This post discusses English language proficiency (ELP) requirements for colleges and universities in the United States Student Exchange and Visitors System (SEVIS). In particular, the Tennessee higher education landscape is briefly examined. <o:p></o:p>
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Overview<o:p></o:p>
· What is "proficiency" and why does it matter?<o:p></o:p>
· ELP Testing Requirements Target Certain Students (and Provide an Advantage to Others)<o:p></o:p>
· ELP Requirements: Tennessee<o:p></o:p>
· Recommendations for ELP Policy Development in Tennessee<o:p></o:p>
· Questions for Readers<o:p></o:p>
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What is "proficiency" and why does it matter?<o:p></o:p>
Proficiency is a broad term that measures the degree of fluency an individual has in a language, particularly in understanding the language, producing the language, using proper syntax, using a variety of vocabulary, and employing semantics or other language structures. Without some degree of language proficiency, a person may not be able to thrive, or even survive, in a particular setting. In the context of education, a language deficiency may impact critical features of the academic experience. In particular, a student may not be able to interact with the material without some degree of fluency in the language of the material. <o:p></o:p>
However, language proficiency is not static. The needs of an individual may change depending on the context of their use of the language. For example, a student whose major is in medicine may do quite well in their additional language when the context is medicine. However, when they take a physics class – sometimes required for pre-medicine degrees – their proficiency in this field may not be indicative of their medical language proficiency. Furthermore, some students may have skill inconsistencies across areas of interest, such as writing, speaking, reading, and listening. <o:p></o:p>
Many institutes of higher education in the US do not track English as an additional language (EAL) students, let alone consider ELP in applications of native US students. EAL students who are not born in the US or did not graduate from a US institution may be targeted or underserved audiences due to potential bias in language proficiency requirements in the context of US - Tennessee higher education. In the context of studying in the US - Tennessee for this discussion, international students are students who 1) are not US citizens; 2) have primarily attended school in a nation other than the US; and 3) have earned their degree (e.g. high school completion, bachelor's degree, etc.) outside of the US or US educational system. <o:p></o:p>
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ELP Testing Requirements Target Certain Students (and Provide an Advantage to Others)<o:p></o:p>
There are several parties who help shape a school's ELP requirements. The Student and Exchange Visitor Program (SEVP) is overseen by the Department of Homeland Security (DHS) whose policies are outlined by the Federal Register published by Immigration and Customs Enforcement (ICE). The published codes – the CFR – are to be interpreted by DHS, SEVP, Designated School Officials (DSOs), and admissions teams of schools, at a minimum. To understand the advantage given to US students, I attempt to interpret the current CFR codes, DHS Study in the States publications, and ICE and SEVP FAQs that are available online. <o:p></o:p>
Since international students typically study in the US by obtaining a US visa, a school must have a set policy for admitting students; this policy should be fair and equal for all students, and not just applied to international students as an extra step. Students typically study at SEVP-certified schools who have been scrutinized and approved by DHS. According to DHS, ELP is not required to fully admit a student if ELP is not a part of the admission policy; furthermore, SEVP "does not regulate how well an international student must speak the language in order to study in this country" (DHS, 2016). However, since taking classes in a different language can be challenging, many schools have their own language policy: usually, it is part of the overall admissions requirement (DHS, 2016). The ICE form guidance for language proficiency only indicates the general admission requirements – not additional testing – should be part of a school's SEVIS certification; if no testing is required, then it is recorded in the school's certification (DHS, 2016; ICE, n.d).<o:p></o:p>
However, many schools require international students, particularly those from areas where English is not a primary or government language, to take additional tests on top of existing admission requirements in order to be admitted to the school. Some schools have begun making ELP testing optional, or allowing students to take an ELP test on-site if there are concerns during advising that they may not succeed in their coursework. The actual policy is outlined in CFR 214.3 (k) (2): <o:p></o:p>
§214.3 Approval of schools for enrollment of F and M nonimmigrants.<o:p></o:p>
(k) Issuance of Certificate of Eligibility. A DSO of an SEVP-certified school must sign any completed Form I-20 issued for either a prospective or continuing student or a dependent. A Form I-20 issued by a certified school system must state which school within the system the student will attend. Only a DSO of an SEVP-certified school may issue a Form I-20 to a prospective student and his or her dependents, and only after the following conditions are met:<o:p></o:p>
(2) The written application, the student's transcripts or other records of courses taken, proof of financial responsibility for the student, and other supporting documents have been received, reviewed, and evaluated at the school's location in the United States."<o:p></o:p>
Aside from this regulation, the current federal register explicitly references ELP "both oral and written" as mandatory only for graduate-level medical students (ICE, 2023). <o:p></o:p>
Students who are from a country other than the US and who are planning to attend institutes of higher education in the US are explicitly targeted by additional barriers to admission. Throughout the 128 countries where English may not be the national or common language, there are multitudes of all-English private schools, All-English British and American schools, and other opportunities (such as family, friends, personal interests, tutoring, etc.) where students may learn processional, academic, and conversational English (Worldometer, 2023).<o:p></o:p>
To add to this bias, it has been noted in several studies that students who may fare well on standardized testing – the most common evidence requested for ELP – do not do well in classroom situations (Butler et al., 2020; Chen & Bang, 2020; Chen & Fink, 2021; Chennamsetti, 2020; Girmay et al., 2019; Harrison & Shi, 2016; Koo et al., 2021; San et al., 2022; Shi, H. 2021; Lee et al., 2020). Although students may have a strong grasp of some parts of the language – particularly, those parts needed for standardized testing – they may not have "application" skills in language use. English is required as an area of study in many parts of the world, but it is not necessary to be fluent in all cases – it's necessary to pass a class or meet a benchmark, much like many US students may take Spanish or French in high school with little to no actual using of the language or intent to use it in the future. <o:p></o:p>
Furthermore, EAL students who graduate in the US or other areas where the primarily spoken language is English do not have to take additional testing. In the US case, for example, if student who was born in Britain, goes to an all-French K-12 school in New York, that student wouldn't be asked for language proficiency – even if English was a secondary language – because they were born in an English-dominant country and graduated from high school in the US. As a second example, a student who was born in Tennessee, but perhaps grew up and graduated in Argentina – where Spanish is the first language, may not be asked to provide ELP as a US citizen. A student from China who immigrated to the US in their last year of high school before graduation may be asked to provide ELP since they graduated in the US. However, a student born in Dubai and who had attended an international school in the United Arab Emirates, where curriculum is given in English, may be required to submit additional evidence – not based on their academic history, but their birthplace and area of study. <o:p></o:p>
Ultimately, the tenacity of the federal regulation of schools to "require" English proficiency puts the weight of policy-building on the school. Is it equal to require only international students who are not from "English-dominant" countries to take language proficiency tests as an admission criterion?<o:p></o:p>
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ELP Requirements: Tennessee<o:p></o:p>
The author's frame of reference for this discussion is based on the requirements of 25 colleges and universities in Tennessee (Tennessee Higher Education Commission, 2023). SEVIS-approved schools were found using the DHS School Lookup tool (DHS, 2023). Each school's admission page was scanned for ELP requirements. <o:p></o:p>
The Tennessee Department of Education lists English as a Second Language regulations for K-12 education under their academic standards online. No information for higher education is listed (TDOE, n.d.)<o:p></o:p>
The Tennessee Board of Regents (TBR) for the College System of Tennessee's Limited English Proficiency G-130 guideline advises that institutions within the TBR system "take reasonable steps to provide meaningful access to persons with limited English proficiency" (TBR, 2012). The definition of such students is provided, and is noted to include "international students, faculty, staff, and other individuals seeking services and access to programs" (TBR, 2012). The specific and relevant TBR policies for admissions are:<o:p></o:p>
Policy 2:03:00:00 "Admissions" – provides the basic English requirement for entering students.<o:p></o:p>
"Policy 2:08:30:00 "Admission and Delivery of Services to International Students and for the Employment and Delivery of Services to International Faculty and Academic Staff at TBR Institutions" - provides requirements related to English proficiency and the provision of professionally staffed ESL programs if the institution admits students not meeting those requirements.<o:p></o:p>
These TBR policies indicate that for college and university admissions, all students should provide evidence of basic English requirements – not just international students. Additionally, if an admitted student does not meet language proficiency, the institution must provide professionally staffed English language programs to help students meet those requirements (TBR, 2012). <o:p></o:p>
Of the separate (separate campuses not included) colleges and universities listed in the DHS school search:<o:p></o:p>
· 35 Require additional ELP testing with general admission<o:p></o:p>
· 7 Do not require additional ELP testing with general admission<o:p></o:p>
o ELP is equivalent to the placement test (SAT, ACT, etc.) required by all students and is 'waived'.<o:p></o:p>
· 9 do not list a policy for ELP<o:p></o:p>
Notes: Each school's policy varied to some degree, and some schools waived placement testing requirements, requiring only English. Others accepted some degree of English-medium instruction. Some had excepted countries. This list is not exhaustive and did not include several seminary schools and additional campuses/branches of schools listed in the SEVP list.<o:p></o:p>
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Recommendations for ELP Policy Development<o:p></o:p>
While language proficiency may be important in some context, it should not be a qualifying admission criteria for international students. Policies requiring only some students to take additional testing targets, by means of adding an extra barrier, a specific group of potential students without equally targeting others. Institutions should involve stakeholders to discuss potential resolutions for equitable access to education for all students who want to apply for a school. For example, if the SAT or ACT is required for US students to show college readiness or academic aptitude, then international or other EAL students should provide the same evidence. If a school's stakeholders, such as faculty, instructors, staff, or trustees, are timid in requiring equitable testing for students, then it is possible for schools to start collecting language data of applicants. Students who consider themselves EAL students can opt-in for a language proficiency test before registration, removing the equity barrier, but also providing an avenue for students to self-report needs. <o:p></o:p>
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Questions for Readers<o:p></o:p>
What are ELP requirements at your institution? <o:p></o:p>
Are they similar for all applicants?<o:p></o:p>
How do ELP requirements influence applicants to your school? <o:p></o:p>
How do ELP requirements at your school impact current students?<o:p></o:p>
What trends have you noticed among EAL or international students at your school regarding their experiences in relation to their ELP? <o:p></o:p>
What reservations would you have about removing "extra" ELP requirements at your institution? What are possible benefits?<o:p></o:p>
What recommendations do you have to initiate conversations with potential students regarding ELP criteria for admission? With current students? With faculty? With admissions?<o:p></o:p>
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This discussion post was written as a draft of Social Scholarship, or discussing scholarship via social media, for a postgraduate education class. All critical feedback is welcomed, as well as missed information, misinterpretations, misunderstandings, or unconscious bias perpetuated by the author. <o:p></o:p>
The author is not employed by an admissions team and does not develop admissions criteria; however, they work with international students in recruitment, involvement, and advising, and found other university policies to be different than their own. As such, this area has become an area of interest, not of expertise. All polite, informed comments and guidance are encouraged and welcomed so they may learn more with the community. <o:p></o:p>
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Department of Homeland Security. (2016). Questions from DSOs: Is English proficiency testing required to issue the form I-20? Study in the States. https://studyinthestates.dhs.gov/2016/10/questions-dsos-english-proficiency-testing-required-issue-form-i-20 <o:p></o:p>
Department of Homeland Security. (2016). Do I need to pass an English language test to study in the United States? Study in the States. https://studyinthestates.dhs.gov/2016/01/do-i-need-pass-english-language-test-study-united-states <o:p></o:p>
Department of Homeland Security. (2023) School search. Study in the States. https://studyinthestates.dhs.gov/school-search?field_school_name_value=&field_location_city_value=&field_location_state_value=3&field_location_zip_value=&field_education_level_value=1&field_f_1_school_value%5B1%5D=1 <o:p></o:p>
Tennessee Department of Education. (n.d.) Academic standards: English as a second language. https://www.tn.gov/education/instruction/academic-standards/english-as-a-second-language.html <o:p></o:p>
Tennessee Board of Regents. (2012). Limited English proficiency: G-130. https://policies.tbr.edu/guidelines/limited-english-proficiency. <o:p></o:p>
Tennessee Higher Education Commission. (2023). Tennessee's colleges and universities. https://www.tn.gov/content/tn/thec/learn-about/tennessee-s-colleges-and-universities/west-tn-institutions.html <o:p></o:p>
United States Immigration and Customs Enforcement. (n.d.) A guide to the form I-17 fact sheet. ICE. [PDF]. https://www.ice.gov/sites/default/files/documents/Document/2015/formI17guide.pdf<o:p></o:p>
Worldometer. (2023). How many countries are there in the world? https://www.worldometers.info/geography/how-many-countries-are-there-in-the-world/#:~:text=There%20are%20195%20countries%20in,and%20the%20State%20of%20Palestine. <o:p></o:p>
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Elizabeth Harrison
International Student Services Coordinator
Austin Peay State University - Clarksville, TN
United States
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