List of 54 'Compromised Colleges' for F-1 Students Shrinks by 16

In August 2017 the Center for Immigration Studies published a list of 54 marginal universities — we called them "compromised colleges" — all of which had DHS approval for the admission of foreign students and all of which were only accredited by an entity that, in turn, was "derecognized" by the U.S. Department of Education (DoEd) on the grounds of its own low standards.

Some to many, but not all, of the 54 were clearly visa mills, educational entities organized to secure profits for the managers and owners and work permits for the alien students, while providing little in the way of education. The accrediting entity in trouble with DoEd was the Accrediting Council for Independent Colleges and Schools (ACICS); Washington-based, it was set up a century ago to serve the interests of private-for-profit higher education.

Returning to the scene 18 months later, we find that the list of 54 has shrunk by 16 (or at the rate of about one a month), with eight institutions going out of business, and eight others (none of which appeared in 2017 to have been major visa mills) dropping their instruction of foreign students, leaving 38.

Did the shrinkage reflect an assertive Department of Homeland Security (or DoEd) getting rid of what we called the "Dregs of Higher Education?" Far from it. Neither lifted a finger in the clean-out and Secretary of Education Betsy DeVos played a counter-productive role.

Oddly the (for-a-while) hero in this complex drama was ACICS, during the time between DoEd's de-recognition and its Betsy DeVos-engineered revival last year. During this period it terminated or threatened to terminate a number of accreditations, but after its return to full health, it accredited two of the most prominent "compromised colleges", Northwestern Polytechnic University in Fremont, Calif., and Virginia International University in Fairfax, Va.

Supporting roles in the cleanup were played by the state regulatory agencies in both California and Virginia, as we reported at the time.

The question of what entities (if any) regulate schools that have the power to cause the admission of foreign students is a complex one, and currently lacks a satisfactory answer.

Congress has ordered, appropriately, that schools dealing with English as a second language and pilot's licenses must be accredited by, respectively, entities approved by DoEd, and by the Federal Aviation Administration. There is no requirement that other institutions working with foreign students need to be accredited by anyone. On the other hand, to secure a DHS permit to teach foreign students on F-1 visas, the entity must have a license issued by a state agency.

In many, but not all, cases the state agencies do require that the schools they license be accredited by a DoEd-recognized agency. So it is possible for an organization that is not accredited to still issue the paper (Form I-20) that leads to the visas. Our original list of 54 did not include any without any accreditation at all.

That list also did not include the University of Farmington (Mich.), which was a successful sting run by DHS investigators; as we recall, it had secured its "accreditation" from an entity other that ACICS. This is hard to confirm at the moment, because the Farmington website has (understandably) disappeared.

An institution's presence on the list of the 38 surviving ones should not be regarded as a ringing endorsement. Three of them are of interest for different reasons; two in Virginia and another with branches in both Virginia and California.

The two in Virginia, and only in that state, have a commonality: Both are for-profits and both are old enough to be "grandfathered" into licensure, which puts them beyond the control of that state's regulator, the State Commission on Higher Education in Virginia (SCHEV). This means that they do not, legally, need to remain accredited to stay in business in that state.

One of them is Stratford University in Falls Church. Ten years ago it was so aware of the benefits of the now-over-used Optional Practical Training program, a scheme for subsidizing employers who hire foreign graduates of U.S. colleges, that it had more graduates in OPT than the entire Ivy League combined, a remarkable, if passing, achievement for a small school. More recently, its current website shows 13 different "withdrawal of approval or "student achievement show cause" notices, all indicating problems in meeting ACICS standards. A nod, however, should go to Stratford for publishing this list in a small corner of its website.

The other school is the newly renamed American National University; of its many campuses, only the ones in Salem and Lynchburg, Va., are authorized by DHS to have foreign students. Both of these campuses have a single accreditation, and this is from the Distance Education Learning Commission, and that requires 51 percent-plus of students to be distant (or online) learners. Under the F-1 rules, a foreign student can take only one online course a semester. That might suggest that DHS should remove the F-1 admission powers granted to these two campuses, but such an action is not likely.

Then we have the case of California University of Management and Sciences, which has campuses both California and Virginia. The state regulator in California, the Bureau for Private Secondary Education, published a searing 18-page "accusation" against CalUMS, and then, last year, decided that it would renew its license anyway, but only if CalUMS removed, on 15 days notice, five named administrators of the school. Those to be removed included the founder, Dr. David Park, Jennifer Park (believed to be his wife), James Kim, and two others.

If you look at the current website in California you will find none of those five names, but you will find those of Julia Park and JaeBun Kim as two of the six members of the local board of trustees, and on the comparable body for the Virginia campus there is Julia Park, again. Maybe the current Park and the current Kim are not related to the Parks and the Kim ordered off the board by the state agency, and maybe they are.

The complete list of the 38 still-operating institutions is shown in Table 1.

Several of the eight schools that went out of business — shown in Table 2 — were still operating but on the verge of closing when our 2017 table was published, such as Jones College and Colorado Heights University.

Two that did not leave the scene quietly were the American College of Commerce and Technology (ACCT) in Falls Church, Va., and Silicon Valley University (SVU) in San Jose, Calif.

The main owner of ACCT tried all sorts of tricks to stay alive, including an alleged and last-minute "sale" of the place to one of its insiders, but the state agency eventually prevailed.

There was more drama at SVU. Its departing president took a $12.5 million "loan" on his way out the door, the place lost its ACICS accreditation, filed for bankruptcy, and then lost its state license. But it kept operating for months until CIS told the state agency that it was still alive; a few days later it closed.

A quick glance at Table 2 shows that ACICS played a major role in closing some of the worst cases among the earlier list of compromised colleges.

The last grouping of these schools, those that are still in business, but no longer hosting foreign students, is the least interesting one (Table 3). None were known previously to CIS as major institutions for foreign students, none attracted press attention as visa mills, and certainly none were targeted by the Department of Homeland Security (of course that holds true for every school on these lists).

Several were under pressure from the market and three of the eight changed their names, never a good sign.

Our sense is that foreign students were probably a minor factor in the picture for these eight, and that the nuisance of maintaining status with DHS was simply not worth the trouble.

While the reduction from 54 listed schools to 38 is a welcome development, visa mills remain alive and well, as new ones pop up from time to time, many were never involved with ACICS, and some have been accredited by that agency.

Four policy changes would be helpful, but in the current climate of tolerating immigration law violations, none is likely to happen:

1. All post-secondary educational entities, not just those teaching ESL, should be accredited before they get DHS permission to cause the admission of foreign students.
2. Congress should probably re-think the very concept of admitting foreign students to take ESL courses; this has produced a lot of illegal aliens. And ESL training is available all over the world.
3. The agency nominally tasked with overseeing the thousands of institutions allowed to bring in foreign students, the Student and Exchange Visitor Program (a unit of ICE), with its 700 employees, should stir itself from its slumber and start closing the worst of the remaining visa mills. The agency continues to be run by the same civil servants who worked under prior administrations, continues to see itself as a service agency, rather than an enforcement one, and my suspicion is that no Trump appointee has even set foot in the agency's offices in Arlington, Va., in the last two years.
4. Most importantly, the Optional Practical Training program should be abolished by a stroke of the president's pen. The program is very useful to the visa mills, it harms citizen and green-card college graduates (who do not get the tax breaks it provides to former foreign students), and it costs well over $2 billion a year to the trust funds for the elderly (Social Security and Medicare). Congress could act as well, but the program was created without congressional input, and could be killed in the same way.

But don't hold your breath.

Kathleen Sharkey, an undergraduate at the University of Michigan, is currently an intern at CIS.