Curricular Practical Training

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Curricular Practical Training
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Agenda

• CPT Regulations Guidance
• Who qualifies for CPT
• Creating an institutional policy
• Scenarios Emailed Questions
• Additional Questions

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What is Curricular Practical Training (CPT)

• 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

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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 post-completion 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.

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Additional Guidance

• INS Memo CO 214.2F-C, 5/4/92 reported in
  Interpreter Releases, Vol. 69, No. 6, p.587
• When offered through course work, curricular
  training must be either for credit (in the case
  of an elective course) or required.

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Further Guidance

• INS Memo CO 243.69-C, 1/22/92 reported in
  Interpreter Releases, Vol. 69, No. 6, pp. 187-188
• The training program must be listed in the
  schools course catalog with the assigned number
  of credits and the name of the faculty member
  teaching the course clearly indicated.

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Integral Part of an Established Curriculum

• 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

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RegulationsWho Qualifies for CPT?

• An F-1 student with a job offer that is directly
  related to students field of study
• F-1 student in status for at least 1 academic
  year, excluding those at language schools
• 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.

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RegulationsLimits of CPT

• 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

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The Balancing Act How to establish an
institutional policy
Faculty Demands
Spirit of the law
Institutional Structure
Documentation
Campus policy on external employment
Professional Enrichment
Academic Necessity
F-1 Regulations
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What Institutional Policy Can Determine

• 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

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Establishing Policy

• Consult with university legal counsel
• Establish a policy and document it
• Apply it consistently
• Maintain application materials to document a
  good faith effort
• Academic Advisors recommendation letter
• Job offer letter (optional)
• Proof of course enrollment (optional)

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Make the Academic Advisor Work for You!

• The academic advisor can attest to
• Relevance of the work to the major and to the
  level
• Number of credits awarded for work
• Whether the internship will count towards a
  students degree program
• Exceptions necessitated by academic requirements

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CPT Recommendation A Joint Process

• 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 advisors recommendation.

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Application materials Make it easy and accessible

• 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

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• CPT questions submitted
• via email

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Scenario 1 Question

• 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?

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Scenario 1 From the Regulations

• Has the academic advisor recommend this
  internship as an integral part of the degree
  program?
• Will the student use coop or course credit CPT?

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Scenario 1 From the Institution

• Have you established a start date/end date policy
  for course credit and coop CPT?
• Does this employer the university have a coop
  relationship?

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Scenario 2 Question

• 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?

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Scenario 2 From the Regulations

• SEVIS offers two types of CPT recommendations
• Part Time 20 hours or less per week
• Full Time More than 20 hours per week
• Due to SEVIS functionality, you cannot restrict
  students any further in hours per week.

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Scenario 2 From the Institution

• 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

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Scenario 3 Question

• 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.

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Scenario 3 From the Regulations

• 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.
• 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.

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Scenario 3 From the Institution

• 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.

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CPT Frequency and Duration

• Students can be authorized for CPT
• 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

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Does CPT period need to correspond with course?

• How will grade be assigned if internship takes
  place later?
• Are there periods in the year where classes
  arent offered?
• Example from Berkeley
• CPT must fall within dates of course enrollment
• Extension into winter based on academic
  exceptions because no credit is available.
• CPT available throughout summer with enrollment
  in 1 summer session course

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Can students work on campus and get CPT?

• On Campus Employment
• Incidental to status
• 20 hours/week during semester
• 214.2(f)(9)(i)
• Limits on campus employment do not impact CPT
  hours/week
• 20hrs on campus 20hrs CPT OK
• 20hrs on campus 40hrs CPT OK

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Unpaid Internship Do I Need CPT?

• 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

• Employer-intern relationship consultant, direct
  hire, intern, etc.
• Social security/Medicare tax withholdings
• I-9 required?