The U.S. Department of Homeland Security’s (DHS) Student and Exchange Visitor Program (SEVP) recently issued official broadcast messages to Designated School Officials (DSOs) establishing a significantly narrower interpretation of Curricular Practical Training (CPT) eligibility under federal regulations (8 CFR § 214.2(f)(10)(i)).
Under this updated guidance, SEVP indicates that CPT should only be authorized when an internship or practical training experience is a mandatory graduation requirement for all students enrolled in that specific degree program. In response, major universities have initiated immediate freezes on new elective/optional CPT approvals while their legal counsel and academic leadership review the operational and legal implications.
| Student Status / Category | Immediate Status | Practical Impact & Guidance |
| Existing Approved CPT (Form I-20 already endorsed) | ACTIVE / VALID (No Immediate Disruption) | Students currently working under active Form I-20 with endorsed CPT authorization can continue working through their approved end date, provided they adhere to the employer, location, and conditions listed. |
| Mandatory Degree Practicums (Required for all students) | UNRESTRICTED (Fully Authorized) | Programs requiring practical experience as a non-negotiable degree completion requirement (e.g., clinical nursing, student teaching, accredited residencies) remain fully eligible for CPT. |
| Elective / Course-Credit CPT (Optional internships for credit) | PAUSED / AT RISK (Approvals Halted) | Universities are halting new CPT authorizations for elective internships (common in Business, Computer Science, and Engineering) pending institutional legal review. Pending requests will not be issued. |
Curricular Practical Training Interpretation Impact on Employers & Business Operations
- For current employees working on CPT, existing List A documentation (foreign passport, Form I-94, and endorsed Form I-20) remains valid through the expiration date specified on the I-20. However, employers cannot legally allow prospective interns to start based on an offer letter alone; students MUST present an updated Form I-20 endorsed for CPT prior to Day 1.
- Students who have accepted internship offers for upcoming terms (Fall, Spring, or Summer) but have not yet received an updated Form I-20 will face delayed start dates or offer cancellations if their universities maintain a pause on optional CPT.
- Employers planning to extend current interns beyond their existing Form I-20 end dates will be unable to process extensions through elective CPT while university holds remain active.
- Employers may need to evaluate Pre-Completion Optional Practical Training (OPT) as an alternative. However, Pre-Completion OPT requires direct USCIS adjudication (Form I-765), government filing fees, and 60-90+ days of processing time, which deducts directly from the student’s 12-month post-graduation OPT allotment.
Impact on International Students (F-1)
- Students enrolled in degree programs without a mandatory internship curriculum cannot engage in off-campus industry employment during their studies under standard elective course credit.
- Students who commence work without a newly issued, DSO-endorsed Form I-20 commit a severe status violation resulting in termination of SEVIS status, loss of lawful presence, and bar from future immigration benefits.
- To gain industry experience during academic breaks or concurrent with studies, students may be forced to utilize Pre-Completion OPT, thereby reducing the available 12-month post-completion OPT window upon graduation.
Recommended Client Action Plan & Next Steps
- Export and verify all current employees and interns authorized via CPT to confirm Form I-9 reverification dates. Flag any endorsements expiring within the next 30 to 60 days.
- Contact all prospective student hires immediately. Determine whether their school has authorized their Form I-20 or paused issuance, and adjust projected start dates accordingly.
- Under no circumstances should any student be allowed to perform work (including onboarding tasks or orientations) without a physical or verified Form I-20 with active CPT employment authorization.
- Engage with campus recruitment liaisons and international student offices at target universities to track school-specific policy resolutions.
Disclaimer: This blog post is for informational purposes only and does not constitute formal legal advice. Compliance decisions should be discussed with qualified immigration and employment counsel.
Vijay Thakkar has more than 12 years of HR Operations experience, including 8 years helping employers improve their Form I-9 management and E-Verify compliance, especially for mergers & acquisitions, internal and external I-9 audits, training and development, migration to the electronic system, I-9 escalations, quality checks, strategic planning, and building standard operating procedures with a keen interest in US immigration and global mobility.
Prior to joining Experian, Thakkar has served as Levi Strauss & Co’s I-9 subject matter expert, an investigator to the behavioral health unit at the US Army, and Sustainability Analyst at his alma mater the University of Texas at Arlington from where he earned his Master’s in Human Resource Management and MBA.
