A Message from Patrick Vogt: Continuing Initiatives and “Dear Colleague Letter”

April 4, 2023
Washington Monument

Tuesday, April 4, 2023

From: Patrick Vogt, CEO of API


Dear Valued Partners,

Academic Programs International’s (API) purpose is to provide high-quality experiences for students that foster intercultural understanding, personal development, and academic achievement. We are dedicated to supporting all students in achieving their academic and personal goals by providing them with immersive and culturally enriching experiences out of the classroom, and we have built our organization, advisory services, and technology to power increased access to experiential learning, with a focus on diversity, equity, and inclusion.

We’ve also launched the API Foundation, a 501(c)(3), non-profit corporation that supports students, colleges, and universities through research, dedicated funding for student scholarships, and legislative advocacy.

API’s legislative agenda is simple: support federal policies that will increase student participation in — and funding for — life-changing experiential learning and other high impact practices that drive better learning and career outcomes.

We have provided comments on behalf of students, colleges, and universities regarding The Senator Paul Simon Study Abroad Program Act, multiple pieces of proposed legislation that impact Pell Grants, and other areas of Title IV Federal Financial Aid, with the following consistent themes:

  1.  Increase Participation in & Access to Experiential Learning: We need to expand both the demographic profile and number of students participating in experiential learning (study abroad, internships, and other hands-on learning opportunities).
  2. Foster Intercultural Understanding: Exposure to different cultures is essential to building a more interconnected and peaceful world. By immersing students in different cultures, global learning experiences promote cross-cultural understanding and empathy.
  3. Enhance Personal and Professional Development: Studying abroad and experiential learning provides an opportunity for personal growth and professional development. Immersing students in new global contexts challenges them to grow and develop skills like independence, adaptability, and resilience, all of which are characteristics that also make them better interviewees and employees.
  4. Promote Academic Achievement: International learning opportunities enhance students’ academic achievement through high-quality academic courses that expand intellectual horizons. 

We have also provided our comments and opinion regarding the recent “Dear Colleague Letter” (DCL), which purports to provide guidance on prior legislation affecting our industry. We collaborated with our industry peers, associations, colleges, and universities in formulating an appropriate response.  Because the DCL has been an area of inquiry, we are also briefly addressing our thoughts on what this means for API’s continued fulfillment of its mission.

On February 15, the Department of Education issued the DCL with the intention of providing “guidance” on existing law affecting the requirements and responsibilities for third-party service providers and educational institutions providing experiential learning opportunities abroad.  While the DCL is not a new law or regulation, it purports to issue new guidelines based upon a broad interpretation of the reach of existing legislation. These more wide-ranging interpretations could impose novel obligations and restrictions upon institutions if not modified subsequent to the comment period, which recently ended on March 30th. The current effective date for compliance with the DCL guidance is September 1, 2023.  

As noted, API has been actively following the public response to the DCL and has submitted its own comments on behalf of our industry. Regardless of the implementation of the guidance in whatever form, API is well-positioned, and we will work closely with you all to ensure compliance, while continuing to expand our experiential learning services and technology. API has also joined the overwhelming majority of institutions who are critical of this legislative overreach, and the likely unintended consequences of the proposed guidance. Accordingly, we are awaiting the DOE’s response to the input and feedback and the expected modification of the DCL, prior to making any changes to our existing contractual relationships.  

While we do not take issue with the stated purpose of the DCL, which is to protect the interests of institutions, taxpayers, and students, the current guidance is antithetical to that purpose and should be revised to be more explicitly focused toward achieving its purpose. Everyone at API is anticipating the guidance to come, and continues to work to serve our college and university partners and students in compliance with the final guidance.  

API looks forward to continuing to deliver on its purpose: to provide students with transformative educational experiences that prepare them to be outstanding global citizens and leaders.

Please feel free to contact me or our API team if you have any questions or comments.

Best Regards,



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