Role of Designated School Official (DSO)

Law Cite 8 CFR § 214.3(i)

A Designated School Official (DSO), or Principal Designated School Official (PDSO) is a regularly employed member of the school administration whose office is located at the school and whose compensation does not come from commission for recruitment of foreign students.

The PDSO or DSO must be either a citizen or a lawful permanent resident of the United States.

Designated School Officials (DSOs) are required to carry out numerous responsibilities and to fill various roles. These roles sometimes appear to be at cross purposes and
present DSOs with situations where the “correct” interpretation is hard to determine and good judgment must be exercised. DSOs must carryout the responsibilities assigned by their institutional employers, and comply with an array of federal regulations, yet provide the best possible service to their students and other “constituents.” These other constituents may include the students’ dependents, government or financial sponsors, academic advisers, supervisors, and other individuals or groups that have an interest in the student and feel entitled to information, assistance, or influence with regard to the international student. Defining boundaries and responsibilities in all these relationships and in the flux of constantly changing circumstances, regulations, and expectations is a Herculean task. DSOs face these tasks as they grapple with the additional workload brought about by SEVIS and, for many, an increasing number of students in difficult economic and political situations.

Historically, most DSOs have seen themselves as an advisor, friend, mentor, confidant, and/or advocate to the international student. The majority of the work does seem, for many DSOs, to be moving toward the collection, monitoring, and reporting of information rather than assisting international students to get their visas and/or employment authorizations or to acculturate to their new place of study.

With differing roles, a DSO will certainly face difficult decisions (e.g. what to do if a student reveals in a discussion an action or circumstance that is or may be a violation of status) or actions (e.g. terminating a student’s record in SEVIS for a violation of status). With the implementation of SEVIS, the increasing explicitness of the regulations, and the numerous and repeated certifications of DSO compliance, there seems to be a decrease in the latitude with which a DSO may act or the extent to which discretion may be used. It is more important than ever for F-1 students not only to understand the requirements of maintaining their lawful non-immigrant status (along with all the procedures, conditions, and time-frames involved), but also to understand fully that they are ultimately responsible for maintaining their own non-immigrant status. They need to realize that many infractions, no matter how minor they may appear, preclude reinstatement and have significant short-term and long-term consequences.
In addition to abiding by NAFSA’s code of Ethic, DSOs would be wise to utilize other resources-particularly knowledgeable NAFSAns and their own institution’s legal counsel to establish effective policies and business practices as pertain to the advising of international students in order to be consistent, lawful, practical, and beneficial for all parties.

The roles and responsibilities of DSOs are indeed changing and every DSO and PDSO – must adapt and forge a solution that complies with statutory requirements, institutional demands, and the needs of the F-1 student. The DSO is pivotal for the continuation of international education and is the key to success for the entire student visa program. It is the DSO, not the institution or any federal agency, that assists the international student with maintaining status so that he/she can reach his/her academic goals.

One DSO at each institution has an additional responsibility, that of Principal Designated school Official or PDSO. The PDSO serves as the contact between the BCIS and the institution with the authority to add or delete campus DSOs in SEVIS and the responsibility for optimal batch-file processing in SEVIS.

DSOs often have conflicting responsibilities that create ethical and legal dilemmas in performing their duties as international educators. A DSO is entrusted to protect his/her institution’s ability to enroll/employee international students. The DSO is an advocate of and confidential advisor to students. However, at times SEVIS compliance is at odds with a DSOs preferred role. Indeed DSOs are struggling to balance security requirements with their desires to facilitate international educational exchange. There are no easy or clear-cut answers to many of the issues facing the seasoned DSO in today’s environment. However when facing ethical dilemmas DSOs can refer to NAFSA’s Code of Ethics for guidance.

*User manual for school Users of the Student and Exchange Visitor Information System