On August 12, U.S. Immigration and Customs Enforcement (“ICE”) issued a broadcast message to all Designated School Officials (“DSOs”) reminding them of their responsibilities and potential liability when authorizing curricular practical training (“CPT”). The message emphasizes that DSOs must ensure CPT is properly used and subject to increased program oversight. A DSO may only authorize CPT when the training is:
- An integral part of an established curriculum, and
- Directly related to the student’s major field of study.
The message re-enforces that CPT cannot be granted solely to facilitate employment. ICE further cautioned that DSOs may face administrative or legal consequences if they issue a Form I‑20 reflecting CPT that is not compliant with federal regulations.
This reminder has direct implications for students enrolled in programs that offer CPT from the first day of enrollment (“Day 1 CPT”). Because DSOs must certify that CPT is academically required and integral to the curriculum, schools offering Day 1 CPT should expect heightened scrutiny when issuing new I‑20s. If a DSO determines that the CPT is not properly justified or that the program’s use of CPT appears employment‑driven, the DSO may decline to authorize CPT on the subsequent I‑20. Students who rely on Day 1 CPT should be prepared for more rigorous review of academic plans, course enrollment, and program materials before receiving continued CPT authorization.
ICE confirms that the message serves as guidance to DSOs but it does not alter existing regulations.
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