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The Student and Exchange Visitor Program (SEVP), under U.S. Immigration and Customs Enforcement (ICE), is reminding schools and Designated School Officials (DSOs) of their responsibilities when authorizing Curricular Practical Training (CPT) for F-1 students.
SEVP says it has observed an increase in CPT authorizations that do not meet regulatory requirements, particularly when the training is not truly an integral part of an established curriculum. In response, SEVP is increasing its scrutiny of CPT approvals and reminding schools that improper authorization may carry consequences for both the institution and the individual DSO.
For schools, DSOs, students, and employers involved in CPT, the message reinforces an important point: CPT is an academic benefit tied to a student’s curriculum, not simply an opportunity for employment.
What Is Curricular Practical Training?
Curricular Practical Training allows eligible F-1 students to participate in certain employment, internships, cooperative education programs, or other practical training experiences that are directly related to their major area of study.
However, being related to a student’s field of study alone is not enough.
SEVP emphasizes that CPT must be an integral part of an established curriculum. It cannot be authorized solely because a student wants to gain work experience or because an employment opportunity is related to the student’s major.
What Does “Integral to the Curriculum” Mean?
This is one of the most important points in SEVP’s reminder.
According to SEVP, DSOs should only authorize CPT when the practical training is truly necessary to the student’s academic program. SEVP’s guidance states that CPT should be authorized when the absence of that training would make completion of the degree impossible and when the associated work is required for all students pursuing that degree.
Schools determine their own academic requirements, but SEVP may request documentation and other evidence to evaluate whether CPT is genuinely a core and essential part of a student’s studies.
This means schools and DSOs should be prepared to demonstrate the academic basis for each CPT authorization.
SEVP Is Increasing Oversight
SEVP has indicated that it may investigate schools when it suspects CPT is being used primarily to create employment opportunities rather than to support legitimate academic requirements.
If SEVP believes a school is attempting to bypass federal regulations or improperly use CPT, the school may face additional scrutiny from SEVP and Homeland Security Investigations (HSI).
In serious cases, this could include potential withdrawal of the school’s SEVP certification.
DSOs Have Individual Responsibilities
The reminder also emphasizes the responsibility of individual Designated School Officials.
When a DSO signs or re-signs Form I-20, Certificate of Eligibility for Nonimmigrant Student Status, to authorize CPT, the DSO is certifying under penalty of perjury that the information provided is true and correct to the best of their knowledge.
That certification includes confirming that the CPT is required or otherwise integral to the student’s curriculum.
As a result, improperly authorizing CPT may create consequences not only for the institution but also for the individual DSO responsible for the authorization.
What Are the Potential Consequences of Improper CPT Authorization?
Improper CPT authorization may expose schools and DSOs to administrative or legal consequences.
Depending on the circumstances, these may include:
- Increased SEVP scrutiny or investigation
- Withdrawal of a school’s SEVP certification
- Potential penalties involving false information or misrepresentation
- Further review by Homeland Security Investigations
Improper CPT authorization may also create immigration complications for the F-1 student involved, making careful review important for everyone participating in the process.
What Should Schools and DSOs Do Now?
SEVP is encouraging DSOs and institutions to review both individual CPT requests and their broader academic requirements.
Schools and DSOs should:
- Carefully review CPT requests before authorization
- Confirm that the training is genuinely integral to the academic program
- Review academic requirements across fields of study to ensure CPT practices comply with federal requirements
- Maintain thorough documentation supporting the curricular necessity of each CPT authorization
- Consult an SEVP field representative when questions arise about a particular case
Schools should also consider reviewing their existing CPT policies and procedures to ensure their practices accurately reflect the academic purpose of the program.
What Does This Mean for F-1 Students and Employers?
Although SEVP’s reminder places significant emphasis on schools and DSOs, students and employers should also understand the increased scrutiny.
F-1 students should not assume that employment qualifies for CPT simply because the position relates to their major. The training must satisfy the applicable CPT requirements and be properly authorized before employment begins.
Employers working with F-1 students may also want to ensure that the student’s CPT authorization appropriately covers the employment before the student begins working.
Key Takeaway
SEVP’s increased scrutiny of CPT authorizations reinforces that Curricular Practical Training must have a legitimate academic purpose and be integral to an established curriculum.
Schools and DSOs should be prepared to document why CPT is academically necessary, while F-1 students and employers should understand that CPT cannot be used simply as a pathway to employment.
This SEVP broadcast message is a compliance reminder rather than a new rule or final agency action, but it signals increased attention to how CPT is being authorized and used.
Frequently Asked Questions:
- What is Curricular Practical Training (CPT)?
CPT is a form of practical training available to eligible F-1 students when the training is directly related to their major and is an integral part of an established curriculum.
- Can CPT be authorized simply because a job is related to a student’s major?
No. A connection to the student’s major alone is not sufficient. The training must also satisfy the requirements for being an integral part of the student’s established curriculum.
- Why is SEVP increasing scrutiny of CPT authorizations?
SEVP says it has observed an increase in CPT authorizations that do not meet regulatory requirements, particularly when training is not integral to an established curriculum.
- Can SEVP ask a school to provide evidence supporting CPT authorization?
Yes. SEVP may request documentation and other evidence to determine whether the CPT is genuinely a core and essential part of the student’s academic program.
- Can a DSO face consequences for improperly authorizing CPT?
- Is SEVP’s CPT reminder a new rule?
If you have questions about Curricular Practical Training, F-1 student employment, or how these requirements may affect your school, organization, or immigration status, you may schedule a consultation with the Law Office of Jacqueline Lentini, LLC by calling 630-262-1435 or emailing jacki@lentinivisas.com.