Q&A for Second Approvers of CPT E-Form
Curricular Practical Training
Curricular Practical Training (CPT) is a benefit for international students in F-1 status that allows temporary training authorization for an “alternative 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.”
CPT can only be authorized prior to a student’s degree completion for a work experience that is in their major field of study and considered to be “an integral part of an established curriculum.”
Study in the States explains, “CPT is only available for F-1 students when it is part of an established curriculum within a school. CPT must be integral to your program of study”
In 2020, ISSS conducted a comprehensive review of our Curricular Practical Training (CPT) protocol for international students holding F-1 nonimmigrant status. Based on the results of the ISSS internal review, we instituted comprehensive changes to our CPT protocol (requiring that the internship experience be connected to either an internship course or a degree requirement) that became effective on May 6, 2021. Detailed information is available regarding this change as well as a summary of the data collected during our internal review.
The F-1 regulations require that CPT be authorized for work experience that is considered “an integral part of an established curriculum.” An eligibility requirement of CPT is that a student must meet one of the following requirements for CPT, which their Academic Advisor or Graduate Program Administrator must sign off on (by completing this CPT Request e-form):
Be enrolled in an internship course for credit that could count towards their degree. (Enrollment in the course must be concurrent with the training. For example, if the internship is in the summer, the student must be enrolled in the internship course during the summer) or
Their degree must require an internship and that requirement is clearly documented in the University Catalog.
Since ISSS is not an academic unit, we ask for the assistance of academic advisors and graduate program administrators to confirm that the student’s degree program is designed in such a way that they are eligible for CPT. By completing the CPT Request e-form, you are confirming that the student is either enrolled in an internship course that could count for credit towards their program or, alternatively, that their degree program requires an internship, and the internship requirement is clearly documented in the University catalog.
- If a student is enrolled in an internship course for credit, you’ll be asked to provide the course name and number of that class.
- If the student’s degree program requires an internship, you’ll be asked to provide a link to the section or webpage in the University Catalog where that requirement is clearly documented.
While ISSS does not set a specific deadline, an ISSS Advisor will reach out to second approvers who have not signed the e-form after 3 business days. ISSS cannot review and authorize the CPT until we have received a completed CPT Request e-form that includes confirmation from the second approver.
Yes! Once you click on the CPT Request e-form through the email you receive, there is a link at the top of the form called “Curricular Practical Training (CPT) Request” that will open a page with the information the student provided on their section of the e-form. The offer letter can be found at the bottom of that page in a separate section called “attached file(s)”.
Please see below for the link to use to access the student’s section and offer letter:
Yes. The field that asks second approvers to briefly explain how this internship is an integral part of the student’s major curriculum and how the student will gain practical training through the internship opportunity feeds directly into SEVIS, the immigration system accessed by the Department of Homeland Security. The information that the second approver puts in this field is subject to audit by the Department of Homeland Security. While we understand the potential redundancy of this field and the internship agreement form, we hope that this helps clarify the importance of the field you are being asked to complete. The internship agreement form is not required by ISSS, but it may be required by your department’s internship policies.
Yes. Please see below examples of sufficient descriptions and insufficient descriptions.
Examples of sufficient descriptions of how the internship is integral to the student’s major curriculum:
- Example 1: As an SDE intern at Amazon, the student will be with the Aurora SQL Team working on understanding existing codebase, fixing bugs and developing new features for operations. This aligns with their academic goals in their major field of study, Computer Science.
- Example 2: This internship directly relates to the student’s major field of study, Computer Science. Students may complete an internship for credit to support on the job training that complements in-class instruction.
Example 1 is the preferred approach given the level of detail it provides. While ISSS will accept the less detailed explanation, it’s best to provide as much information as possible linking the internship directly to the student’s major field of study.
Examples of insufficient descriptions of how the internship is integral to the student’s major curriculum:
- Example 1: The student will directly apply skills learned in the engineering program during the internship experience.
- Example 2: The student is approved for this internship by the academic department.
The internship credits need to have the potential to count towards the student’s academic program and appear on their transcript but it is not necessary for the credits to apply toward the student’s degree requirements each time the student enrolls in the internship course.
For example, if a PhD student is already in their dissertation stage and an internship course could be applied towards the student’s degree requirements, we would authorize CPT based on their enrollment in the internship course.
Yes.
Yes, as long as this is approved by the academic department. The internship class in which students enroll in order to be eligible for CPT must be a course for credit that could count towards their degree. If the academic department approves the student’s subsequent enrollment in the internship course over multiple semesters, ISSS can accept this as meeting the requirement to be eligible for CPT.
The minimum is one credit. ISSS does not set a maximum number of credit hours for the internship class. We defer to the academic department, as each department may have their own internship policies depending on the course requirements and contact hours.
Yes, as long as the following holds true:
- the internship course is approved by the academic department in which the student’s major field of study is housed
- the internship is directly related to the student’s major field of study and
- the internship credits could apply towards the student’s academic program
No. There is no minimum GPA requirement for a student to be eligible for CPT unless the academic department has a GPA requirement for their internship class.
The academic department has some discretion when deciding what the internship dates can be. However, ISSS policy dictates that for the purposes of CPT the internship start and end dates cannot overlap with another semester. CPT authorization can begin after the previous semester ends. The CPT authorization must end before the first day of the next semester. For example, if the Spring Semester ends on May 4, 2022, then you can request CPT to start as early as May 5, 2022. If the student is graduating, the internship end date can be no later than the last day of the semester or semester term in which the student completes their degree.
No. One of the requirements for CPT is that students need to have completed one full academic year (Fall & Spring semester) of continuous full-time enrollment in active nonimmigrant status. ISSS can authorize CPT prior to the grades in a student’s second semester posting. Please note, if a student receives an incomplete grade(s) they must complete the requirements of the Incomplete within the deadline set by the faculty member.
If applying for CPT based on enrollment in an internship course, the student must be enrolled in the course before they submit the CPT request to ISSS. ISSS will not authorize the CPT until we confirm enrollment in the course. Therefore, the student should try to enroll in the course as early as possible.
If a student withdraws from the internship course upon which their CPT has been authorized, then their CPT authorization will be immediately cancelled and they may face loss of F-1 status if ISSS determines they have worked without authorization.
CPT authorization is employer specific. If a student changes their internship placement, then ISSS must approve the change prior to the student working for the new employer. If a student changes employers without prior authorization from ISSS, then they face the loss of their F-1 status.
No. An independent study does not count as an internship class for the purposes of CPT eligibility.
No. CSVC 1000 is a non-credit bearing course. Students using an internship course for CPT eligibility must be enrolled in an internship course for credit that could count towards their degree.
The internship course needs to have the ability to apply towards the student’s degree program. If the course can be taken as Pass/Fail and still count towards their degree that is allowed. If the internship course will not count towards a student’s degree if taken as Pass/Fail then the course must be taken for a letter grade.
A CPT extension requires an update to the student’s SEVIS record. It is important that ISSS has significant documentation of the academic necessity of the extension. CPT authorization must be an integral part of an established curriculum, not a supplemental training experience. If audited, CU Boulder and ISSS need to be able to show how CPT meets this requirement, including the extension of CPT beyond the original requested end date.
Examples of explanations with a sufficient academic reason justifying the CPT extension:
Example 1: This student is working on developing a handbook for fixing bugs and requires 1 additional week to complete the project which will be a significant component for the evaluation of this student successfully completing their portfolio at the end of the internship.
Example 2: After working on the project, the student realized that they will require 2-3 extra weeks to finish the project properly. Additionally, the student can gain exposure to research in new domains that will be included in the final report for the internship course.