Wednesday, 17 May 2017 08:42

ASM Letter on State Department Notice on High Risk Visa Applications

David T. Donahue
Acting Secretary, Bureau of Consular Affairs
Visa Office
Department of State

Re: Docket Number DOS-2017-0019

Dear Mr. Donahue:

The American Society for Microbiology (ASM), the largest single life science Society worldwide with over 50,000 members, supports the Department of State’s mission and believes that it is important to provide United States’ consulates with the tools necessary to prevent the entry to the United States of persons who represent a threat to our country. We support the Department’s ability to give further scrutiny to applications filed by high risk individuals “based on information that will lead US consular officers at posts around the world to conclude the applicant warrants enhanced screening”. We are concerned, however, about any possible effect on the processing of visa applications for the vast majority of applicants who would not be subject to enhanced vetting.

The ASM strongly supports the exchange of scientific ideas and collaborations among and between members of the scientific community, both in the United States and around the world. The ASM believes that current security procedures provide an effective means of deterrence and prevention against the entry of persons with terrorist intent. Tools available currently to the State Department include the ability to request detailed travel history, family relationships, and the ability to request social media identifiers. Current tools also include the Visas MANTIS system which is designed to guard against proliferation of sensitive technology, including biological technology that is often developed and utilized by members of ASM.

The ASM believes that the proposed notice insufficiently details the criteria that the State Department will utilize to select those visa applicants who will be required to provide additional information under this proposed rule.  ASM is concerned that because of this lack of specifically defined criteria, the government’s selection of those applicants for additional screening could be overbroad and could be applied indiscriminately.  As a result, we are concerned about the potentially negative and chilling impact upon the ability of the scientific community to continue the robust exchange of scientific information that is so critical to scientific progress and national security.

We request that the Department clarify and define the criteria to be used in selecting visa applicants for additional security screening, to ensure that the Department's security procedures do not unnecessarily and unduly result in harmful impact to the necessary exchange of scientific ideas and information.

Thank you for the opportunity to comment. We would be pleased to answer any questions and be of assistance in any way possible.


Susan Sharp, Ph.D., President, American Society for Microbiology
Stefano Bertuzzi, Ph.D., M.P.H., CEO, American Society for Microbiology
Ronald M. Atlas, Ph.D., Chair, ASM Public and Scientific Affairs Board