FN20.   The reason the Rule adopts the exemption for institutions of higher learning permitting them to avoid having to E-Verify all new hires is because of the large number of students with intermittent employment.  The preamble to the Rule states: “The Councils recognize that coverage of a large number of educational institutions was not anticipated in the proposed rule.  These entities have a large number of students with intermittent employment, which may complicate these institutions’ efforts to comply with E-Verify requirements.”  FAR Case 2007-013, Employment Eligibility Verification, 73 Fed. Reg. at 67,682.