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B-234667.5 1 (1992-07-08)

handle is hein.gao/gaobadqla0001 and id is 1 raw text is: 



             United States              Document Control
GAO          General Accounting Office  Room 6536
             Washington, D.C. 20548

             Office of the General Counsel

             B-234667.5

             July 8, 1992

             Jon W. Van Horne, Esq.
             McDermott, Will & Emery
             1850 K Street, N.W., Suite 500
             Washington, D.C. 20006

             Dear Mr. Van Horne:

             This concerns your May 3, 1991, submission in which you take
             issue with several legal conclusions in our February 1990
             report: Inappropriate Uses of Educational and Cultural
             Exchange Visas, GAO\NSIAD-90-61 (J-visa report). You state
             that the United States Information Agency (USIA) has been
             relying on these legal conclusions in a manner that
             prevents, for example, representatives of the newly
             established Young Men's Christian Associations (YMCA) of
             Eastern Europe from entering the United States under J-visas
             to train in various YMCA activities. We appreciate your
             comments and position. Nevertheless, after carefully
             considering your arguments, we believe the legal conclusions
             expressed in our report are correct.

             The J-visa report was prepared under section 555 of the
             Foreign Operations, Export Financing, and Related Programs
             Appropriations Act, 1989, Public Law 100-461, 102 Stat.
             2268-37, which required the General Accounting Office (GAO)
             to report on whether participant activities under the J-visa
             program were consistent with the congressional intent of the
             J-visa legislation. In your submission you contest GAO's
             conclusion that certain activities and programs under the
             J-visa program in the trainee and the international visitor
             categories,' specifically the summer student travel work
             and international camp counselor programs, are inconsistent
             with the intent of the legislation establishing the J-visa.

             At the outset, we should point out that our conclusions
             about the programs described were general. Participant
             activities varied greatly and we could not evaluate each
             specific program. Your specific comments on the YMCA
             programs therefore are more appropriately addressed to the
             USIA than to GAO.




             'The international visitor category, which was established
             by regulation, included the summer student travel/work,
             international camp counselor and Au Pair programs.

                          FILE   r i -     u i

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