ETSU | Curricular Practical Training (CPT)

International Enrollment and Services

F-1 Curricular Practical Training (CPT)

Students must complete the CPT Training Modules in D2L before submitting the CPT application. You can access the CPT Training Module Request form here. Our standard processing time for CPT is 10 business days (excluding holidays/closures). However, it's important to note that CPT requests often face delays due to errors or omissions on the request form or employment letter. To ensure you are authorized to work on time, we strongly advise you to submit your CPT application to our office at least TWO WEEKS BEFORE your internship/employment start date. If you submit your application later than that, we cannot guarantee that you will be authorized to work by your requested start date of employment. Please remember that F-1 students are required to have their CPT I-20 in hand on their first day of employment. 

What is Curricular Practical Training (CPT)?

US Department of Homeland Security (DHS) regulations state the following: CPT accommodates individuals enrolled in a program of study that requires participation in an internship or practicum. It is not a supplemental training experience but rather an “integral part of an established curriculum,” meaning it is a required part of the degree or program of study. The regulation makes this clear by defining CPT as an “internship, cooperative education or any other type of required internship or practicum….” (USCIS CPT Training)

  • May a student participate in CPT related to the student’s minor or general graduation requirements?
    • No, federal regulations require CPT to be directly related to a student’s major area of study. This means CPT cannot be authorized based on a student’s minor or general graduation credits. CPT participation may only be approved if the training opportunity is directly related to the major program of study (USCIS CPT Training).

CPT is an academic experience and should not be used for regular ongoing off-campus work. It's important for students to understand that CPT is designed to enrich their academic learning and should be used accordingly. Students should keep all records of CPT and the academic work related to CPT, and how that employment is integral to the degree program. When applying for OPT, students will need copies of all previous CPT I-20s.

  • Eligibility Requirements

    > The student is currently in the U.S. in valid F-1 status.

    > The student has been enrolled full-time for at least one academic year (fall and spring semesters) and is in good academic standing. An exception to the one academic year requirement is provided for graduate students enrolled in a degree program that requires immediate participation in training or work within the first academic year of the current program of study.

    > The training or work is an integral part of the established curriculum. Integral refers to the training or work activity being a required, necessary, or essential component of the established curriculum; the established curriculum refers to the student’s major field of study.

    > Students must secure an academically appropriate internship offer directly related to their field of study. Positions must be appropriate to the student's level of study and major field of study. Retail sales, food service, and other unskilled positions will be denied.

    > The credits taken for the CPT must count towards the student’s degree requirements.

     

    Students must obtain CPT authorization BEFORE beginning employment; authorization cannot be back-dated. Failure to obtain CPT approval before starting the internship will result in the student falling out of status, resulting in a SEVIS termination. CPT is available only before completion of the program of study. The student may begin the internship only after receiving CPT Employment Authorization on their new I-20 from the International Student Advisor.

  • Internship Course Requirements

    If CPT authorization is based on a course, the student must enroll in the internship or practicum course during the term in which they plan to complete the training.  The period of CPT authorization cannot extend beyond the dates of the semester that the student registers for the course and CPT dates may not extend into an adjoining semester without additional enrollment for an internship course in that semester.

    Qualifying CPT courses MUST:

    • carry academic credit that will be applied towards graduation requirements
    • be listed in the program’s course catalog
    • have a faculty member assigned to supervise the course
    • be clearly designated as an internship or practicum course either in the course title or course description
    • be in the student’s major field of study

    The credits taken for the CPT must count towards the student’s degree requirements; this must apply in one of the following ways:

    • Completion of the training or work is required for all students within the program of study
    • Participation in the training or work is optional and will fulfill elective credits that will count towards meeting the total number of credits designated by the program of study. Registration in independent study credits or for course credits not intended for experiential learning is not acceptable for CPT.
    • The training or work is necessary for the student to conduct research to complete the thesis or dissertation. A detailed letter from an academic or faculty advisor is required. The letter should explain how the work experience is related to the thesis/dissertation research or project. The work experience must be connected to the thesis/dissertation research and not just academically related.

    CPT cannot be authorized on any basis except for one of the three categories listed above. Students who do not  qualify for CPT may speak to an international student advisor about Pre-completion OPT work authorization as an alternative option.

    NOTE: It is imperative that any employment experience required by the course be instrumental to achieving a curricular academic objective.

  • Paid vs. Unpaid

    SEVP guidance states that "compensation is not a consideration when determining whether an opportunity qualifies as CPT," but federal and state labor and wage/hour laws do still apply.Whether you need work authorization for an unpaid internship is considered on a case-by-case basis. International students who receive an offer for an unpaid internship should contact their ISA for guidance. 


    CPT work authorization is required for all paid employment opportunities. It is strongly recommended that you obtain CPT work authorization even for unpaid opportunities if the opportunity does not meet the Fair Labor Standards Act (FLSA) test for unpaid internships versus employment. If you choose to pursue an unpaid internship without CPT work authorization, please make sure that the company is aware of the FLSA regulations concerning unpaid internships and that you have written assurances to that effect before you accept the position. We also recommend that 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 your participation. Please keep this letter for your permanent records.

    If you are receiving any type of compensation, including clothing, stipends, honoraria, stock options, or reimbursements, or the prospective position does not meet the unpaid internship criteria, you must obtain U.S. work permission if eligible. In addition, you cannot offer to volunteer for a position that is normally a paid position or for which you will be paid later due to work authorization constraints. 

     

    If, in the future, you are applying for benefits or an adjustment of status and the U.S. government determines your unpaid internship met the definition of "employment," but you did not have CPT work authorization, you may need to work with an immigration attorney to avoid any negative consequences. 

  • Limitations

    Students in CPT can work up to 20 hours per week during the spring and fall term and full-time during the summer term (unless the student is required to register for coursework for the summer term, in which case, summer will be considered a regular term).

    If an F-1 student uses 12 months or more of full-time CPT at the same degree level, the student forfeits Optional Practical Training eligibility. (Use of full-time CPT in a prior degree at the same level would be included in the 12-month calculation.) Accrual of part-time CPT should not negatively affect eligibility for OPT.

    While there are no limitations on part-time CPT, high CPT usage can cause DHS to increase scrutiny when the student applies for OPT, visa applications, or other DHS benefits like H-1B petitions. 

  • Application Instuctions

    Students must complete the CPT Training Modules in D2L before submitting the CPT application. You can access the CPT Training Module Request form here. CPT processing time is 10 business days (excluding holidays/closures). CPT requests often face delays due to errors or omissions on the request form or employment letter, so be sure to submit a completed application packet to avoid delays. We strongly advise you to submit your CPT application to our office at least TWO WEEKS BEFORE your internship/employment start date. If you submit your application later than that, we cannot guarantee that you will be authorized to work by your requested start date of employment. 

    Students may not begin employment until the CPT has been approved in SEVIS and a new Form I-20 has been issued.

  • Application Checklist

     

    [    ] Complete CPT Training Modules in D2L: use this link to request access to the CPT  Module


    [    ] Completed CPT request form

    [    ] Concise Student Schedule (access via your Goldlink) demonstrating registration in the appropriate CPT course (see Internship Course Requirement tab)

    [    ] Internship/practicum course description and/or syllabus for the appropriate term

    • Graduate students:
      • If the internship is a degree requirement, submit the requirement description from the department’s handbook and any other documentation outlining the requirements (number of practicum hours needed, required prerequisites, etc.).
      • If the internship is required for thesis/dissertation research, submit a letter from your advisor on department letterhead that includes:
        • Description of student’s research
        • Explanation of student role at the internship site and how it is related to the field of study
        • Why the research must be done off-campus and cannot be completed at ETSU
        • How the research is required for thesis/dissertation completion


    [    ] F-1 CPT Verification Letter from internship employer/organization signed and on company letterhead. A template letter can be found here. All elements listed on the verification letter must be included or it will not be accepted

    [    ] Most Recent Form I-94, which may be retrieved at https://i94.cbp.dhs.gov

    DO NOT SEND FILES VIA A CLOUD SERVICE, such as Sharepoint, Google Drive, etc. 

    We will authorize you to work for a specific employer and for specific dates. Any changes in employment conditions, such as early termination, change in number of hours per week, MUST be communicated to the International Student Advisor.

    Important note: You cannot begin CPT employment until you receive written authorization on a new Form I-20.