Understanding Curricular Practical Training(CPT) Compliance
- William Vittetoe
- Brian Todd
Overview
This guide explains important compliance practices for employers offering University of Tennessee students CPT opportunities. Approval for participation in a CPT experience is jointly completed by the academic department and by the immigration compliance unit, International Student and Scholar Services (ISSS). Student are not clear to begin the opportunity until they have received direct authorization on the second page of their form I-20. Please see the example below.
Offer of Employment
An official offer of employment is required for students to receive approval. A sample template is listed below, but any format can be used as long as the following components are present on official company letterhead:
Student’s Name
Student’s Address
Employer Name (Super Important - please note that we will reference the letter when reporting the CPT employment in the student’s immigration record in SEVIS. The name will be listed on the I-20 exactly the same as reported in SEVIS).
Employer Physical Address (not a PO Box)
Start Date
End Date
Hours of Work per Week (Note: for CPT authorization part-time is 20 hours per week or less)
Rate per Hour (or indication that position is unpaid)
Supervisor's Name, Title, Phone Number, and Email
Student’s Position
Student’s General Duties (a sentence or two of general description is sufficient)
Sample Job Offer Template
It is preferred that employers provide simple employer letters for CPT authorization purposes rather than lengthy letters with multiple pages even if the official job offer letter contains the required information, the longer and more complex the letter, the more lengthy and complicated the CPT approval process may be.
Complete the Form I-9
Complete the form I-9 following your company's regular process. You can refer to the United States Citizenship and Immigration Services (USCIS) publication Handbook for Employers M-274 for information on what documents to use for the I-9. The specific sections are 6.4.2 F-1 and M-1 Nonimmigrant Students and 6.4.1 Exchange Visitors (J-1). Important, CPT approval is temporary. The validity of the student’s work authorization expires at the end date listed on page two of the I-20, or upon the advent of a change in the nature of the opportunity.
Regulatory Background
The following regulations form the basis of CPT policy at the University of Tennessee.
(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:
(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.
(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.