Can an Old J-1 Program on Form IAP-66 Still Create INA §212(e)?
Yes. Older exchange programs documented on Form IAP-66 remain relevant to the two-year home residence requirement. DOS requires applicants to disclose and submit historical IAP-66 records when seeking an Advisory Opinion or waiver.
IAP-66 was the predecessor to DS-2019
Older exchange visitors may have program records on Form IAP-66 rather than a SEVIS-generated Form DS-2019.
Old programs remain legally relevant
INA §212(e) is not limited to modern SEVIS-era programs. A historical program can still create a foreign-residence requirement if one of the statutory triggers applied.
DOS requires the historical forms
Current Advisory Opinion and waiver instructions require legible copies of every DS-2019 or IAP-66 ever issued to the applicant.
Old records may need special DS-3035 entries
DOS publishes specific instructions for applicants whose program approval was on Form IAP-66, including substitute entries for the SEVIS number and subject field code.
Frequently Asked Questions
Can a J program from before SEVIS still make someone subject?
Yes.
Does DOS still review IAP-66 forms?
Yes.
Should old IAP-66 forms be included in an Advisory Opinion request?
Yes.
Need Help With a J-1 Waiver?
The Messersmith Law Firm represents J-1 exchange visitors, physicians, researchers, professionals, and families in complex INA §212(e) matters.
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