One of the biggest changes under the DHS Final Rule is that extending your academic or exchange visitor program and extending your authorized stay in the United States are no longer always the same process. Under the previous Duration of Status (D/S) rule, many students and scholars simply obtained an updated Form I-20 or DS-2019 when additional time was needed to complete their program. Under the new fixed-period admission rule, some individuals may also need to take additional immigration
One of the easiest ways to understand the new rule is to think about three separate, but related, documents.
Issued by TCU.
This document:
- describes your academic or exchange visitor program;
- establishes your expected completion date;
- confirms your eligibility to participate in the program.
It is not your admission record.
Issued by U.S. Customs and Border Protection (CBP) when you enter the United States.
It establishes:
- your immigration classification;
- the date you entered the United States; and
- your authorized period of stay.
Under the new rule, many individuals will receive an Admit Until Date (AUD) on the Form I-94 instead of “D/S.”
In some situations, an individual who wishes to remain in the United States beyond the current period of admission may need to request an Extension of Stay from U.S. Citizenship and Immigration Services (USCIS).
Whether an Extension of Stay is required depends on the individual’s circumstances and the applicable immigration regulations.
Under the previous D/S rule, the process was often straightforward.
Need more time TCU extends your I-20 or DS-2019 Continue maintaining status Remain lawfully in the U.S. under D/S
For many students and scholars, no separate request to USCIS was required simply because the academic or exchange visitor program was extended.
For individuals admitted under the fixed-period rule, the process may involve additional steps.
Need more time Request an updated I-20 or DS-2019 from TCU Review your current Form I-94 Will your Admit Until Date cover the extended program? If so, you must apply for an Extension of Stay with USCIS.
The appropriate next step depends on your individual circumstances and the applicable federal guidance.
A program extension allows additional time to complete the objectives of your approved academic or exchange visitor program.
Examples include:
- additional coursework needed for graduation;
- dissertation or thesis research;
- changes in research timelines;
- approved medical circumstances;
- other valid academic or program-related reasons.
Program extensions continue to be available under existing F-1 and J-1 regulations.
Not always.
Under the new rule, an updated Form I-20 or DS-2019 confirms that TCU has approved additional time for your academic or exchange visitor program.
However, your authorized stay in the United States is determined by your Form I-94 and the immigration rules that apply to your admission.
For some individuals, additional immigration procedures may be necessary if the extended program will continue beyond the current period of authorized stay.
No. Not every student or scholar who receives an updated Form I-20 or DS-2019 will need to file an Extension of Stay request.
Whether additional immigration procedures are necessary depends on several factors, including:
- when you were admitted to the United States;
- whether transition provisions apply to your admission;
- your current Form I-94;
- whether you travel internationally; and
- future implementation guidance from DHS, USCIS, SEVP, and CBP.
International Services will review these factors with you before advising on next steps.
Many students and scholars who were already in the United States before September 15, 2026, may continue under the transition provisions established by the Final Rule.
Those provisions may affect how and when the new fixed-period admission rule applies to you.
Because the transition rules are fact-specific, International Services will review each individual’s circumstances before recommending any immigration filing.
Some individuals may consider whether leaving the United States and seeking readmission is an alternative to requesting an Extension of Stay.
The appropriate course of action depends on many factors, including:
- your immigration classification;
- the timing of your travel;
- your visa validity;
- your program dates; and
- the current federal guidance in effect at the time.
International Services can help you evaluate your options before making travel plans.
Important
Do not assume that international travel is a substitute for an Extension of Stay or that an Extension of Stay will always be required instead of travel. The appropriate process depends on your individual circumstances.
Frequently Asked Questions
If you need additional time to complete your program, contact International Services before your current program end date. We will review your eligibility for a program extension and discuss any additional immigration steps that may be necessary.
No. The Final Rule does not require every F-1 or J-1 student or scholar to file Form I-539. Whether an Extension of Stay is needed depends on your admission history, your current immigration documents, and the applicable regulations.
Not necessarily. An updated I-20 or DS-2019 authorizes the extension of your academic or exchange visitor program. Depending on your circumstances, you may also need to ensure that your period of authorized stay remains valid.
International Services will review your:
- Form I-94;
- Form I-20 or DS-2019;
- anticipated program completion date;
- travel history; and
- applicable federal guidance
before advising you.
Scenario 1: F-1 Student Needs One More Semester
Situation: A student changes majors and needs an additional semester to graduate.
What to Expect: The student should request a program extension before the current I-20 expires. International Services will determine whether the student’s current period of authorized stay is sufficient or whether additional immigration procedures should be considered.
Scenario 2: J-1 Research Scholar Receives Additional Grant Funding
Situation: A research grant is extended for one year.
What to Expect: The host department should contact International Services as soon as the extension is anticipated. International Services will determine whether a DS-2019 extension is appropriate and explain any additional immigration considerations based on the scholar’s admission history.
Scenario 3: Student Travels Before Program Extension
Situation: An F-1 student plans to travel internationally shortly before requesting an extension.
What to Expect: Travel may affect the student’s admission record and should be discussed with International Services before departure. Advising may differ depending on the student’s immigration history and the timing of the extension request.
Our Commitment
The relationship between the Form I-20 or DS-2019, the Form I-94, and any Extension of Stay request is one of the most significant changes introduced by the DHS Final Rule. International Services is actively monitoring guidance from DHS, USCIS, SEVP, and CBP and will provide individualized advising as additional implementation details become available.