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US universities rethink CPT program after ICE warning: What Indian students need to know about the pause
Several US universities are reevaluating their Curricular Practical Training (CPT) programs following a warning from federal authorities.
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Several US universities have paused or reconsidered parts of their Curricular Practical Training (CPT) programs after federal immigration authorities warned that schools and officials could face serious consequences for improperly authorizing off-campus training for international students.
The move may create uncertainty for Indian students in the US, particularly those enrolled in programs that use CPT as a way to gain work experience while completing a degree. The issue is especially significant for students relying on so-called “Day 1 CPT” arrangements, which have come under increased scrutiny.
The memo was introduced on August 12 by US Immigration and Customs Enforcement (ICE), warning designated school officials about their liability when authorizing Curricular Practical Training (CPT) for international students.
Why are US universities pausing CPT?
CPT allows eligible F-1 students to undertake internships, cooperative education or other practical training connected to their academic program. Unlike Optional Practical Training (OPT), CPT is generally authorized through the university’s Designated School Official (DSO), rather than through a separate USCIS employment authorization process.
Federal rules require the practical training to be an integral part of an established curriculum and directly related to the student's major.
ICE's August 12 guidance warned DSOs that CPT approvals must comply with those requirements. The agency said improper authorization could expose officials to administrative or legal consequences and could put a university's ability to host international students at risk.
That warning has prompted universities to reassess CPT programs that may be considered optional rather than a mandatory part of a degree.
Which universities have paused CPT?
UC Berkeley, UC Davis, and University of Colorado Boulder are among institutions reported to have paused or reconsidered certain CPT arrangements.
UC Davis, for example, said it was temporarily suspending applications for “Course Credit CPT” that is considered integral to a program but is not a degree requirement. The university said degree-requirement CPT would continue to be processed. Students who had already received a CPT I-20 were also not affected by the temporary suspension, according to the university.
The distinction is important. The latest developments do not amount to a blanket federal ban on CPT.
Instead, universities are examining whether individual programs satisfy the existing federal requirements.
Why Indian students could be particularly affected
The changes could have a significant impact on Indian students because CPT has been used by international students to gain practical work experience while remaining enrolled in US degree programs.
Students using programs marketed as “Day 1 CPT” face particular uncertainty. These arrangements allow students to begin practical training at the start of an academic program, but ICE has warned schools against treating CPT as a substitute for general employment authorization.
The concern is not simply whether a student has a job. The underlying question is whether the training is genuinely part of the academic curriculum.
ICE has now made clear that CPT cannot simply be an optional work opportunity attached to an otherwise unrelated course. The agency has also warned schools to ensure that the training is directly connected to the student's field of study.
What does the latest ICE guidance mean?
A subsequent ICE clarification issued on August 26 provided additional details on how the agency views CPT.
According to the guidance, foreign students must formally request CPT authorization from their DSO. The school must determine whether the practical training is integral to an established curriculum, directly related to the student's major and properly recorded in the student's SEVIS record.
The guidance also addresses a key distinction between CPT and OPT. OPT is optional and does not form an integral requirement of a student's academic program. CPT, by contrast, must satisfy the curriculum requirement.
ICE said that where practical training is an integral part of an established curriculum, participation cannot simply be optional for some students. The agency said the requirement applies regardless of citizenship.
That means US universities are now under pressure to ensure that CPT programs are structured as genuine academic training rather than employment programs attached to a degree.
What should Indian students do now?
Indian students currently using CPT should check directly with their university's international student office before making changes to employment or academic plans.
Students should also determine whether their CPT is a degree requirement, whether the training is directly connected to the major and whether the university has issued the appropriate CPT authorization and I-20.
A university temporarily pausing new CPT applications does not automatically mean every student already authorized for CPT must stop working. UC Davis, for example, specifically said students who had already received a CPT I-20 were not affected by its temporary pause.
