Transcript Curricular Practical Training

Curricular Practical
Training
Agenda
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CPT Regulations & Guidance
Who qualifies for CPT
Creating an institutional policy
Scenarios & Emailed Questions
Additional Questions
What is Curricular Practical
Training (CPT)
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CPT is a type of employment
authorization that allows
qualified F-1 students to gain
practical experience in their field
of study while making progress
towards the completion of their
academic program
Code of Federal Regulations
8 CFR § 214.2(f)
214.2(f)(10)(i) Curricular practical training
An F-1 student may be authorized by the DSO to participate in a
curricular practical training program that is an integral part
of an established curriculum. Curricular practical training is
defined to be alternative work/study, internship, cooperative
education, or any other type of required internship or
practicum that is offered by sponsoring employers through
cooperative agreements with the school.
Students who have received one year or more of full time
curricular practical training are ineligible for postcompletion academic training.
Exceptions to the one academic year requirement are
provided for students enrolled in graduate studies that
require immediate participation in curricular practical
training.
A request for authorization for curricular practical training must
be made to the DSO. A student may begin curricular
practical training only after receiving his or her Form I-20
with the DSO endorsement.
Additional Guidance
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INS Memo CO 214.2F-C, 5/4/92
reported in Interpreter Releases,
Vol. 69, No. 6, p.587
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“When offered through course
work, curricular training must be
either for credit (in the case of an
elective course) or required.”
Further Guidance
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INS Memo CO 243.69-C,
1/22/92 reported in Interpreter
Releases, Vol. 69, No. 6, pp.
187-188
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“The training program must be
listed in the school’s course
catalog with the assigned number
of credits and the name of the
faculty member teaching the
course clearly indicated.”
“Integral Part of an
Established Curriculum”
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Degree requirement CPT – graduation
requirement for all students in the degree
program (may not carry units)
Co-op CPT – pre-existing relationship
between school & employer, credit not
necessary, not required of all students
Course credit – a required or elective
internship/practicum within a degree
program
Regulations:
Who Qualifies for CPT?
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An F-1 student with a job offer that is
directly related to student’s field of
study
F-1 student in status for at least 1
academic year, excluding those at
language schools
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From 214.2(f)(10)(i): “Exceptions to the
one academic year requirement are
provided for students enrolled in
graduate studies that require immediate
participation in curricular practical
training.”
Regulations:
Limits of CPT
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CPT is not available once a
student completes the degree
12 months of full time CPT will
eliminate OPT at the same
degree level
Student must obtain CPT
authorization prior to start date
The Balancing Act – How to
establish an institutional policy
Spirit of the law
Faculty
Demands
Documentation
Institutional
Structure
Campus policy
on external
employment
Professional
Enrichment
F-1 Regulations
Academic
Necessity
What Institutional Policy Can
Determine
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Limits on Part Time/Full Time*
Definition of “enrolled”*
Start/End Date – must they
correspond with enrollment?*
Minimum GPA (if any)
Legitimacy of work-credit relationship
Number of credits earned
Number of times a student can use
CPT
Establishing Policy
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Consult with university legal counsel
Establish a policy and document it
Apply it consistently
Maintain application materials to
document a “good faith” effort:
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Academic Advisors recommendation
letter
Job offer letter (optional)
Proof of course enrollment (optional)
Make the Academic Advisor
Work for You!
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The academic advisor can attest to:
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Relevance of the work to the major and
to the level
Number of credits awarded for work
Whether the internship will count
towards a student’s degree program
Exceptions necessitated by academic
requirements
CPT Recommendation: A Joint
Process
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The academic advisor within a
credit-granting unit evaluates the
internship and determines whether it
is “directly related to the student's
major area of study”
International Student Adviser
recommends CPT in SEVIS based
on academic advisor’s
recommendation.
Application materials: Make it
easy and accessible
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Create a fillable form to collect
all data, signature, & comments
Use a form letter
Create a handout for distribution
in office
Put all materials online so
students, faculty, advisors, and
employers can have access
CPT questions submitted
via email
Scenario 1: Question
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An undergraduate student
majoring in Liberal Arts wants to
work in a paternity testing lab.
How does the DSO determine if
this work is applicable to the
major and eligible for CPT?
Does the course need to
correspond with the work?
Scenario 1: From the
Regulations
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Has the academic advisor
recommend this internship as an
integral part of the degree
program?
Will the student use coop or
course credit CPT?
Scenario 1: From the
Institution
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Have you established a start
date/end date policy for course
credit and coop CPT?
Does this employer & the
university have a coop
relationship?
Scenario 2: Question
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Do the authorized number of
hours/week need to correlate with
the number of units offered? For
example, you know that 1-unit
internship class only requires 5
hours of work per week but the
employer letter indicates that the
student will work up to 20 hours per
week.
Should you approve this CPT
request?
Scenario 2: From the
Regulations
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SEVIS offers two types of CPT
recommendations
Part Time: 20 hours or less per
week
 Full Time: More than 20 hours per
week
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Due to SEVIS functionality, you
cannot restrict students any
further in hours per week.
Scenario 2: From the
Institution
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The institution can set a part
time/full time policy based on
semester vs. summer CPT
As an institution, do you require
or want to evaluate job offer
letters?
Job offer letters could be
evaluated by the academic
advisor
Scenario 3: Question
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The DSO was not aware of the
CPT request until after the start
of a internship. Is it a problem
to enter the authorization in
SEVIS after the term starts?
Functionally, SEVIS allows you
to put a past start date.
Scenario 3: From the
Regulations
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214.2(f)(10)(i): A student may
begin curricular practical training
only after receiving his or her
Form I-20 with the DSO
endorsement.
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214.2(f)(10)(i)(B): The DSO must
sign, date, and return the SEVIS
Form I-20 to the student prior to the
student's commencement of
employment.
Scenario 3: From the
Institution
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Clearly indicate this rule –
everywhere!
Remind students to factor in
document turn around time
Work done prior to CPT is
unauthorized employment
If DSO error: contact SEVIS
Help Desk or document in
SEVIS RTI.
CPT Frequency and Duration
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Students can be authorized for CPT
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For a 2nd degree at the same degree
level
For a higher degree level
For a lower degree level
CPT can be authorized FT or PT
according to the regs
Reminder: 12 months of FT CPT at
any one degree level will eliminate
OPT at the same level
Does CPT period need to
correspond with course?
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How will grade be assigned if
internship takes place later?
Are there periods in the year where
classes aren’t offered?
Example from Berkeley
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CPT must fall within dates of course
enrollment
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Extension into winter based on academic
exceptions because no credit is available.
CPT available throughout summer with
enrollment in 1 summer session course
Can students work on campus
and get CPT?
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On Campus Employment
Incidental to status
 20 hours/week during semester
 214.2(f)(9)(i)
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Limits on campus employment
do not impact CPT hours/week
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20hrs on campus & 20hrs CPT = OK
20hrs on campus & 40hrs CPT = OK
Unpaid Internship: Do I Need
CPT?
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To protect the student, he or she
should get CPT if there will be
any compensation in exchange
for the work:
Pay
 Food
 Other perks
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Questions for the employer
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Employer-intern relationship:
consultant, direct hire, intern,
etc.
Social security/Medicare tax
withholdings
I-9 required?