The regulations state that a student may participate in a “curricular practical training program” that is “an integral part of an established curriculum” and “directly related to the student’s major area of study.” They define curricular practical training as “alternate work/study, internship, cooperative education, or any other type of required internship or practicum which is offered by sponsoring employers through cooperative agreements with the school.”
Regulatory Source: 8 CFR 214.2(f)(10)(i).
Here are some quick facts about Curricular Practical Training (CPT):
For students to receive CPT, the training (and employment associated with the training) must be “an integral part of an established curriculum” and “directly related to the student's major area of study.”
Regulations require one full academic year of study before a student may engage in CPT except when enrolled in a graduate level studies where immediate CPT is required of all students engaging in the program. In these instances, CPT is allowed in the first year of study.
CPT is authorized directly by the designated school official (DSO) who updates the student’s SEVIS record with the CPT authorization, including: the employment start and end date; employer name and address; and whether the authorization is for part-time or full-time CPT.
CPT can be paid or unpaid. SEVP guidance states that “compensation is not a consideration when determining whether an opportunity qualifies as CPT.”
There is no set limit to the amount of time a student may engage in CPT. However, if a student engages in full-time CPT for 12 months or more, the student becomes ineligible for post-completion OPT. Engaging in part-time CPT (20 hours per week or less) does not affect eligibility for post-completion OPT.
The above information was provided by the NAFSA advisors manual.
Winter Term, Internships, and Your Visa Status
If work in the US is connected to a winter term project or is credit-bearing over summer, you should have curricular practical training (CPT) authorization to make sure you maintain visa status. Likewise, all paid positions off-campus require CPT authorization, and most unpaid positions do, too.
Employees vs. Volunteers:
- Employee: an individual who provides services or labor for an employer for wages or other remuneration. “Remuneration”—a reward paid for work or service—includes any non-monetary benefits, such as free housing, food, or gifts. Most interns are considered to be employees even if th position is unpaid.
- Volunteer: an individual who performs service for civic, charitable, or humanitarian reasons, without promise, expectation, or receipt of compensation for such services. A volunteer must also not displace a genuine employee. This definition of a volunteer applies especially to a non-profit organization for public service, or for religious or humanitarian objectives.
If you are working in the private sector, your position must satisfy the criteria below in order to be considered volunteer training. According to the U.S. Department of Labor, any internship in the private sector is considered employment (rather than volunteer training), unless the internship satisfies all of the following guidelines:
- The internship, even though it includes actual operation on the facilities of the employer, is similar to training 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, the employer’s 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 internship.
Most unpaid internships do not qualify as "volunteering" under this definition and therefore require employment authorization.
You should secure CPT authorization if your position as employee or volunteer is part of a winter term project or otherwise credit-bearing. You do not need CPT authorization if your position meets the U.S. Department of Labor guidelines for volunteer training and the program is neither part of a winter term project nor credit-bearing. If you have any concerns about an internship opportunity, we strongly recommend CPT authorization for your protection, in the event that an official from the US Citizenship and Immigration Services (USCIS) disagrees with the assessment by you and/or the employer that you are engaged in volunteer training. CPT authorization cannot be granted after an international student has already started working, be sure to apply using the application below before you start any off-campus position.