DHS Guidelines Force Wesleyan to Restrict International Students Work Off-Campus

In response to recently revised guidelines issued by the Department of Homeland Security (DHS), which limit the scope of off-campus work opportunities for international students on F-1 Visas, the University has joined many other higher education institutions in indefinitely pausing their issuance of Curricular Practical Training (CPT) for international students.

The Office of International Student Affairs (OISA) announced the change in an email to international students on Friday, Sept. 4. The pause came as a result of new guidance by the DHS’s Student and Exchange Visitor Program (SEVP), which warned international student officials in higher education institutions that they may be at risk for losing their certification for enrolling international students if the new guidelines aren’t followed. 

CPT is a temporary work authorization for F-1 status international students to gain experience off-campus through practical training, such as internships. The pause in the issuance of CPT affects the ability of F-1 status holders to work off-campus jobs, including internships.

Previously, SEVP guidelines had authorized academic institutions to grant CPT authorization if it was “an integral part of an established curriculum,” meaning that the opportunity to work off-campus must be either required by the curriculum or the student must receive credit. At the University, eligible students were previously issued CPT authorization from the OISA by enrolling in “Internship” (CSPL 493) and securing an opportunity for practical training directly related to their major. 

OISA initially became concerned about the potential need to change the University’s policy on CPT authorization on Wednesday, Aug. 12, when a broadcast message from SEVP came out warning Designated School Officials (DSOs), staff members at U.S. academic institutions responsible for managing international student records, about strict requirements to comply with the DHS’s policies. A second broadcast message from SEVP explicitly outlined a new interpretation of CPT policies on Monday, Aug. 24.

OISA then contacted senior officials at the University, DSOs at peer institutions, the SEVP Field Representative for the University, and an immigration attorney, per Morgan Keller, the Principal Designated School Official (PDSO) of the University. OISA staff was particularly concerned by the second broadcast message, as the new requirement for the issuance of CPT authorization would not be met by the University’s credit-bearing course for internships, which is an elective, not a required course. 

“In any instance where an elective course is optional, making the CPT optional, the integral and required aspects of CPT would not be met,” the second broadcast message states. “CPT is an integral part of an established curriculum and the practical training is required for [all students] participating in that curriculum, regardless of citizenship.” 

International students will retain their ability to work on campus, including for research. While applying for a pre-completion Optional Practical Training (OPT) is an alternative to CPT that allows F-1 status international students to work off campus, it has its own downsides for student workers, including allotting time for those work experiences by drawing directly from their fixed duration of OPT.

“The alternatives [to CPT authorization] are on-campus employment or applying for pre-completion [OPT],” Keller wrote in an email to The Argus. “Wesleyan offers internships, research opportunities, and other summer jobs which could serve as enriching practical training for F-1 international students. However, pre-completion OPT is now the only option for F-1 international students to engage in off-campus practical training opportunities, and unfortunately, there are many drawbacks to it: it requires that they submit a formal application to USCIS, which carries fees and sometimes lengthy processing times, and the amount of time they work using pre-completion OPT deducts from their total bank of 12 months should they apply for post-completion OPT to work in the U.S. after graduation.”

In the aftermath of this pause, international students voiced their frustrations and fear surrounding their prospects for employment in the United States.

“I’m worried I can’t do research outside of campus,” an international student, granted anonymity to speak candidly about federal immigration policy, wrote in a message to The Argus. “Unfortunately, no professors at Wesleyan work on the research topic I’m most interested in. Honestly, I’m worried that if things get worse, I won’t be able to do research here either. We don’t need CPT for [on-campus research,] but if the hostility against international students grows, then [I’m worried] that I can’t do research here either. Hopefully, that’s not going to happen.”

Others commented on the impact of the new policy on incoming international students.

“There was definitely a lot of discussion [on the new policy] even during International Student Orientation,” another international student, also granted anonymity, wrote in a message to The Argus. “It’s crucial this year to be familiar with the rules.”

OISA shared that they’re committed to continue supporting international students and encourages students to utilize their advising services, especially as other policy changes, such as the new proposed limitation on F-1 visa students’ time in the United States to four years only, are in flux. As a federal judge issued a nationwide preliminary injunction, effectively blocking the DHS’s proposed cap on Monday, Sept. 14, the rule as it stands allows for a flexible expiration date as long as students maintain their legal status and academic progress.

Keller said that there have been no further discussions about changing the University’s CPT policy. Continuing to authorize CPT for F-1 status international students, he said, could put the University’s SEVP certification—which allows for the enrollment of international students—at risk.

Akari Ikeda can be reached at aikeda@wesleyan.edu.