of time-honored exchange programs that enhance American safety, security, and prosperity.  

This action risks the health, safety, and future of the more than 12,500 American youth, students, and professionals who are currently abroad or who have plans to be abroad in the next six months. It also shuts off funding for U.S. programs now hosting more than 7,400 youth, students, and professionals in American communities from around the world. 

We encourage all exchange champions take action today and urge Congress to support thousands of American students and communities by contacting the U.S. Department of State to demand that funding be turned back on for international exchange programs. 

Alliance congratulates Marco Rubio on his confirmation as Secretary of State

The Alliance for International Exchange congratulates Secretary of State Marco Rubio on his confirmation, and on being sworn in, as the 72nd Secretary of State this week. During his remarks to Department of State staff, Secretary Rubio emphasized the need for a pragmatic U.S. foreign policy that makes America safer, stronger, and more prosperous. We are optimistic that this mission for the Department will translate into the Secretary’s strong support of international exchange programs, which meet those important criteria.  

Exchanges make America safer by advancing U.S. interests and values around the world. Exchanges make America stronger by creating future American leaders and telling America’s story to the world. And exchanges make America more prosperous by bringing billions of dollars to the U.S. economy and creating hundreds of thousands of jobs for Americans. 

The Alliance looks forward to working with Secretary Rubio in his new role and to promoting and expanding Department of State international exchange programs. 

Alliance congratulates Senator Rubio on Secretary of State nomination

The Alliance extends its congratulations to Senator Marco Rubio on his Secretary of State nomination. Since his election to the Senate in 2011, Senator Rubio has been a supporter of international exchange programs, particularly through his membership on the Senate State-Foreign Operations Appropriations Subcommittee. 

On November 21, the Alliance sent a letter to Senator Rubio’s office, congratulating him directly and highlighting the positive economic, political, and social impact of international exchanges on Americans and American communities: 

• An investment in international exchange programs is an investment in the U.S. economy. International university students contributed $43.8 billion to the U.S. economy and created 378,175 jobs in 2023-24. Approximately 90%, or $660 million, of the Department of State exchange program budget is spent on Americans traveling abroad or by international participants while in America. This is one of the best returns on investment in the entire federal government. 

• International exchanges create political and business networks around the world – networks that cement diplomatic relationships and strengthen national security. Exchange programs have immeasurable national defense and security benefits, provide unique value for our nation, and advance American interests around the world. International exchanges are one of our oldest forms of diplomacy and are a key instrument of U.S. foreign policy, essential to strengthening U.S. global leadership and keeping us safe. Exchanges help us promote American values worldwide and build international partnerships based on shared interests that ultimately save lives and build nations.  

• International exchanges create future American leaders, providing them the skills to be successful on the world stage. More than 31 million job openings require skills in communication, leadership, and problem-solving – all skill sets shaped through international exchange experiences. Studying and traveling abroad helps to build careers – 9 out of 10 youth surveyed say they believe travel experiences increase employability. 

• International exchanges help tell America’s story, showing the world what America is really like, building familiarity, kinship, and trust. Four out of five Americans feel international exchange programs enhance the image of their community as a good place to live. 94 percent of exchange students from Muslim-majority countries reported that they have a deeper, more favorable view of American culture after their year in the United States. 79 percent of Fellows who participated in the Mandela Washington Fellowship for Young African Leaders agreed that the Fellowship helped build lasting and productive relationships, both personal and institutional, between the United States and African countries. 

The Alliance looks forward to engaging Senator Rubio in his new role to sustain, protect, and grow international exchange programs. 

A Proven Investment in America: Exchange Policy Priorities for the Incoming Trump Administration

The Alliance for International Exchange has released its international educational and cultural exchange policy priorities for the incoming Trump Administration. The Alliance recommends that the new Administration make international exchange programs a part of its policy priorities because of the transformative power of exchanges in advancing America’s economic and national security interests.   

The Alliance’s policy priorities paper outlines its recommendations for the incoming Administration, focusing on five key areas of growth and collaboration: 

• Policy Priority #1: Support a robust appropriation for Department of State international exchange programs
   The Alliance recommends that the Trump Administration prioritize robust funding for Department of State international exchange programs, one of the best returns on investment in the federal budget. At $741 million in FY24, funding for exchanges is only 0.0006% of the federal budget. And 90% of this funding, or ~$660 million, is spent domestically – either on Americans to travel abroad or by international participants while in the U.S. Funding for ECA exchange programs grew by 17% during the first Trump Administration, and the Alliance looks forward to coordinating with the Administration to continue this trend and ensure funding for these critical public diplomacy programs continues

• Policy Priority #2: Support and expand Department of State BridgeUSA private sector exchange programs
   The Alliance recommends that the Trump Administration prioritize the well-being and growth of the State Department’s BridgeUSA private sector exchange programs, also known as “J-1 visa programs.” BridgeUSA programs, all limited-term and non-immigrant, contribute to the success of many aspects of American business, education, and family life. Program participants not only play vital roles in American life, but they also pay their own way and come at no cost to the U.S. taxpayer. In addition, BridgeUSA exchange participants traveling to the U.S. contributed at least $584.6 million to the U.S. economy in 2023 before returning home. The Alliance will release its BridgeUSA Regulatory Policy Agenda at the start of 2025 and looks forward to coordinating with the Administration to move this agenda forward on specific programmatic interests.  

• Policy Priority #3: Increase the number of international students studying in the U.S. 
  The Alliance recommends that the Trump Administration prioritize the growth of international college and university students studying in the U.S. International students contribute to the U.S. economy and create American jobs and having a cadre of U.S.-educated political and business leaders around the world forwards U.S. interests. The Alliance is a founding member of the U.S. for Success Coalition, a group of organizations that seek to achieve this policy goal, which looks forward to working with the Trump Administration to bring more international students to our country for our economic and diplomatic benefit.   

• Policy Priority #4: Create more access for American students and young professionals to study and work abroad 
  The Alliance recommends that the Trump Administration prioritize creating more opportunities for American students and young professionals to study and work abroad to keep pace and achieve reciprocity with many other countries around the world. Only 280,000 American students studied abroad in 2022-23, while more than 1 million international students came to the U.S. Studying, interning, and working abroad should not be viewed as a luxury for young Americans, but rather a necessity. International experience is a crucial component of a 21st century education and vital to building leadership skills; allows Americans to succeed in the modern marketplace; and plays an important role in developing the global mindset needed to balance local and international challenges

• Policy Priority #5: Ensure effective and secure processing of exchange visitor and international student visas by the Department of State’s Bureau of Consular Affairs 
  The Alliance recommends that the Trump Administration provide sufficient resources to the Department of State’s Bureau of Consular Affairs. By doing so, the Administration will ensure U.S. consular officers can continue to provide visas to the qualified and fully vetted applicants who bring so much value to our country. A well-resourced Consular Affairs Bureau is able to encourage the continued mobility of non-immigrant exchange participants and international students to the U.S., ensuring we continue to benefit from the economic and diplomatic impact of these programs. 

The full policies priority paper is available here, along with a summary one-pager. 

The Alliance team would like to thank all those who contributed to these priorities and recommendations. The international educational and cultural exchange community is at its strongest when it comes together as a unified voice to advocate for the continued success and growth of these life-changing programs. 

Please contact Mark Overmann at movermann@alliance-exchange.org with any inquiries.