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					                     Impact Assessment
                       US IEP Industry

  Prepared at the Request of the Bureau of Educational and
                      Cultural Affairs,
                    Department of State

             Judy Judd-Price, Chair, ATESL, and
  Karen Decker, Shelley Etzine, William M. Fish, Laurie Miller,
    Marsha Sprague, Valerie Woolston, Deanna Wormuth.
ATESL thanks AAIEP and UCIEP for their support and assistance.

                         August 2003
                          Impact Assessment
               IEP (Intensive English Program) Industry

The IEP industry in the US began approximately 70 years ago and includes
university-governed programs and independent institutions. The
independent institutions are often invited by colleges and universities to
offer programs on campuses. IEPs work together through associations
such as NAFSA, AAIEP, UCIEP, and TESOL. Our competitors are IEPs in other
English speaking countries including Canada, the UK, Australia, and New
Zealand who receive government support in marketing and data
collection, and benefit from visa waivers or policies which allow short term
and up to 6 months’ study with no student visa requirement for many

Just as US students who participate in Study Abroad programs do so to
achieve a variety of objectives, international students who attend an IEP
may do so for academic, professional, or personal goals. Both in the US
and in other countries, students attending IEPs study in courses focusing on
English for Academic Purposes, English for Special Purposes (specialized
vocabulary and content for specific fields such as business or banking), or
in short-term general English courses, sometimes called study vacation
courses. Students enroll in courses for anywhere from 2 weeks to an
academic year, depending on their proficiency in English at the time of
arrival at the IEP, time available before they must return to studies or jobs
in their home countries, and their goals in learning English. It is important
to bear in mind that IEP students apply for visas every month of the year.
Historically, peak entrance dates have been in January, April, June, July,
and August. Most IEPs offer instruction year-round with frequent entry
dates because students enroll while on break from studies and jobs in their
home countries as well as prior to attending undergraduate or graduate

Self Regulation in the IEP Industry
The US IEP industry promotes best practices through voluntarily adopting
the standards of professional associations such as NAFSA, AAIEP, UCIEP,
and TESOL. Both AAIEP and UCIEP require that standards be met in order
to achieve and maintain membership. All of the associations have
protocols in place to address complaints made against a member
charged with violating the Code of Ethics or membership standards.
Many IEPs seek accreditation by an accrediting body recognized by the
US Department of Education to award accreditation to English Language
programs or institutions. CEA (Commission for English Language Program
Accreditation) was formed by representatives from AAEIP, UCIEP, TESOL,
and NAFSA and was recognized by the Department of Education in June
of this year to grant both programmatic and institutional accreditation to
ESL and IEP programs. ACCET (Accrediting Council for Continuing
Education and Training) is recognized by the Department of Education to
accredit a wide range of institutions including IEPs. Both accrediting
bodies worked with members of the IEP industry to create the field specific
standards, documentation, and verification procedures appropriate for
an IEP, including those related to academic program, student services,
and compliance with DHS.

In addition to creating and promoting standards related to program
quality and student services, the IEP industry has been involved in actively
promoting compliance with INS/DHS regulations. IEPs have contributed to
the introduction and implementation of SEVIS by working with members of
the SEVIS Team to develop procedures that are workable for programs on
a non-semester schedule. The IEP industry was represented in the CIPRIS
project, participating in all phases of the pilot for SEVIS, and has been
active in providing training and support for PDSOs and DSOs in IEPs. In
March of this year, NAFSA published SR-2003-e, The Impact of F SEVIS
Regulations on Language School Operations, written by IEP DSOs to assist
the field in being compliant with the new reporting requirements. NAFSA
has included representation from the IEP industry in the SEVIS Project
Manager group, and BICE/DHS calls on this group as an industry advisory
panel regarding SEVIS procedures.

Enrollment Decline
As reported at the NAFSA Conference and in the Chronicle of Higher
Education, AAIEP and IIE conducted a web based survey in early May of
this year. The results indicate that US IEP enrollment declined by 19.1%
between 2002 and 2003. Based on applications received by early May,
the anticipated number of summer language program enrollments for all
nationalities in 2003 was a decline of 30.5% compared to 2001. Some
industry observers estimate that the decline in enrollment for 2003 YTD
compared to the same period in 2001 is much higher than 30%.

Over the past two years, the decline in enrollment in US IEPs has been
caused by students’ concerns about safety, the economy of some foreign
countries such as Brazil, travel restrictions related to SARS, confusion about
changing visa policies, concern about treatment while in the US, and
aggressive marketing by our competitors in other countries. While
consular staff has been instructed to grant visas for English study,
anecdotal information suggests that in some cases students are told they
do not need to travel to the US “just to learn English.”
While the above information refers to IEP programs, it should be
remembered that many IEP programs are the gateway to US higher
education. Many IEP participants continue on to pursue undergraduate
and graduate degrees in the United States. A loss in market share in
IEP programs will produce additional loss in the number of international
students in higher education in the US.

Impact on Higher Education
Many US universities are dependent on IEPs to evaluate the English
proficiency of international teaching assistants (ITAs) and certify them to
teach in their institutions. Most large research universities rely on their IEPs
to prepare ITAs for teaching, by improving their English language
communication skills and by increasing their knowledge of American
culture. Many lower-level undergraduate courses are taught by ITAs who
are expected to have comprehensible English, good teaching skills, and
knowledge of American culture and university life. Without IEPs, they
would not receive the training they now get, and undergraduate
education would be seriously impacted.

MA TESOL programs and certificate programs which prepare K-12
teachers to teach in the multi-cultural classrooms in many communities
and states often depend on IEPs. IEPs serve as labs for practicum classes,
an important part of the education of new teachers.

Universities and colleges have depended on revenue from their IEPs to
support programs and services for the larger institution. When the IEPs
take in less revenue or close due to low enrollment, some universities may
need to either reduce services on campus or increase the tuition.

Lost Revenue
In addition to fees paid directly to IEPs for application, tuition, residence
halls, and meal service, vendors who serve IEPs are also affected
negatively by the downturn in enrollment. These include the airlines, travel
and tourism industry, publishers of ESL materials, host families, student
health insurance carriers, testing companies, rental car companies, and
the cities and communities where these students live and shop. The travel
and tourism sectors benefit from student flights to the US, school-organized
cultural enrichment activities frequently involving excursions, and
extensive travel within the US before and after their programs of study.

Some universities and private IEP systems may favor opening new schools
in other countries where the return on investment is more assured at this
Language Travel Magazine estimates the total English language teaching
market for all English-speaking countries was worth over 7.5 billion dollars in
2002 with the largest two destinations being the UK and the US. LTM
estimates that the US share of the market is 28.5%, which breaks down as
follows: Tuition, $660,021,230; Accommodations, $595,423,412; and
Miscellaneous, $941,583,482. According to the article, the total US share
of the worldwide IEP industry in 2002 was $2,197,028,124. The 19.1% drop in
US enrollment reported by IIE would suggest a loss of nearly a half billion
dollars this year.

Lost Jobs
Using a teacher/student ratio of 1:20 (and many programs have much
smaller class size for effective language instruction), we estimate that at
least 1,000 IEP teachers lost their jobs in the past two years due to the
decline in enrollment. We estimate that a quarter of the administrators at
IEPs are no longer full-time administrators. Losing staff positions at this time,
when considerable staff time is used for reporting information to SEVIS,
leaves fewer staff hours available for curriculum development, marketing,
and student services, areas that are important to maintain the reputation
of US IEPs and a competitive advantage over the IEP industry in other
English-speaking countries.

Student Ambassadors
IEPs are commonly the first experience an international student has in the
US, and in some cases the only experience in the US the student will have.
IEPs do much more than teach English. Schools organize events to bring
international students to public schools to help educate American
children about other countries and cultures. Because IEP students want to
learn about our culture and values and because interacting with
Americans is the best way to practice newly acquired language skills, IEPs
help students find opportunities for volunteer activities with service and
charitable organizations as extra-curricular activities, plan educational
field trips, invite community leaders and professionals to speak to students,
and encourage activities with American students.

When American students interact with international students at campus
events planned by IEPs, they are motivated to study a foreign language
and to plan a study abroad trip even though they may not have studied
or mastered the language of the country they will visit. IEP students
contribute by helping internationalize the campus and when they return
home they become future international leaders and ambassadors of
good will for the US.
School Closings
The AAIEP Central Office reports that 27 IEPs, or 10% of their total
membership, have closed due to low enrollment in the last two years.
Many more are sure to close as enrollments erode further.

One of the many other IEPs that have closed during the same time period
is the Economics Institute in Boulder, Colorado. In its 45 years of service,
the Economics Institute taught over 13,000 students from 160 countries.
The student body always included scholarship students from Senegal,
Ivory Coast, Zaire, Mali, and Chad who would go on to earn an MBA or
PhD. The alumni list includes those who went on to positions in universities,
in ministries of finance, and as directors of banks in their home countries.
One alumnus, Ernesto Zedillo, became President of Mexico.

IEP Diversity Threatened
As enrollments decline and fewer IEPs survive, the diversity of types of
programs within the US IEP industry will be reduced. The programs that
can last the longest with reduced enrollments will fall into 2 categories:
those that cut corners to reduce expenses, and those that have
substantial financial backing. This group includes those major universities
that can operate IEPs at break even or at a loss and a small group of
private programs. Students and our industry are best served when a
variety of programs are viable, when there are adequate resources for
research and publication, and when teacher preparation programs

Visa Delays
Visa delays have been well reported in the past few weeks and are a
major concern for IEPs. We are concerned that many US IEPS will not be
able to survive additional obstacles affecting student travel on top of the
challenges our industry has faced in the past two years.

The following examples have been reported:

Switzerland: It is reported that the amount of lead-time to schedule an
appointment varies between 4-8 weeks. Students must go to Berne and
wait for 2 hours for their turn in a windowless room without air conditioning.
Students report that the attitude of the Embassy personnel is that there is
no reason to study in the US and that the US doesn’t want or need them.

Japan: In 2001, Japanese students represented more than 20% of the
total enrollment at US IEPs, according to the AAIEP-IIE Survey. It is reported
that no visas will be issued for the next 2 weeks as Tokyo prepares for the
interviews. Three officers will interview about 2000 applicants each week.
Students must go to Tokyo or Osaka for the interview. Someone who lives
hundreds of miles away must travel at considerable expense for a 2-
minute interview.

Brazil: Brazilian students have typically represented an important group for
US IEPs, particularly when Brazilian students are on seasonal break from
studies. Brazil is larger than the continental US, and traveling across the
country for a 2-minute visa interview will cost hundreds of dollars in airfare
and hotel accommodations.

Visa delays and expensive travel required for a visa interview will have a
critical impact on IEPs because those planning to study in short-term
programs do not apply to schools far in advance as they might if they
were seeking admission to Harvard for a four-year program. Typically, an
international student seeking to study English will apply 5-8 weeks prior to
the beginning of the course. This behavior is not likely to change. Rather,
students who want short-term English programs will apply to IEPs in other
English-speaking countries.

While some US Embassy websites inform visitors that they do not need to
get a visa to study in a tennis or golf program, attend a business seminar,
or attend a language program of less than 18 hours per week, US IEPs
have been told that students on B visas and visa waivers cannot enroll
unless study is incidental to the reason for entering the US. These
instructions appear to be contradictory and are confusing to students
overseas and to the IEP industry.

Lost Market Share
As reported in The Wall Street Journal on July 29, 2003, other English-
speaking countries such as Australia, New Zealand, Ireland—and even
Malta—are more welcoming to intensive English consumers than ever
before. “We’re out to take market share away from the U.S.,” said
Richard Law, who works for the state-supported British Council in London.
The article also reports that a recent e-mail to schools and recruiters from
Canada’s equivalent of the British Council, the Canadian Education
Center Network, predicted that “a growing suspicion toward foreign
students in the US would discourage many applicants and benefit more
welcoming countries that adapt their marketing strategies to take
advantage” of this situation.

The websites of the Canadian Education Center Network promote
Canada as a world-class education provider and describe Canada’s IEP
teachers as having excellent academic background, strong professional
training, neutral English accent, and innovative and creative teaching
methods. We do not take issue with this description. Rather, we would
like to have the same level of support from our government so that the US
can remain the leader in our field.

The CEC also provides many valuable services to students interested in
studying in Canada and to schools interested in enrolling international
students. Services include conferences so that schools may meet with
overseas educational counselors and in-country assistance with the visa
issuance process for students.

Each student who decides to study at an IEP in Australia, Canada, the UK,
Ireland or New Zealand due to less stringent visa rules will refer his relatives,
friends, and employees to schools in those countries.

Former students are referral sources for the rest of their lives. We know
from experience that students who study in a particular country tend to
return for additional study, pleasure, and business later in their careers and
to refer their employees to that country for language training. They
become lifelong ambassadors and promoters of the US. The US is losing
the revenue and the good will of these students and those they would
have referred.

The government-imposed visa delays, interview requirements, and travel
necessary for interviews facing students and scholars who wish to enter
the US are now threatening the livelihood of IEPs.

Other countries recognize the importance of the English language
industry and are working hard in a concerted plan to recruit students and
scholars from abroad and to take market share from the US.

IEPs in the US are at a crisis point. We need the active support of our
government now. Our government has the ability to provide clear, user-
friendly instructions to students and those who refer them, to create a
welcoming environment in the consulates and embassies, and to
recognize the importance of English study in the US.