TO CPT OR NOT TO CPT? That is the question Presented by: Chris Bargerstock, MSU Rosemary Max, MSU

A CPT by any other name... 8 C.F.R. § (f) (10) (i) (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:

A CPT by any other name... (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.

Pray thee regulations, what sayest thou about CPT?  Must be in F-1 status  Must be lawfully enrolled for one academic year before being eligible for CPT (enrollment must be lawful does not have to be in F-1 status).  One exception graduate students enrolled in a program that requires immediate CPT.  CPT can be approved for part time (20 hours or less) or full time (over 20 hours).  For CPT, student must have an offer of employment. This must be approved by DSO before CPT begins.

Pray thee regulations, what sayest thou about CPT? CPT position must be directly related to student’s major area of study CPT is defined as part of the curriculum and must be approved before completion of the academic objective. Use of full time CPT for 12 months or longer eliminates OPT. Use of part-time CPT does not affect eligibility for OPT. CPT is not available to students in English Language training

Regulations, what dost thou NOT sayest about CPT? Does not specify what kind of workplace: company, not for profit, church, symphony, etc or that it be paid Does not specify that CPT must be in same city as school Does not specify a time limit, only that a 12 months full time makes a student ineligible for OPT Does not require specific documentation to grant CPT only that DSOs verify that a student is eligible Does not specify that a student who is authorized to be underenrolled is ineligible for CPT Does not specify that CPT be part-time during the school year

Regulations, what dost thou NOT sayest about CPT? Does not specify that CPT must be related to an established internship at the school Integral part “Integral part of an established curriculum” is subject to a great deal of interpretation. Some interpret very narrowly, while others take a more expansive view. Training required by all students (eg. teacher, social worker) Training a student may opt for when pursuing a particular course track Cooperative education employment offered under cooperative agreements between an employer and the university through a co-op office, which is an integral part of the curriculum but not required for a particular course or of all students, constitutes bona fide practical training. INS has recognized that “CPT offered through institutionally sponsored cooperative education... is usually optional and not-for- credit.” INS memorandum CO 214.2F-C, May 4, 1992

Pray thee NAFSA, what sayest thou about CPT? Because the practice of schools vary widely in regard to training programs, the international office at each school should develop institutional policies and procedures regarding CPT through discussion with their own office and relevant campus offices. If you have policies and procedures that are clearly established and followed consistently, if a question ever arises about the legitimacy of CPT authorization the student, the DSO and the institution will be able to demonstrate that they acted in good faith. (pages 3-148/49 NAFSA Manual, 2003)

Pray thee NAFSA, what sayest thou about CPT? The Service is clearly concerned about potential abuses of using CPT where the student has some choice in whether or not to pursue an academic route involving employment. In the January 1992 memo, INS stated that such training can be classified as CPT if the student receives course credit. (pages NAFSA Manual, 2003) DSOs wishing to gain a fuller understanding of the terms of CPT will need to combine the sparse regulatory language with elaborate discussions found in the Federal Registry supplementary information of the October 1991 regulatory revision and in subsequent cables, including INS Memorandum CO C, January 22, 1992 and INS Memorandum CO 214.2f-C, May 4, 1992 which attempt to clarify the terms “required” and “sponsored.” (pages NAFSA Manual, 2003)

Pray thee, MSU what sayest thou about CPT? At MSU, CPT is considered to be a valuable tool that allows international students to gain much needed experience in their field of study. MSU takes a student friendly approach to its CPT policy and at the same time respects immigration regulations. MSU has decided, except in a few scenarios, that CPT is granted on a part time basis during the school year. However, full time CPT will be authorized during the school year if it is required for the degree, if a student is in his or her last semester and is getting the balance of credits for the degree, and for some PhD students who are full time with 1 credit. MSU will authorize full time CPT over the summer—traditionally a time for students to gain needed work experience. This policy was developed after a lengthy discussion on what is appropriate for a large research university whose international student population is 60 percent graduate, who are working in the land grant philosophy of applied learning, and whose highly qualified students have opportunities in other cities and states. (see handout)

So..... To CPT or NOT to CPT? A Drama in Three Acts

Act 1 Romeo is an F-1 student finishing a bachelor’s degree at the University of Michigan and will graduate on 5 May He is accepted to the MBA program at Michigan State and he will start in the summer session in mid-May. He has talked to his MBA academic advisor at MSU to let her know that he has found a full time summer job very relevant to his MBA program and he wants to use CPT for the job. His academic advisor agrees that the work experience is relevant. Romeo is now in your office asking for CPT authorization. TO CPT or NOT TO CPT

Act 2 Juliet is a Master’s student in F-1 status with an assistantship. The assistantship counts for her part-time on campus job. She has approached the international office with an offer for work experience that is related to her studies but it is for 40 hours a week during the school year. Juliet insists that she can keep up her course load, her assistantship and do a full time job at the same time. TO CPT or NOT TO CPT

Act 3 MacBeth is an F-1 PhD student in entomology who is all but dissertation and thus his “full time” requirement is minimal. He has followed his academic advisor to a far away tropical state to study bugs. He continues to register for the minimum amount of internship credit though full time and requests full time CPT authorization semester after semester. All of this is done via mail. His work experience is relevant but is he making progress toward his degree? To CPT or NOT TO CPT

Conclude CPT regulations are vague and open to interpretation which will cause discussion in your offices It is important to set a policy and apply it uniformly International students have many restrictions: advocate for student centered policies in your offices

Conclude All the world's a stage, And all the men and women merely players; They have their exits and their entrances, And one man in his time plays many parts. Exaunt