DHS Signals Increased Scrutiny of Curricular Practical Training (CPT) Programs

SEVP Issues New Guidance Reinforcing Narrow Interpretation of CPT Eligibility

On August 24, 2026, the Student and Exchange Visitor Program (SEVP) issued new guidance to Designated School Officials (DSOs) regarding the administration of Curricular Practical Training (CPT). The guidance follows a prior SEVP broadcast warning that the agency has observed a rise in CPT authorizations that appear inconsistent with regulatory requirements and signals increased enforcement activity in this area.

For U.S. employers that hire F-1 students, the guidance is significant because it reiterates that CPT is available only in limited circumstances and emphasizes that CPT must be a required component of a student’s academic program, not simply a means of obtaining employment authorization. The guidance also suggests that schools, students, and employers involved in CPT arrangements may face increased scrutiny moving forward.

Key Takeaways

SEVP’s guidance focuses on several core principles:

• CPT is available only when practical training is an integral and required part of an established curriculum.
• Participation in CPT cannot be optional if it is being used as the basis for employment authorization.
• Schools should require all students enrolled in a curriculum where practical training is deemed integral to complete the training component, regardless of citizenship or immigration status.
• Students must proactively request CPT authorization through their Designated School Official (DSO).
• CPT should be conducted through sponsoring employers that have established cooperative agreements with the school.

These principles reflect a more restrictive interpretation of CPT and may impact institutions and employers that have relied on more flexible CPT models in recent years.

Understanding the Difference Between CPT and OPT

A central theme of SEVP’s guidance is the distinction between Curricular Practical Training (CPT) and Optional Practical Training (OPT). While both permit employment related to a student’s field of study, SEVP emphasized that they serve fundamentally different purposes.

Curricular Practical Training (CPT)

According to SEVP, CPT is employment authorization available only when practical training is an integral and required component of an established curriculum. CPT may take the form of an internship, cooperative education program, practicum, alternative work-study arrangement, or similar training experience that is necessary for successful completion of the academic program. The agency further emphasized that participation in CPT should be required for all students enrolled in the relevant curriculum.

Optional Practical Training (OPT)

OPT, by contrast, is employment authorization that is not required by a student’s program of study. Participation in OPT is voluntary, and students may complete their academic programs without engaging in OPT. Unlike CPT, OPT is designed primarily to provide practical experience related to a student’s major field of study rather than satisfy a mandatory curricular requirement.

SEVP specifically noted that some schools have improperly treated CPT as if it were OPT by characterizing the training as optional rather than integral to the curriculum. The new guidance appears intended to address those practices.

Elective Courses May Not Support CPT

One of the most significant aspects of the guidance concerns CPT offered through elective coursework.

SEVP stated that when a course is optional and a student may choose whether to enroll, the related practical training is likewise optional. According to the agency, this arrangement does not satisfy the requirement that CPT be both integral and required. As a result, schools may face challenges supporting CPT authorizations that are tied solely to elective academic offerings.

Practical Training Must Be Required for All Students

The guidance also emphasizes that if practical training truly constitutes an integral component of a curriculum, all students enrolled in the program should be required to complete it.

SEVP noted that it has identified schools where only certain students participate in practical training despite claims that the training is integral to the curriculum. The agency indicated that such inconsistencies raise compliance concerns because CPT is permitted only where practical training is a mandatory component of the educational experience.

Schools Must Continue to Verify Eligibility and Maintain Records

The guidance reiterates that students must formally request CPT authorization from their DSO before beginning employment.

Schools are expected to confirm that:

• The student is enrolled in a curriculum where practical training is integral.
• The training is directly related to the student’s major field of study.
• Appropriate updates are made to the student’s SEVIS record.

The agency cautioned that failure to satisfy these verification and record-keeping requirements may result in significant compliance consequences for institutions.

Cooperative Agreements with Employers

SEVP emphasized that CPT should be conducted through employers that have established cooperative agreements with the school.

According to the guidance, schools should work only with legitimate, bonafide employers capable of providing meaningful practical training directly related to the student’s area of study. Employers may therefore see universities requesting additional information regarding job duties, training objectives, supervision, and the educational components of a proposed position before authorizing CPT.

Potential Impact on Employers

While the guidance does not create new regulations, it clearly signals an intent by DHS to increase enforcement of existing CPT requirements.

Employers that hire F-1 students using CPT should anticipate:

• Increased scrutiny of CPT authorizations by schools and government agencies
• More restrictive CPT approval practices at certain institutions
• Additional university requests for employer documentation
• Increased focus on whether employment is directly related to the student’s academic program
• Continued scrutiny of programs commonly referred to as “Day 1 CPT”

Looking Ahead

The agency’s position is clear: CPT is not intended to function as an alternative form of optional employment authorization. Rather, it is available only where practical training is an essential and mandatory component of an established academic curriculum. Employers that hire F-1 students pursuant to CPT should expect increased scrutiny and should take proactive steps now to validate their compliance practices and mitigate immigration-related risk.

How Clark Hill Can Help

Our immigration team is closely monitoring developments affecting F-1 students and employers. We can assist with CPT compliance reviews, workforce audits, onboarding procedures for foreign national employees, evaluations of CPT-dependent hiring strategies, and assessments of potential risk arising from changing agency enforcement priorities.

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