The Department of Homeland Security (DHS) has proposed charging international students $100 for mandatory registration in a national tracking database, vastly exceeding expected fees and eliciting sharp responses from many institutions.

But in the immediate wake of the proposal, which became available Monday, Harvard has not taken issue with the DHS’s recommendation. The University instead plans to explore the proposal’s logistic implications and wait to see how its peers react before deciding how to respond to the governmental recommendation, officials say.

The DHS’s proposal levies a fee for most non-immigrant students—a step international officials have been expecting, according to Senior Director of Federal and State Relations Kevin Casey.

“We’ve been anticipating this for quite some time,” Casey said Monday. “I guess we’re kind of grateful that it wasn’t established during the period when classes started.”

But since word of the DHS’s proposal escaped—first by rumor, then in print—several administrators at other institutions have condemned the one-time $100 fee as excessive.

The DHS’s proposed figure, which international students would pay in addition to greater visa processing fees, exceeds both the $95 Congress recommended as a reasonable upper limit for the charge and the $54 fee projected as sufficient by KPMG Consulting, an independent consulting firm that the DHS hired a year ago. The firm devised its figure from consideration of the nearly $40 million that the USA Patriot Act allotted toward the creation of a tracking databases.

The governmental agency has said that the KPMG report did not take all necessary considerations into account in calculating the $54 figure, according to Sharon R. Ladd, director of the Harvard International Office (HIO). Proceeds from the charges will be used to fund SEVIS, a year-old national database that tracks personal data and academic information about non-immigrants presently studying in the U.S. on student visas.

The database, established by Congressional decision in the wake of Sept. 11 and maintained by the DHS, requires institutions ranging from research universities to trade schools to update their students’ records in the database themselves whenever circumstances change—even, in certain cases, if a student drops a class.

The SEVIS fee, which loomed as a possibility even before the database became active, comes as the result of the 1996 Illegal Immigration Reform and Immigrant Responsibility Act, which stipulates that such a database should be funded in part by fees rather than solely by government appropriation.

The agency will use income from the fees, expected to total about $30 million, to maintain the database and hire new officers to ensure compliance with its demands, explained Monday’s proposal.

The proposal also establishes a commenting period, extending through Dec. 26, during which school administrators can provide feedback on its merits.

As of today, Harvard’s response remains undefined.

“In order for us to evaluate how we’re going to respond, we need a little more information,” Ladd said.

Much of the HIO’s hesitation stems from uncertainty about the practical implications of different payment methods the proposal defines, she said. DHS allows international students to pay by mail or online with a credit card. While Ladd said she does not expect problems with the latter method, paper submissions of the fee will require a money order and time for processing, potentially yield a higher margin of error and ultimately make the process more difficult for students.

“We need to get a little more input about how difficult this is for students who do not have credit cards, because not everyone has that opportunity,” she said.

And for some students, an extra $100 to an already costly registration process could pose a financial burden. The Harvard College Financial Aid Office had not heard about the DHS’s proposal as of yesterday afternoon, but Associate Director of Financial Aid Janet Irons said she expected the new fee will be compensated through the College’s financial aid program if it proves a burden for the University’s international undergraduates. Official financial aid policy—which presently does not compensate visa fees—will emerge from discussion within the department, she said.

Ladd and her colleagues are also waiting to see what action Harvard’s peer institutions will take. The University belongs to the Association of International Educators, a coalition of colleges and universities serving as a forum for discussion of international student issues and a public voice on the topic.

Casey, who lobbies in Washington, D.C., in consultation with Ladd, said he plans to work with several similar associations to which the University belongs, reporting back to the government as soon as a consensus emerges on the DHS’s proposed fee.

“Normally on something like this we work with the administrations as a community,” he said.

—Staff writer Nathan J. Heller can be reached at heller@fas.harvard.edu.