Duration of Status Final Rule

AACP Brief

Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media

September 3, 2026

Issue

The Department of Homeland Security (DHS) final rule, Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media, makes significant changes to the immigration framework governing F-1 students and J-1 exchange visitors.

The rule eliminates admission for “duration of status” (D/S) and generally limits F-1 and J-1 admission to the period necessary to complete the program identified on the student’s Form I-20 or exchange visitor’s Form DS-2019, not to exceed four years. Individuals needing additional time generally must apply directly to U.S. Citizenship and Immigration Services (USCIS) for an extension of stay (EOS) or depart and seek readmission. 

In fall 2023, AACP reported 1,906 students enrolled in M.S. programs and 3,529 students enrolled in Ph.D. programs at U.S. colleges and schools of pharmacy. International/foreign students accounted for 48.7% of full-time M.S. enrollment and 49.0% of full-time Ph.D. enrollment. Nearly half of full-time graduate students in pharmacy-school M.S. and Ph.D. programs are international/foreign students, making implementation of the final rule consequential not only for individual students, but also for research laboratories, faculty investigators, sponsored research, pharmaceutical innovation, and the future pharmaceutical sciences workforce. 

The rule also establishes new restrictions governing F-1 student transfers, changes in educational objectives, and enrollment in programs at the same or a lower educational level. These provisions will have significant implications for academic pharmacy because professional pharmacy education, graduate education, and biomedical research frequently involve educational pathways that do not follow a simple bachelor’s-to-master’s-to-doctorate progression. The final rule takes effect September 15, 2026.

Background

In its September 26, 2025, comment on the proposed rule, AACP cautioned that replacing duration of status with fixed admission periods could misalign with Pharm.D. and Ph.D. program structures, increase administrative burdens and costs, restrict academic mobility, and reduce the post-completion grace period. AACP specifically highlighted legitimate transitions between Pharm.D. programs and the Pharm.D. into laboratory-based M.S./Ph.D. programs and requested that DHS preserve reasonable transfers and same-level academic changes. The policy represents one of the most significant changes to international student status management in decades.

DHS states that the final rule is intended to increase periodic federal review of F, J, and I nonimmigrants and improve oversight of compliance with immigration requirements. Under the existing duration-of-status framework, F-1 students generally do not need to obtain a new USCIS determination solely because an academic program takes longer than initially anticipated. Under the final rule, a fixed expiration date will create periodic points at which affected students and exchange visitors must obtain an extension or another form of authorization from USCIS to remain in the United States. USCIS will make the immigration adjudication and may approve or deny the request even when the DSO has recommended the program extension. The total USCIS pending caseload has reached approximately 11.3 to 11.6 million pending applications.

Pharmacy education includes experiential education requirements, clinical rotations, research training, postgraduate training, and degree pathways that may span multiple years and settings.  The final rule is particularly relevant to academic pharmacy because schools and colleges of pharmacy educate and employ international individuals across multiple pathways, including:

• Doctor of Pharmacy (Pharm.D.) programs;
• M.S. and Ph.D. programs in pharmaceutical sciences and related disciplines;
• Pharm.D./Ph.D. and other dual-degree programs;
• postdoctoral research training;
• visiting faculty and J-1 research scholars;
• OPT and STEM OPT employment following graduation; and
• industry, clinical, translational, and laboratory research.

DHS received comments specifically addressing pharmaceutical development and pharmaceutical manufacturing, including concerns about the effects of the rule on interdisciplinary education and the workforce.

Current Law

The final rule was published July 17, 2026, at 91 Federal Register 44976 and is scheduled to take effect September 15, 2026. DHS classified the regulation as a major rule subject to congressional review and states that it will publish a Federal Register notice if congressional review changes the effective date or terminates the rule. Historically, F-1 students and J-1 exchange visitors were admitted under D/S, allowing them to remain in the United States if they maintained status and academic progress.

The final regulation also gives DHS discretion, through September 14, 2028, to delay or suspend implementation of provisions governing transfers, changes in educational objectives, and educational-level progression if implementation is infeasible. DHS must announce such action publicly and provide advance notice before later implementing a delayed provision.

DHS's Student and Exchange Visitor Program has published implementation resources through Study in the States, including a final-rule Frequently Asked Questions document, a quick-reference guide, and an SEVP webinar addressing the fixed-period-of-admission framework. These resources should be read together with the final regulatory text because they provide operational guidance for designated school officials and F-1 students.

Relevant AACP Policies

• AACP supports and recognizes the importance of adequately prepared preceptors, including non-pharmacists and non-US-based preceptors, for global health and international APPEs and training programs. (Source: Global Pharmacy Education Special Interest Group, 2015)
• AACP supports and encourages collaborative scholarship in the area of global health and international pharmacy education and practice. (Source: Global Pharmacy Education SIG, 2016)

Implications for AACP and Schools/Colleges of Pharmacy

Fixed Admission Period of Up to Four Years
Under the final rule, an F-1 student generally will be admitted for the period necessary to complete the program listed on the Form I-20, not to exceed four years, with a separate period for departure following program completion. A program itself does not have to be shortened to four years; students whose authorized period does not cover the full length of their program may seek an EOS from USCIS. Although the professional phase of many Pharm.D. programs is approximately four years, an international student pathway to the Pharm.D. may be considerably longer. Some students complete one or more years of U.S.-based undergraduate prerequisite coursework before entering the professional program, particularly when prior international coursework does not fully satisfy institutional prerequisite requirements. These students may encounter additional immigration transition points before matriculating into the professional Pharm.D. curriculum, including the final rule’s restrictions on transfers and changes in educational objectives during the first academic year of undergraduate study. As a result, the four-year admission ceiling and the rule’s restrictions on transfers and changes in educational objectives may affect students before they matriculate into the professional Pharm.D. curriculum. The effect may be more pronounced in pharmaceutical sciences Ph.D. programs, where completion frequently depends on the pace and outcome of original research rather than a predetermined course sequence. Federal data from the Survey of Earned Doctorates managed by the National Center for Science and Engineering Statistics (NCSES), shares the median time to complete a research doctorate from the start of a doctoral program is 5.7 years across all fields.

New Extension-of-Stay Process 
Students who need additional time to complete an existing program generally must obtain an EOS from USCIS. DHS recognizes “compelling academic reasons” as a potential basis for an extension and states that applications will be evaluated individually. For research-oriented programs, circumstances supporting additional time may include legitimate changes or challenges associated with research and academic progression. The change shifts an important immigration decision from an institution-centered SEVIS process toward direct USCIS adjudication. Schools and colleges of pharmacy may therefore need closer coordination among designated school officials; graduate program directors; Pharm.D. student affairs offices; registrars; experiential education offices; faculty research advisers and principal investigators; human resources; sponsored research offices; and institutional immigration counsel. Schools should consider internal systems that identify affected students well before their fixed admission periods expire.

Graduate-Level Changes in Educational Objectives
The final rule provides that an F-1 student “at the graduate degree level or above may not change educational objectives at any point during their program of study.” DHS defines “educational objectives” to mean the student’s educational level or major. This provision could have important consequences for pharmaceutical sciences graduate programs in which students may refine their fields as research develops—for example, moving among pharmaceutics, medicinal chemistry, pharmacology, toxicology, health outcomes research, regulatory science, or related disciplines. A distinction will be important between a permissible evolution in research within an existing major and a prohibited formal change in the student’s major or educational level.

Restrictions on Graduate-Level Transfers
F-1 students at the graduate degree level or above generally may not transfer to another institution during their program. SEVP may authorize an exception for extenuating circumstances. The regulatory examples include circumstances such as school closure or a prolonged institutional inability to provide instruction. This restriction may have particular consequences for research training. Graduate students sometimes move institutions because a faculty adviser relocates; specialized research infrastructure becomes unavailable, grant-supported work moves to another institution, or a student needs a different academic environment. For Pharm.D. education, the provision also raises questions about students who may have legitimate reasons to transfer between schools of pharmacy. Notably, DHS specifically acknowledged commenters' concerns regarding “disruptions to transitions between PharmD programs”.

Restrictions on Same- or Lower-Level Programs
The final rule provides that an individual who completes a U.S. F-1 program after September 15, 2026, at one educational level generally may not maintain, obtain, or be admitted in F-1 status to pursue another program at the same educational level or a lower educational level. A student progressing to a higher educational level may continue to maintain F-1 status if other applicable requirements are met. Professional and research degrees do not necessarily follow linear progression. Examples include:

• Pharm.D. → Ph.D. in pharmaceutical sciences: movement from professional practice preparation to intensive research training;
• Ph.D. → Pharm.D.: movement from research preparation to the professional degree necessary for pharmacist licensure;
• Pharm.D. → M.S.: acquisition of specialized training in areas such as clinical research, regulatory science, pharmacometrics, health outcomes, or pharmaceutical sciences;
• Pharm.D./Ph.D. programs: coordinated professional and research doctoral training.

DHS expressly acknowledged comments regarding possible disruption to “movement from PharmD to research-focused graduate programs” but did not establish a Pharm.D.-specific exception in the final regulatory text. These concerns are not new. In its 2025 comment letter, AACP specifically cited “transitions between PharmD programs” and movement from a Pharm.D. to a laboratory-based M.S. or Ph.D. as examples of legitimate academic progression that could be impaired by categorical restrictions on graduate-level changes. The Pharm.D. and Ph.D. serve substantially different educational, professional, and research purposes even if DHS ultimately places both within a broadly defined doctoral educational level. Additional DHS/SEVP guidance is needed before institutions can confidently advise students about these pathways.

OPT and STEM OPT
The rule retains OPT and STEM OPT but changes how fixed admission periods interact with employment authorization. Students may need an EOS in addition to employment authorization when their authorized admission would otherwise expire. DHS established transitional relief for certain current F-1 students. Individuals in F-1 status admitted for duration of status who timely file for post-completion OPT or a STEM OPT extension on or before March 18, 2027, generally will not be required to file a separate EOS for the requested OPT period. This issue may be particularly important for graduates of pharmaceutical sciences and related programs that qualify under the DHS's STEM-designated degree framework. Schools should ensure that students understand that STEM OPT eligibility depends on the specific DHS-designated Classification of Instructional Programs (CIP) code rather than on use of the words “pharmaceutical sciences” alone.

J-1 Research Scholars and Postdoctoral Researchers
The fixed-admission framework also applies to J-1 exchange visitors. This is relevant to schools and colleges of pharmacy that employ or host international postdoctoral researchers, visiting scientists, professors, and research scholars. The change may require institutions and research programs to incorporate immigration-extension timelines into longer-term research and staffing plans, particularly where grant-supported projects or scholarly appointments extend beyond the individual's fixed admission period.

Reduced Post-Completion Departure Period
For students covered by the new fixed-admission framework, the final rule generally reduces the F-1 post-completion departure period from 60 days to 30 days. A shorter transition period may create additional pressure for international students completing pharmacy or pharmaceutical sciences programs as they coordinate OPT applications; employment; further academic training; changes in immigration status; graduation documentation; relocation; and international departure. Institutions may need to begin transition counseling earlier in the student’s final academic term.

Recommendations

Federal Agency Actions Sought by AACP

• Clarify the treatment of Pharm.D. and Ph.D. programs under the rule’s educational level restrictions.
• Confirm that legitimate educational pathways such as Pharm.D.-to-Ph.D., Ph.D.-to-Pharm.D., Pharm.D.-to-M.S., and integrated Pharm.D./Ph.D. programs remain permissible.
• Expand or clarify circumstances under which graduate-level transfers may be approved.
• Issue implementation guidance addressing health professions education, biomedical research training, dual-degree programs, practical training, and research-adviser changes.

Member Institution Actions

• Develop systems to identify students requiring extension-of-stay applications. 
• Track impacts of the rule on student progression, research training, and international recruitment. 
• Share implementation challenges and case examples with AACP to support advocacy efforts. 
• Coordinate among DSOs, graduate programs, student affairs, and legal counsel to support affected students.

AACP Actions 

• Collect and disseminate information regarding the effects of the rule on pharmacy education and pharmaceutical sciences research. 
• Monitor impacts on enrollment, research participation, postdoctoral training, OPT/STEM OPT participation, and recruitment of international students and scholars. 
• Educate policymakers and federal agencies regarding the unique structure of pharmacy education and pharmaceutical sciences training, including professional-to-research educational pathways.  
• Convene member institutions to identify implementation challenges and develop evidence-based policy recommendations. 

Conclusion 

The DHS final rule represents a significant change in the federal framework governing international students and exchange visitors. For academic pharmacy, its implications extend beyond the new four-year maximum admission period.The most consequential unresolved questions concern the interaction between federal immigration rules and the structure of pharmacy education and pharmaceutical sciences research. In particular, the rule's restrictions on graduate transfers, changes in educational objectives, and subsequent programs at the same or a lower educational level may not align readily with professional-to-research pathways such as Pharm.D.-to-Ph.D. training. Proactive institutional planning, pharmacy-specific data collection, coordinated communication, and targeted requests for DHS/SEVP clarification will be important to protect legitimate international education and research pathways while enabling schools and colleges of pharmacy to comply with the final rule.

References/Resources

1. U.S. Department of Homeland Security. Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media. Final rule. 91 Fed Reg 44976. Published July 17, 2026. Scheduled effective date September 15, 2026.
2. National Center for Science and Engineering Statistics. Doctorate Recipients from U.S. Universities: 2024 Data Tables. NSF 25-349. Alexandria, VA: U.S. National Science Foundation; 2025. Released August 28, 2025.
3. Student and Exchange Visitor Program. Final Rule: Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure—Frequently Asked Questions. Study in the States. Published July 17, 2026.
4. Student and Exchange Visitor Program. Final Rule: Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure—Quick Reference. Study in the States. Published July 17, 2026.
5. Student and Exchange Visitor Program. SEVP Webinar: Establishing a Fixed Time Period of Admission and an Extension of Stay. Study in the States. 2026.
6. American Association of Colleges of Pharmacy. Profile of Pharmacy Students: Fall 2023 Enrollments. Published July 2, 2024. 
7. American Association of Colleges of Pharmacy. Fall 2024 Enrollments—Profile of Pharmacy Students. Posted November 7, 2025.
8. American Association of Colleges of Pharmacy. Comment letter to DHS and ICE regarding Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media. September 26, 2025.
9. U.S. Citizenship and Immigration Services. All USCIS Application and Petition Form Types: Fiscal Year 2025, Quarter 4.U.S. Department of Homeland Security. 
    

Contact Information

For more information, contact: 
Olunife Akinmolayan
AACP Director of Policy, Advocacy, and Strategic Engagement
Oakinmolayan@aacp.org 
202-631-4773

Information contained in this brief is intended for general educational and policy purposes. Immigration requirements are fact-specific and may change through subsequent agency guidance, implementation decisions, litigation, or congressional action. Institutions and individuals should consult qualified immigration counsel regarding specific cases.