Policy Brief: Trump’s DOS Doctrine Misses the Mark, but Integrity Measures Can Safeguard Visa Security

Contact: Mariah Ferguson (mferguson@aila.org); Shev Dalal-Dheini (sdalal-dheini@aila.org); Kate Angustia (kangustia@aila.org)

The Department of State (DOS) is implementing the “Donroe Doctrine,” which reframes immigration as a national security threat within the Western Hemisphere.¹ DOS has undergone significant policy, operational, and personnel changes in line with this doctrine with the stated purpose of making America “safer, stronger, and more prosperous.” In reality, these policies have weakened U.S. economic power, global influence, and credibility by slowing and halting visa processing for foreign workers, family members of U.S. citizens and permanent residents, and individuals seeking humanitarian relief. As we close our door to this talent, other countries have opened theirs to immigrants’ skills and innovation.²

Rather than dismantling the legal immigration system, DOS can achieve the Administration’s goals of putting “America First” by recognizing that immigration is a vital tool that can protect our national security by advancing U.S. economic and global interests. The United States already has a track record of policies that safeguard national security and advance prosperity, and we should improve upon these proven tools as a strategic choice.

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Visa Processing Disruptions Undermine U.S. Economic Strength and Prosperity

As detailed below, DOS has implemented widespread changes to consular processing with little notice or transparency, causing confusion and disrupting consular services worldwide.³ These disruptions obscure accountability, slow lawful travel, and signal institutional dysfunction. Increased vetting without prioritization overwhelms consular officers, delays visa issuance for workers, students, and families, and undermines confidence among U.S. employers, universities, and international partners. Through transparency, accountability to U.S. economic drivers and citizens, and a risk- and evidence-based vetting system that has been tested for results, DOS can facilitate safe and secure migration to the benefit of the United States.

Visa Revocations and Increased Vetting Turn Away International Students

In the spring and summer of 2025, DOS revoked more than 6,000 student visas while the U.S. Immigration and Customs Enforcement (ICE) revoked over 4,700 student SEVIS records and thereby their legal status. Consular posts paused student visa interviews for weeks, and implemented burdensome screening and vetting policies for F, M, and J nonimmigrant visa (NIV) categories, requiring consular officers to review and assess applicants’ entire online presence for “any indications of hostility toward the citizens, culture, government, institutions, or founding principles of the United States.” There is little evidence that such in-depth scrutiny of someone’s social media accounts, without credible suspicion of wrongdoing, results in actual threat detection. Rather, it generates reams of useless information that can be misunderstood and be weaponized to target minorities.

These actions drove a 188% increase in student visa wait times at reporting consulates, and fall 2025 international student enrollment fell by 17%. The economic cost of these delays is substantial, as international students are a major economic engine for the United States.⁴ Arbitrary vetting standards deter top talent and push students toward competitor countries.

A better way forward is to recognize international students as a strategic and economic asset rather than a default threat. With this basic tenet driving strategy, DOS should implement targeted vetting, based on credible evidence, rather than blanket social media scrutiny and impingement on freedom of speech. Focusing on a teenager’s shared TikTok posts will not identify genuine national security threats; rather, DOS should improve available intelligence tools and information sharing partnerships to truly protect U.S. national security.

Sudden and Uncoordinated Vetting Changes Strand Workers and Harm U.S. Employers

On December 3, 2025, DOS announced expanded screening and vetting for H-1B and H-4 visa applicants. On December 8, 2025, DOS abruptly suspended December 2025 visa interview appointments for these high-skilled workers and their family members en masse. The timing of the announcement was particularly problematic, as it coincided with the holiday travel season, as well as the new $100,000 fee and weighted lottery. Many appointments were rescheduled for spring 2026, but some were pushed back as far as April 2027, stranding H-1B workers and their families overseas for many months. An AILA member reported that a cardiologist’s visa renewal appointment, originally scheduled for December 2025 and past the biometrics stage, was abruptly canceled and rescheduled for several months later. As a result, nearly 900 cardiac patients were left without access to essential medical care. Cases like this signal that the United States is an unreliable destination for top talent and business investment, as employers have no idea if, or when, their employees may return to the United States.

DOS should course correct by prioritizing continuity for H-1B workers who are already working in the United States, such as information technology workers, healthcare professionals who work in underserved communities, financial experts, professors, or architects. It should align employment-based visa processing with labor market needs and public health realities. Additionally, DOS must enhance training and internal messaging and streamline policy implementation to reduce confusion and inconsistency among officers and posts. Rolling changes out in this way will allow DOS to ensure the integrity of the visa system, while minimizing their impact on U.S. businesses and families.

Restrictive Visa Processing Policies Burden Without Making America Safer

Restriction of Interview Waivers

Until September 2025, it had been long-standing DOS policy to waive NIV interviews for low-risk applicants, such as those who had previously been issued a visa, children, or the elderly. While the requirements for waiver eligibility varied, many administrations, including the first Trump Administration, agreed that interview waivers are an effective way to manage limited resources without impacting national security.

The change to interview waiver guidance for NIV applicants upset DOS’s long-standing practice of exempting children from in-person interviews, undermining efficiency without improving security. Interviewing children provides no meaningful security or adjudicatory value, diverts consular resources from high-risk cases, and worsens backlogs. Following these changes, the average visitor visa wait time rose by 95% between January 7, 2025, and November 20, 2025. Visa issuance has also decreased, with NIV issuance in May 2025 falling by 16% when compared to May 2024.

DOS Eliminates Third-Country National Visa Processing

Similarly, until August 2025, DOS permitted third-country national (TCN) visa processing, a policy that allowed individuals to apply for a visa at a consulate in a country where they had ties, even if they were not a citizen of that country. This policy eliminated unnecessary hurdles for individuals to apply for visas. DOS always retained the discretionary authority to refuse third country national processing for high-risk applicants.

The elimination of TCN interviews has created problems—in November 2025, AILA received reports that in Madrid, the policy is to not interview TCN family members even if the principal applicant is a Spanish citizen. DOS’s TCN interview policy has caused confusion, inconsistent application, and family separation without improving consular efficiency or national security. DOS should restore TCN interviews, not least to avoid the physical separation of families during the interview process. Processing families together will also allow consular officers to see the whole picture and assess any related security concerns.

Tailoring Interviews to Match Security Risks Would Streamline DOS Processing

Rather than eliminating policies that were designed to ensure efficiency and security in the visa process, DOS should reconsider eligibility criteria to determine when an applicant would be a low security risk and allow consular officers to exercise their discretion. If DOS wants to increase the number of interviews to address credible security risks, then such policies must be accompanied by additional consular officers to conduct these interviews. To address resourcing constraints, DOS should leverage technology—such as video interviews—to facilitate worldwide interviews and reinstate visa processing in the United States. Such solutions could ensure efficiency and protect security while restoring a semblance of order and predictability.

Travel Bans and Indefinite Visa Processing Pauses

In June 2025, Trump released a Presidential Proclamation fully or partially blocking nationals of 19 countries from entering the United States as immigrants and certain classifications of nonimmigrants. Six months later, President Trump expanded the travel ban to include nationals of 39 countries, again with a full and partial ban, depending on the country. The proclamation also fully restricts the entry of individuals travelling with documentation issued by the Palestinian Authority.

Further, as of January 21, 2026, DOS paused immigrant visa issuance for nationals of 75 countries pursuing permanent residency. Under this policy, consular officers apply a presumption of public charge ineligibility to applicants presenting passports from any of the designated countries. The government did not articulate a rationale for this change or present findings as to why these countries are deemed a high risk for public charge. Moreover, it disregards the fact that individuals who are coming permanently to the United States must already demonstrate that they have the means to support themselves through an affidavit of support. Further, it prevents close family members of United States citizens and legal permanent residents from reuniting with their loved ones and prevents employers from recruiting needed workers. This policy is causing family separation, widespread delays, and economic disruptions. In one case, a direct care provider from Sierra Leone who provided support to a family with an autistic son and a daughter with special needs has been banned from coming to the United States because of her nationality, leaving a U.S. family without necessary care. DOS should create clear guidance for the evidence that creates a public-charge risk consistent with the law, and standards for officer discretion to avoid bias or arbitrary outcomes.

DOS Layoffs and Internal Reorganization Exacerbate Processing Delays

In addition to the significant policy upheaval and backlogs in consular processing, DOS has overhauled and reduced its workforce, further exacerbating the strain on the immigration system. In July 2025, DOS laid off over 1300 of its employees, 246 of whom were foreign service officers. While Secretary Rubio pledged that layoffs would lead to efficiency improvements, the targeted bureaus—Population Refugees and Migration, Diplomatic Technology, and the Office of the Comptroller—are critical to the operation of the agency. The Bureau of Democracy, Human Rights, and Labor (DRL) was almost completely dismantled, which threatens core statutory obligations to champion internationally recognized human rights and directly contravenes congressional mandates such as protecting national security. Consular Affairs was also among the bureaus that suffered the highest cuts, leaving fewer personnel available to handle the implementation of expanded screening and vetting.

Further, in December 2025, the Administration recalled “nearly 30 ambassadors and other senior career diplomats to ensure embassies reflect its ‘America First’ priorities,” without advance notice or explanation. This highly unusual move further politicizes the Foreign Service and undermines morale at DOS, which is already extremely low. A 2025 American Foreign Service Association survey found that 98% of the 2,100 Foreign Service members surveyed reported poor morale, and 86% said their ability to advance U.S. diplomatic priorities has been hindered under the second Trump Administration.

Core areas of U.S. foreign policy have been damaged, with half of Foreign Service workers identifying that the capacity of public diplomacy and national safety initiatives have been especially weakened. With an eye toward facilitating secure and effective visa adjudication processing and serving U.S. citizens and foreign nationals, AILA cautions against further reductions in DOS’s workforce. A more effective path forward would elevate diplomacy and consular operations as strategic national security tools.

A Better Way Forward

To restore integrity to consular processing, AILA recommends that Congress urge the Department of State to take the following actions:

• Encourage transparency and accountability in executive actions through increased Congressional oversight, including through hearings and imposing reporting requirements.
• Seek public engagement and dialogue to better understand the pressure points of the existing systems and processes.
• Conduct impact studies prior to implementing new policies to avoid threats to the U.S. economy and other national interests.
• Enhance training and internal messaging to streamline policy implementation to reduce confusion and inconsistency across consular posts.
• Triage immigrant visa appointment requests by adjudicating the low-security risk cases more quickly while thoroughly vetting cases that present risk factors to reduce backlogs and maximize resources.
• Reinstate age-related interview waivers to focus on higher risk applicants.
• Accept that contrary viewpoints do not equate to clear security threats when analyzing visa applicants’ social media histories.
• Update public charge guidance with clear standards consistent with the law.
• Resume processing of employment-based immigrant visa applicants subject to the public charge pause.
• Reintroduce TCN interview processing to increase efficiency and allow officers to focus on real threats.
• Maintain DOS’s current workforce and reject reductions in force to ensure program integrity.

This non-exhaustive list of policy solutions is more than aspirational; these policies have a track record of facilitating successful and safe migration while serving the national interests and security of the United States. These recommendations can achieve the Administration’s national security goals while providing the level of service citizens, intending immigrants, visitors, and temporary workers previously experienced and should expect from the federal government, rather than separating families, disrupting communities, and threating long-term economic harm to our country.

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¹ The Department of State Strategic Plan for Fiscal Years 2026-2030 refers to President Trump’s foreign policy goal of dominance in the Western Hemisphere and establishes the “Donroe Doctrine” in Goal Two. www.state.gov/wp-content/uploads/2026/01/Agency-Strategic-Plan-for-Fiscal-Years-2026-2030.pdf.
² Countries like China, Canada, the United Kingdom, and South Korea have introduced or are exploring programs that will attract scientists, researchers, and other skilled workers to their countries instead of the United States. See https://www.aljazeera.com/news/2025/9/23/trumps-h-1b-visa-fee-hike-which-countries-could-benefit.
³ While disruption is evident, the full scale is not yet known as DOS has failed to timely publish visa issuance statistics and consular wait times. As of the date of this policy brief, the most recent NIV issuance statistics are from May 2025. The slow release of information obscures DOS’s operations and accountability from the public and hints at an agency that is not functioning as intended, it overwhelms consular officers, delays visa issuance, and undermines confidence in the immigration system.
⁴ During the 2023-2024 academic year, international students contributed nearly $44 billion to the U.S. economy and supported more than 378,000 American jobs.