The Department of Homeland Security (DHS) urges all to plan for the unexpected. In recognition of this and being aware of the lessons learned during Hurricane Katrina in 2005, the Student and Exchange Visitor Program (SEVP) encourages all SEVP-certified schools to explore a Continuity of Operations (COOP) plan. The effects of a crisis can be lessened by planning, and a COOP plan will allow your school to continue critical operations until the crisis situation normalizes. SEVP and DHS strongly encourage you to review the basic tenets of COOP planning and utilize the available COOP planning resources, such as those included with this Fact Sheet.
Large scale destruction of buildings, infrastructure and telecommunications systems during Katrina led to the displacement of many international students throughout the affected Gulf Coast region. In the aftermath of the storm, school officials and students had few lines of communication through which to share information and assistance. After resolving immediate safety concerns, schools created interim plans to either continue or cancel classes for the semester. Where schools were unable to reopen, SEVP provided emergency guidance on how to transfer students to other SEVP-certified schools around the country. Individual circumstances were resolved throughout the semester owing to the magnificent response from students and Designated School Officials (DSOs). For many, the magnitude of the event and lack of preparation for such a catastrophe led to an extended period of instability and confusion.
While the outcome of any catastrophic event cannot be predicted, planning does help. DSOs from the affected schools identified the following elements as necessary for an effective plan:
- Develop a method by which students can communicate their location, safety concerns, and short and long-term plans during a crisis.
- Designate alternate campus locations or meeting places where instruction can take place. In the event that this isn’t feasible, school officials should have in place coordinated alternate arrangements with other SEVP- certified schools to accept the transfer of displaced students.
- Develop the ability to access the Student and Exchange Visitor Information System (SEVIS) and electronic student records from alternate facilities or remote locations.
School officials need to monitor and update their plans. School officials and students must train to the plan — rehearse their actions.
Designing a COOP Plan
School officials should consider the following:
- Communication is critical. Can you easily contact your international student population? Do you have emergency contact information/email addresses for all students, an individual to be notified in case of an emergency or the student’s next of kin? Do students have emergency points of contact at the school? Do they know how to contact SEVP?
- Nonimmigrant documentation must be preserved. Have students been instructed to hand carry their travel documents, including the passport, visa, I-20, immunization record, proof of personal finances and student ID?
- Regulations must be observed. Do your administrators and students know the basic rules governing how students can maintain status in the event of a crisis? Are both parties well-versed in the regulations with respect to transferring between SEVP-certified schools, the definition of a full course of study, student reporting and registration requirements, online training guidance and coordinating special tuition arrangements in the event that classes are postponed or cancelled?
- Records must be accessible. Do you have a backup server for electronic records/communication? Does the International Student Office (ISO) maintain copies of the students’ documentation, including passport, visa, immunizations and emergency contact information? Is the ISO aware of the notice protocols involved if a death occurs? Does the ISO know which government agencies to contact?
- Alternate arrangements should be pre-established.
- Do you have pre-arrangements with other schools by which instructors can provide offsite instruction to your displaced student population? If not, do you have agreements with other schools to which your displaced students could easily transfer?
- Do you offer online classes that can be substituted for on-site training/education? Do these classes meet Code of Federal Regulation (CFR) requirements?
- Has your school considered the use of virtual classrooms or environments as educational resources?
- Can your administrative staff operate remotely/virtually? This includes provisions for encrypted laptops for key personnel, communications equipment, Satcom phones, mobile devices for text messaging and cell phones with alternate area codes.
- Emergency guidance should be disseminated ahead of time and during the crisis. Can you post emergency instructions on your Web site from a remote location? Do you have an operational plan to do so?
- All parties should be prepared. Have you established a training program? Have you established a listserve and points of contact for communication?
Please reference the following information and guidance for further assistance in designing your COOP plan:
- CFR Student and School Regulations are available at: Record Keeping: 8 CFR 214.3(g)
- Student Reporting: 8 CFR 214.3 (3)(g)
- Online Training: 8 CFR 214.2(f)(6) for F students; 8 CFR 214.2(m)(9)(v) for M students
- Transfers: 8 CFR 214.2(f)(8)
- Department of Homeland Security emergency preparedness, continuity planning and training information: https://www.ready.gov
- FEMA’s Emergency Management Institute offers additional resources and training at http://training.fema.gov.
- In order to encourage Americans to prepare themselves, their families and their communities, the DHS, in partnership with the Advertising Council, has sponsored public service advertisements that educate and empower Americans to prepare for and respond to all kinds of emergencies. The Ready Campaign is available at the following link: www.ready.gov.
- Center for Disease Control and Prevention (CDC) has information and resources, regarding emergency preparedness and response, online at http://emergency.cdc.gov/.
Sample School Plans
The following three resources are actual COOP plans developed by the University of Florida, the University of Arizona, and George Washington University: