Curricular Practical Training (CPT) - How F-1 Students Work Off-Campus During School
F-1 students are all required to receive a practical training authorization before they can legally start working off campus. As long as you are under F-1 visa, you are not allowed to work without an authorization.
There are two types of F-1 practical training: curricular practical training (CPT) and optional practical training (OPT). In this chapter, we will demystify the first one-curricular practical training.
According to [8 CFR 214.2(f)(10)(i)], CPT is defined as employment, which is an integral part of an established curriculum (in other words, when you are still enrolled in school), including:
- Internship (paid or unpaid)
- Cooperative education experience
- Any other type of required internship or practicum which is offered by sponsoring employers through cooperative agreements with the school.
CPT is available only prior to the completion of your degree program and you must have a secured job offer supported by an official offer letter at the time of application. CPT employment may not delay completion of the academic program.
|Type of Practical Training||General Regulations|
|Curricular Practical Training (CPT)||
Regulations and Policy
Complex rules apply to CPT because the training opportunity must comply with both:
- Federal regulations (see above chart)
- School policies regarding internships, experiential learning, etc. (The students need to contact the designated school officials to obtain more info)
A DSO can authorize CPT for an F-1 student enrolled at an SEVP-certified college, university, conservatory, or seminary if the student:
Has been lawfully enrolled on a full-time basis for at least a full academic year.
Note: An exception exists for students in graduate studies whose programs require earlier training.
- Is not studying English as a second language.
- Has secured a training position
Each school also has their very specific policies concerning CPT eligibilities. Any student who is planning to get CPT is required to talk to DSO before applying.
CPT and Unpaid Internships
It is not uncommon for students to confuse unpaid internships with volunteering (and therefore conclude that no work authorization is necessary for engaging in an unpaid internship). However, there is a difference between volunteering and engaging in an unpaid internship.
- Volunteering refers to donating time with an organization whose primary purpose is charitable or humanitarian in nature, without remuneration or any other type of compensation. For more information about volunteering please see “Employment vs. Volunteering” section on the IC web site.
- Internships, both paid and unpaid, are primarily offered by the private sector and related to the intern’s major field of study. The U.S. Department of Labor has guidelines for those seeking an unpaid internship: https://www.dol.gov/whd/regs/compliance/whdfs71.htm
The following six criteria must be met for an internship to be considered a legitimate unpaid internship (and not employment below minimum wage, in violation of Department of Labor laws):
- The internship, even though it includes actual operation on the facilities of the employer, is similar to training which would be given in an educational environment.
- The internship experience is for the benefit of the intern;
- The intern does not displace regular employees, but works under close supervision of existing staff;
- The employer that provides the training derives no immediate advantage from the activities of the intern; and on occasion its operations may actually be impeded;
- The intern is not necessarily entitled to a job at the conclusion of the internship; and
- The employer and the intern understand that the intern is not entitled to wages for the time spent in the internship
CPT authorization is strongly recommended for all unpaid internships, whether the student does or does not need to provide employment authorization documents to the company.
You should have CPT authorization for unpaid internships for the following reasons:
- CPT authorization by the university serves to demonstrate that this practical experience is part of the curriculum.
- CPT authorization is a way of reporting in SEVIS the student's activity, employment, and location where they are working and therefore maintaining their status.
- If ever a student is doing a job on an unpaid basis that someone would be hired and paid for, employment authorization in the form of CPT, OPT, etc. is advised.
- If the unpaid internship at some point changes into a paid one (or if your employer decides to compensate you for your work in any way – for example, give you a monetary gift), you won’t be able to accept the payment if your internship was not authorized as CPT. Please keep in mind that F-1 students cannot be retroactively remunerated or in any way compensated for work done in an unpaid internship if they did not obtain work authorization prior to when the work was performed.
If the position is unpaid and for some reason it is not possible for you to obtain CPT authorization, please make sure that your prospective supervisor is aware of U.S. Department of Labor regulations concerning unpaid internships and that you have assurances (preferably written) to that effect before you accept the position. We also recommend that at the end of your internship you ask your employer to provide you with a letter confirming that there was no remuneration or any other type of compensation provided in any form during the dates you were participating in the internship. Please keep such a letter for your permanent records.
CPT Process Overview
Requests CPT using the school’s established processes.
(Each school has a CPT page specifically describing the eligibility, requirement, documents preparation, etc. The students are required to go through that, evaluate your situation, and contact DSO to start the application)
|2||DSO (designated student official)||Reviews request and determines student’s eligibility for CPT.|