Approving Curricular Practical Training (CPT) for F-1 Students


This explains the process, regulatory background, and requirements necessary for faculty and academic advisors to approve CPT for students on an F-1 (student) visa.

CPT is the required immigration process that F-1 students must use in order to participate in practicums, internships, field experience, and co-op programs that are located off of the University of Tennessee campus. This is required if the training is paid or unpaid.

This authorization must be completed before the student can begin the CPT opportunity.

Academic Oversight

Demonstrating academic oversight is the critical factor to the approval of CPT. The Code of Federal Regulations (CFR) define CPT as,

“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.” 8 CFR 214.2(f)(10)(i)

In the setting of higher-education, the academic advisor or faculty advisor are deemed as individuals with the subject matter expertise to define an experience as meeting the regulatory requirements. In general, there are three broad definitions of academic approval for CPT:

Required for Degree Completion

This is defined by the academic catalog and indicates that a non-optional degree requirement is participation in an internship, practicum, clinical, field experience, or some other off-campus experiential learning.

Required for Thesis or Dissertation

This is defined as being required for the completion of the thesis or dissertation. The student must be in the research phase of their program for this to be applicable.

Integral to the Program

This is defined as an opportunity that while not required is highly recommended for the degree. In addition, the experience must be directly related to a learning outcome. Most CPT opportunities fit into this category.

Course Enrollment

Students are required to attach the CPT opportunity to a course registration during the semester period covering the opportunity. The determination of what course is appropriate is left to the academic department with the exception of the fact that if the CPT is required for a thesis or dissertation, the student must be registered for the matching research hours. Opportunities that cover multiple semester periods must be approved for each semester period and have an attached course for each period.

Note, Use of Facilities courses can never be used to demonstrate oversight and cannot fulfil the course enrollment requirement.

CPT Semester Definitions

Fall Semester Dates: August 1st through December 31st

Spring Semester Dates: January 1st through May 31st

Summer Semester Dates: May 1st through August 31st

CPT opportunities rarely match the exact dates of a semester. As such, each semester period has an expanded series of dates for reporting to the Department of Homeland Security (DHS). CPT opportunities that are pursued in a semester period must have an assigned course that the student registers for within that period.

Example One: A student wishes to pursue an internship from June 15th until August 7th. The student would need to be registered for an attached course (determined by the academic or faculty advisor) for one of the summer semesters.

Example Two: A student wishes to pursue an internship from October 11th until March 1st. The student would need to be registered for an attached course for the fall semester. In addition, another approval would need to be completed with another attached course for the spring semester.

Concurrent Employment at the University of Tennessee

Many students who wish to participate in a CPT opportunity may hold a graduate assistantship or other position with the university. This does not preclude participation in the CPT opportunity. However, students who hold a position at the University of Tennessee cannot participate in a CPT experience that would increase the aggregate number of hours worked for the University of Tennessee over 20 hours per week while class is in session during the fall and spring semesters.

Note, regardless or CPT approval, students may NOT work for more than 20 hours per week at the University of Tennessee while class is in session in the fall or spring semester.

Example One: A student holds a .5 FTE (20 hour per week) graduate teaching assistantship. The student has an opportunity to participate in a research opportunity with an on-campus lab for 10 hours a week through CPT during the spring semester. The student is not allowed to participate in this opportunity since it would create a situation where the student was employed by the University of Tennessee for 30 hours a week during the spring semester.

Example Two: A student holds a .25 FTE (10 hours per week) research assistantship. The student has the opportunity to participate in an on-campus program conducting training with community members for 10 hours a week during the fall. This is permitted as long as all other requirements for CPT is met since the total number of hours does not exceed 20 hours per week in the fall or spring.

Academic or Faculty Advisor Responsibilities

In order to demonstrate academic oversight, the faculty or academic advisor is responsible for several key requirements. These requirements must have been reviewed with the student before approval for the opportunity is given.

  1. Ensure that the opportunity is related to the student’s field of study;

  2. Ensure that participation in this opportunity does not not delay the student’s graduation;

  3. Determine what course the student will be registered in during their CPT participation;

  4. Determine that the opportunity is in alignment with the student’s educational program as per the academic catalog.

Signing the Curricular Practical Training Request E-Form

Students initiate the e-form required for immigration approval. This form reviews required information needed from the student. The second part of the form is routed to the academic or faculty advisor as entered by the student.

Step One:

Select the type of training opportunity that the student wishes to engage in.

CPT E-Form Faculty Start

Step Two:

Select the type of academic approval appropriate for this experience. Please note that if none of the three categories apply, this is an experience that is likely not eligible for CPT.

CPT e-Form Participation

Step Three:

Confirm that you have discussed the opportunity with the student and assessed it as a component of the student’s academic outcomes.

Step Four:

Provide the details of the course that the CPT opportunity will be attached to.

Step Five:

Please confirm your recommendation for the CPT experience and select “Submit.”

Regulatory Background

The following regulations form the basis of CPT policy at the University of Tennessee.

8 CFR 214.2(f)(10)

(10) Practical training. Practical training may be authorized to an F-1 student who has been lawfully enrolled on a full time basis, in a Service-approved college, university, conservatory, or seminary for one full academic year. This provision also includes students who, during their course of study, were enrolled in a study abroad program, if the student had spent at least one full academic term enrolled in a full course of study in the United States prior to studying abroad. A student may be authorized 12 months of practical training, and becomes eligible for another 12 months of practical training when he or she changes to a higher educational level. Students in English language training programs are ineligible for practical training. An eligible student may request employment authorization for practical training in a position that is directly related to his or her major area of study. There are two types of practical training available:

8 CFR 214.2(f)(10)(i)

(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.

8 CFR 214.2(f)(10)(i)(B)

(B) SEVIS process. To grant authorization for a student to engage in curricular practical training, a DSO at a SEVIS school will update the student's record in SEVIS as being authorized for curricular practical training that is directly related to the student's major area of study. The DSO will indicate whether the training is full-time or part-time, the employer and location, and the employment start and end date. The DSO will then print a copy of the employment page of the SEVIS Form I-20 indicating that curricular practical training has been approved. The DSO must sign, date, and return the SEVIS Form I-20 to the student prior to the student's commencement of employment.