Curricular Practical Training CPT

3 years ago By Rajiv S. Khanna 52 comments

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Some F-1 students are eligible for practical training. There are two types of F-1 practical training:

Curricular Practical Training (CPT); and
Optional Practical Training (OPT).

Type of Practical Training	Comparative Points to Note
Curricular Practical Training (CPT)	Training relates directly to the student’s major area of study. Training is an integral part of the school’s established curriculum. Designated school official (DSO) authorized CPT in SEVIS and the authorization prints on the student’s Form I-20. *Occurs before* the student’s program end date on the Form I-20. Authorization is for one specific employer and for a specific period of time. Students must secure the training opportunity before CPT can be authorized. CPT must be authorized before the student can begin work. Students can have more than one CPT authorization at the same time. One year of full-time CPT eliminates a student’s eligibility for OPT.**
Optional Practical Training (OPT)	Training relates directly to the student’s major area of study. DSO recommends OPT in SEVIS. A student does not have to secure training before the DSO can recommend OPT. Authorized by the U.S. Citizenship and Immigration Service (USCIS), and the student is issued an Employment Authorization Document (EAD). Allows the student to work for any employer, as long as the training relates to the student’s major course of study Can occur before or after the student’s program end date. Periods of OPT cannot overlap. Students are eligible for an additional 12 months of OPT authorization when they change to a higher educational level.

Type of Practical Training

Comparative Points to Note

Curricular Practical Training (CPT)

Training relates directly to the student’s major area of study.
Training is an integral part of the school’s established curriculum.
Designated school official (DSO) authorized CPT in SEVIS and the authorization prints on the student’s Form I-20.
Occurs before the student’s program end date on the Form I-20.
Authorization is for one specific employer and for a specific period of time.
Students must secure the training opportunity before CPT can be authorized.
CPT must be authorized before the student can begin work.
Students can have more than one CPT authorization at the same time.
One year of full-time CPT eliminates a student’s eligibility for OPT.

Optional Practical Training (OPT)

Training relates directly to the student’s major area of study.
DSO recommends OPT in SEVIS.
A student does not have to secure training before the DSO can recommend OPT.
Authorized by the U.S. Citizenship and Immigration Service (USCIS), and the student is issued an Employment Authorization Document (EAD).
Allows the student to work for any employer, as long as the training relates to the student’s major course of study
Can occur before or after the student’s program end date.
Periods of OPT cannot overlap.
Students are eligible for an additional 12 months of OPT authorization when they change to a higher educational level.

Curricular Practical Training (CPT)

1. Complex rules apply to CPT because the training opportunity must comply with both:

Federal regulations
8 CFR 214.2(f)(10)-(12)
8 CFR 274a.12(b)(6)(iv)
School policies regarding internships, experiential learning, etc.

2. The CPT must comply with the following regulatory requirements:

The student is enrolled at a SEVP-certified college, university, conservatory, or seminary and has been lawfully enrolled on a full-time basis for at least a full academic year (exception - day one CPT below)
The student is not studying English as a second language.
The student has secured a training position.
CPT is integral to the student's major and the experience must be part of their program of study. This can be demonstrated through the school's standard brochures, website narratives, course descriptions, etc.
The DSO will provide the student a new Form I-120 that shows the DSO has approved the CPT employment.
Students can work on CPT either full-time or part-time.
CPT requires a signed cooperative agreement or a letter from the employer. This is typically a one-page document asserting the employer's understanding that the training is for college credits and that they will ensure that the student works in an area related to the education.
If the student engages in 12 months or more of full-time CPT, they are ineligible for OPT, but part-time CPT is fine and will not stop the OPT.

3. Day one CPT:

A student can get CPT as soon as they join the program ("day one CPT"), if in addition to the requirements for CPT stated above, they enroll at the graduate level and the program requires this type of experience for graduation. 

CPT authorization is only required when the training is inside the United States. For example, a summer internship in a student’s home country does not need CPT authorization.

CPT PROCESS OVERVIEW

step	Player	Action
1	Student	Requests CPT using the school’s established processes.
2	DSO	Reviews request and determines student’s eligibility for CPT.
3	DSO	Authorizes CPT in SEVIS for a specific employer. Prints and signs Form I-20 with CPT authorization.
4	Student	Begins work on or after the CPT start date. Note: The student cannot start work prior to the start date. All work must end by the CPT end date.

FAQ From ICE

Q: May a school authorize a student to participate in CPT instead of OPT?
A: No, CPT and OPT are not interchangeable. CPT accommodates individuals enrolled in a program
of study that requires participation in an internship or practicum. It is not a supplemental training
experience but rather an “integral part of an established curriculum” meaning it is a required part
of the degree or program of study. The regulation makes this clear by defining CPT as an
“internship, cooperative education or any other type of required internship or practicum….” In
contrast, OPT accommodates students who have fulfilled the requirements of an academic or
vocational program and provides an opportunity to augment the student’s learning with real-world
experience

Q: May a student participate in CPT related to the student’s minor or general graduation
requirements?
A: Federal regulations require CPT to be directly related to a student’s major area of study. This
means CPT cannot be authorized based on a student’s minor or general graduation credits. CPT
participation may only be approved if the training opportunity is directly related to the major
program of study.

Q: Does a student need to receive authorization from U.S. Citizenship and Immigration
Services (USCIS) to participate in CPT?
A: No; however, a student’s DSO must authorize CPT in SEVIS. Please note that SEVIS will not allow
DSOs to backdate the authorization.

Q: Can a student begin participating in CPT while waiting on their school official to authorize
the training in SEVIS?
A: No; a student’s DSO must authorize the student’s CPT in SEVIS before the student can
participate. Participating in practical training without the necessary authorization could violate the
student’s status.

Q: Can a student have more than one CPT authorization at the same time?
A: Yes; however, a separate CPT authorization is needed for each employer and each CPT segment

Sources:
https://www.ice.gov/sevis/practical-training
https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-stud…;
https://www.ice.gov/sites/default/files/documents/Fact%20sheet/2019/Cur…

Jump to Can CPT be a good way to gain experience in addition to or instead of H-1B?

Nonimmigrant Visas

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Note: Unless the context shows otherwise, all answers here were provided by Rajiv and were compiled and reported by our editorial team from comments, blog and community calls on immigration.com. Where transcribed from audio/video, a verbatim transcript is provided. Therefore, it may not conform to the written grammatical or syntactical form.

Using CPT while awaiting OPT EAD

Can a student on F1 continue working on cpt till the opt ead card is obtained

The work under CPT would be…

The work under CPT would be allowed only if the student is attending classes full-time and meets other requirements set by their school.

Full Time Job during Day 1 CPT

Having completed my 1st Non STEM Master, I opted for day 1 CPT program in a STEM course after my EAD expired for the 1st Master's OPT. Am I legally eligible to get hired for full time roles and can the company file for my H1B ?

If your approved CPT allows…

If your approved CPT allows for full-time training, you can certainly work full-time. As to the complications created by the government in giving you status, I have posted links to that small entry in my blogs. We will also discuss it during the community conference call on Saturday, May 22, at 9 AM EST. Call 202 – 800 – 8394.

Day 1 CPT after STEM OPT Completion

Q1. I am F1 STEM OPT student,my all 3 attempts are exhausted. During my 2 years of Masters i have done 1CPT for 2 months. Can I enroll for Day1 CPT Master's again or I have to only option for DAY1 Phd/MBA CPT?

Q2.If I do Day1 CPT, Can i apply for H1-B application for that year, if application gets picked then Change of status from USCIS F1 to H1B For Day 1 CPT candidate is legal or illegal?

These questions require some…

These questions require some discussion. Remember to bring them up in our community conference call on Saturday. I will explain.

Hi Rajiv, There have been…

Hi Rajiv, There have been instances where the students got the 1-20 changed.. but never joined the client on the date.. What will be the employer responsibility in these instances. How to safeguard employer interests?

Employers responsibility for CPT students

The entire responsibility of the employer should be summed up in the cooperative agreement they have signed with the University.

Interestingly, there is no strict format for a cooperative agreement. Each University has developed its own. See, for instance, the last two pages of this sample cooperative agreement:

https://www.colorado.edu/isss/sites/default/files/attached-files/cptagr…

DAY 1 CPT

Hello Rajiv ji,

I am quite skeptic about this Day 1 CPT, not sure whether its legitimate?

Will it have an impact if H1-B gets picked in future? Can a person travel aboard and come back without any immigration hassle b enrolling in this DAY 1 CPT.

I see only handful of universities give this Day 1 CPT option.

Let me know your thoughts on this if possible. Thank you for the support.

CPT Impact on H-1B

See this link https://www.immigration.com/blogs/h-1b-and-cpt

Part time CPT

What is the difference between part-time and full-time CPT?

Full time, Part Time CPT

I was asked this question during a call today. Here is the answer.

Part-Time or Full-Time CPT
Part-time CPT: Employment for 20 hours or less per week is considered part-time.

Full-time CPT: Employment for more than 20 hours per week is full-time. Under the regs 12 months or more of full-time CPT takes your eligibility for OPT. To continue your CPT, you must be enrolled full-time or have an approved Reduced Course Load (RCL) from your DSO.

Day 1 CPT F1 - Renewal

Hello Sir,

My wife is on Day-1 CPT and went for F1 renewal , without asking much question she got 214B denial. So there is an option to re-apply, do you think we should apply again and produce document which shows she got tie ups in home country ?

You can try. 214(b) denials…

You can try. 214(b) denials are difficult to overcome and highly unpredicable.

L1-B to F1

Hello Mr. Rajiv,

My L1-B visa is about to expire in March 2022. And, I am looking forward to filing for an H1 visa next year. Can I change my status to student visa F1 and continue working through day-1 CPT till the time I get my H1 approved?

Day 1 CPT

You must have a genuine intent to study. We also have a detailed article on CP, OPT in our blogs.

Can CPT student apply for GC without going to H1B

Hi Sir,

I wanted to understand ease of getting GC directly after CPT without H1B. Is that possible?

Since I am not from India, I also have the possibility of applying for Electronic Diversity Visa (EDV). If picked for EDV, would being in CPT be an issue during EDV interview? Wondering since continuously remaining in CPT might potentially suggest violation of non-immigrant status.

Please suggest. Appreciate your help!

Applying for a green card while on student (F-1) status

I have discussed the issue of applying for a green card while on the student status in detail both on my blog and my author page in The Economic Times: https://economictimes.indiatimes.com/nri/migrate/can-student-visa-holde…

Part time CPT

I'm a master's student and I'm in my last semester. I have done 11 and half months of full-time CPT and was wanted to know can I do part-time CPT during my last Semester without affecting my OPT period and H1B probability? Thank you!

Part time CPT

As far as I know, curricular practical training is not deducted from optional practical training.

Day1 CPT to H1B

Hi Rajiv

I have joined my grad school in Jan 2022, I am on Day1 CPT, can I apply for H1B this year?

Please suggest. Appreciate your help!

Day1 CPT to H1B

Legally, you can. Make sure that you discuss with your lawyers whether there is a problem with your intention to be a student.

Using CPT for Non internship position

I am currently an F1 student and have secured a full-time position (non-internship). Title - Senior Security Engineer. I am currently pursuing my master's degree in Cybersecurity and would graduate by next year. I wanted to know if I can join the company over the summer on CPT? Or is it that CPT is strictly only for internships?

Using CPT for Non internship position

CPT can be used for any job in your field of study. Make sure your DSO has no issues with the job.

Using CPT for Non internship position

Hi, Mihir

I have the same doubt, did your school DSO allow you to work on CPT for a non-intern position? Please do let me know.

Thank you, Dhaval Hirpara

Day1 CPT with Online Graduate Program

Hi Sir, I am living and working in the U.S. with my STEM EAD about to expire in a few months. I am looking at some Day1 CPT options. Is it permissible to enroll in an online graduate course from a reputed U.S. university directly related to my field of work and still avail the day1 CPT? Or does it have to be an in-person/hybrid type of program?

Day1 CPT with Online Graduate Program

As far as I know, you can only take a certain number of credits online. Some exceptions have been made during the Covid times, but I do not know how long they will last.

Day 1 CPT

Hello Sir, Currently I am on OPT and it's about to expire in June and I am planning to enroll in Day 1 CPT. So, is it compulsory to have a job if you want to enroll in Day 1 CPT course? Or one can find the job once CPT/course starts?

Day 1 CPT

Your employer would need to sign a cooperative agreement with your university. You will need to identify an employer. I do not see how you can file without having a specific training opportunity/job.

Part time CPT along with On campus job

I am on my F1 visa and enrolled in full-time studies. I have a part-time job offer (20 hours per week) and an on-campus job (20 hours per week) for the next semester. Can I do both at the same time?

I asked my university's international student services, and they said it should be okay. They said, "Part-time CPT and On-campus job are different authorizations, and there is no official guideline that you can't do both together."

But I am a little skeptical about it as I would be working 40 hours (20 hrs part-time CPT and 20 hrs On-campus) as a full-time student. I just want to ensure I don't violate any laws by doing both jobs simultaneously.

Part time CPT along with On campus job

I think the university is correct, but I haven't specifically researched this issue.

Is there something I can do…

Is there something I can do to be sure about this? Should I be talking to an immigration lawyer?

Consultation

Start with this website https://studyinthestates.dhs.gov/

CPT

I have completed my MS from US and used my 1 year OPT (Non Stem program). I am going to pursue full-time MBA on F1 again, and wanted to know if I can use CPT again for the second masters after one academic year? My program requires a summer internship.

CPT after OPT

You can use CPT.

Change of status

Previously I was on H1B and now changed it to F1 after coming to India for stamping required for full-time MBA. Do I need any specific documents apart from I 20 and school docs, when I enter the US on F1 now for the first time? Or is it just like any other F1 student?

Your help is appreciated!

Entry into US after Change of status

When you enter the US on an F-1 visa, the documents required for entry are the same as those for any F-1 student.

CPT and self-employment

Hello Sir, thanks for your informational website and videos. My question is that are there any legal restrictions to being self-employed while on CPT. The ICE language seems to be clear with regards to its permissibility while on OPT. Can I start my own private practice related to my field of study and work for the practice by registering it on CPT? Are there any evidences for either a Yes or No. I am unable to find an answer in either direction.

CPT and self-employment

I doubt very much you can be self-employed on CPT.

Day 1 CPT

I have done my bachelors in a STEM course here in USA and exhausted all 3 H1-B attempts. Currently on STEM OPT and planning to go on Day 1 CPT to do masters in STEM course. 1. Do I have to go to Part-Time CPT after 1 year of Full-time CPT? 2. Do I get OPT and STEM OPT extension after completion of my masters?

Disclaimer

This answer is for information purposes only and does not create an attorney-client relationship.