DHS to Enforce Limits on Curricular Practical Training

In two new memos, one dated August 12 and the other August 24, to Student and Exchange Visitor Program (SEVP) Designated School Officers (DSO), the Department of Homeland Security (DHS) issued new guidance indicating that Curricular Practical Training (CPT) may no longer be approved for certain international undergraduate and graduate students. CPT allows international students on F-1 visas to participate in off-campus internships and other practical training related to their field of study. The new guidance could significantly limit internship opportunities for affected students.

The new guidelines do not change the underlying regulation but instead represent a stricter interpretation of the existing policy compared to previous years. Absent more extensive guidance, colleges and universities are working to comply with federal requirements around CPT approval, opting to review current programs and halting work authorizations for students on F-1 visas except in cases where the work is a degree requirement.

DHS has indicated that colleges and universities should be approving CPT and internship opportunities that represent “an integral part of an established curriculum” and not routinely approving these opportunities for majors and programs where an internship is not required for degree completion. The DHS memorandum specifies that CPT approvals for students completing programs without required internships could cause DSOs to face personal legal and administrative liability as well as the institution losing certification to enroll foreign students. 

Several organizations representing international students are considering a legal challenge to the guidance.

For more information, please contact:
Karin Johns