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Curricular Practical Training (CPT)

Overview

Curricular Practical Training (CPT) is a form of work authorization for F-1 students. Per federal regulations, CPT is defined as “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” (Source: [8 CFR 214.2(f)(10)(i)]). In its most basic form, CPT is intended to allow F-1 students to participate in internships or similar activities that are an integral component of their program of study. CPT is not work authorization simply for the sake of working and earning compensation.

CPT Eligibility Criteria

In order to be eligible for CPT authorization, you must…

  • Be lawfully enrolled on a full-time basis for one academic year.
  • Enroll in a class where an integral component of the class is an internship, practicum, field experience, training program, or any other experiential activity that involves some kind of placement with a hosting/sponsoring entity. The class must count for credit and must fulfill some kind of requirement needed for program completion.
  • Have a job/internship offer in a position that is directly related to your program of study. The job must begin on or after the start of classes for the semester in which you are enrolled in the corresponding class. The job must also end on or before the end of classes for the same semester. CPT will not be authorized for periods of time in which classes are not in session.
  • Find a job that allows you to maintain physical presence on campus during the fall and spring semesters. This usually means you are limited to employment in the Mount Pleasant/Mid-Michigan area or remote work. CPT during the summer semester does not require physical presence on campus unless you are completing your program at the end of the summer semester.

NOTE: CPT employment is authorized one semester at a time (fall, spring, and summer). If you intend to pursue a CPT experience for multiple semesters, you must request a new authorization for each semester. You must also enroll in the corresponding class for each semester. CPT will not be authorized for periods of time in which classes are not in session.

CPT Authorization and Unpaid Work

Unpaid work at a company or for an employer is not the same as volunteering for a charitable cause or organization. As a result, CPT authorization is often still required for unpaid work. CPT for unpaid work may be required for the following reasons:

  1. A company may say your position is unpaid, but your work may still meet the U.S. Department of Labor’s definition of “employment” and thus require valid work authorization such as CPT (see FLSA Fact Sheet #71). This is almost certainly true if you are working in a position that would normally be compensated or if the primary beneficiary of your work is your company.

  2. Your company may elect later to make your unpaid position a paid one or to retroactively compensate you for past work. By having CPT authorization in place, there would be no question as to the validity of your work authorization or your ability to receive compensation.

  3. CPT authorization by the university validates that your work experience is part of your program. This, in turn, better ensures that you are complying with your F-1 status.

CPT is generally not required for volunteer work done solely for a charitable cause such as for a soup kitchen, humaine society, or some types of service learning. It is always a good idea to check with the ISSS office before engaging in your activity just to verify.

There are no consequences for having or asking for CPT authorization when it is not needed, but there are many serious consequences for not having CPT when it is needed.

Part-Time vs. Full-Time CPT

Part-time CPT: Employment for 20 hours or less per week is considered part-time. For CPT employment during the fall and spring semester, you must be enrolled in classes for the normally required full course of study. You must also maintain a physical presence on campus.

Full-time CPT: Employment for more than 20 hours per week is full-time. Please be aware that 12 months or more of full-time CPT will eliminate your eligibility for Optional Practical Training (OPT). For CPT employment during the fall and spring semester, you must be enrolled in classes for the normally required full course of study. You must also maintain a physical presence on campus.

CPT Application Procedure

You MUST NOT begin any work for your job/internship until CPT is authorized and your authorized start date has been reached. Starting work before CPT is authorized could be deemed a violation of your F-1 status and could likewise result in the termination of your SEVIS record. The government takes work authorization very seriously. Please follow all instructions carefully. Please plan ahead and allow enough time for the ISSS office to process your request, at least one week before the anticipated start date of your job/internship.

If you are starting to explore CPT as an option for work authorization, you must first determine that your program includes an internship, practicum, or other field-based practical training experience for which CPT could be authorized. Remember that CPT is not work authorization simply for the sake of working and earning compensation. Therefore, you must begin these discussions with your academic advisor. Keep in mind that your advisor will not be able to answer specific questions about CPT (those questions are for the ISSS office). Instead, you should frame this discussion through the context of your program’s course sequence and curriculum. For example, you could ask the following: “does my program offer any opportunities for an internship or work experience where I can earn credit?” If the answer to this question is “no,” CPT is not an option for you. If the answer to this is “yes,” you can proceed with requesting CPT only when you meet the eligibility criteria specified above. This is something you can further plan with your advisor, though do be sure they are aware of how CPT eligibility works (i.e. “when could the internship/work experience fit within the sequence of my program keeping in mind that my F-1 status requires me to be enrolled for one full academic year”).

You must have a job/internship offer. You must provide proof of this offer by submitting an offer letter or training plan. The offer letter/plan must meet the following requirements:

  • Be written on company letterhead
  • Include your proposed job/position title
  • Be addressed to you
  • Provide an overview of the proposed job/position description (at least a few sentences describing duties, tasks, goals, etc.)
  • Specify the address where your employment will take place (street, city, state, and zip code). If you will be working remotely, the letter should specify this and list the company’s physical address.
  • Specify number of hours per week you will work/participate in the experience.
  • Specify start and end dates of CPT employment (keep in mind that CPT can only be authorized one term at a time and should align with the term calendar).

You are welcome to provide this sample letter to your employer/sponsoring entity. If your employer prefers to use their standard offer letter that does not cover all of these requirements, an email or supplemental letter from your employer with the missing details is also acceptable. This supplemental email/letter should be addressed to you and be directly from your employer.

 

See here for a sample letter

You must gather the following documents, to be submitted in the next step:

  1. Job/internship offer letter/training plan meeting the requirements above.
  2. An unofficial transcript or copy of your academic history showing your enrollment in the corresponding class for which CPT is needed.
  3. Copy of your most recent I-94.

The request will also ask you to enter the email address for your advisor or course instructor. This will generate an electronic recommendation for them to complete. Be sure to let your advisor/instructor know to expect this recommendation form prior to completing the request.

Log in to the ISSS Portal and go Requests > CPT Request (under “What can we help you with” in the bottom right). Follow the request instructions. Click Submit when finished. Once submitted, the electronic recommendation form will be emailed to your advisor to complete. Watch your cmich.edu email for any correspondence from the ISSS office in the event your request requires correction or clarification.

If your CPT request is approved, you will be notified by email that your CPT I-20 is ready to download. Your CPT I-20 can be downloaded from the ISSS Portal > Requests > Documents. You MUST NOT begin working until CPT is authorized by the ISSS office and your authorized CPT start date has been reached. Should your employer require you to complete form I-9, your CPT endorsed I-20 should be sufficient proof of your authorization to work.

After CPT Approval

Once your CPT has been approved, please keep the following in mind:

  1. You may begin your CPT employment only once your CPT start date has been reached. If your CPT start date changes, please contact the ISSS office to have the start date updated on your I-20.
  2. You must end your CPT employment by the authorized end date on your I-20. If your CPT experience ends before the authorized end date, you must contact the ISSS office to have the CPT authorization shortened. If your CPT experience is expected to continue beyond the current term, a new CPT authorization will be needed for next term. Your eligibility for a new authorization will be evaluated at that time.
  3. If you drop or withdraw from the class for which the CPT authorization was granted, you must contact the ISSS office to have the CPT authorization shortened.
  4. Please understand that any CPT authorization granted is specifically for completion of program requirements only. CPT is not simply work authorization for the sake of working and earning compensation. Your focus must continue to be on your studies and completion of your program.