Brown University Indefinitely Suspends Undergraduate CPT Work Authorizations

Brown University has indefinitely suspended undergraduate CPT authorizations. The policy was released Nov. 9, and International Student and Scholar Services told F-1 students Nov. 11 that Brown would stop issuing them.

Curricular Practical Training (CPT) lets F-1 students take internships and other work activities in the United States. Brown said internships are not required for undergraduates to graduate and directed students seeking off-campus work to pre-completion Optional Practical Training (OPT) instead.

The policy gives no separate effective date, and the status of authorizations already issued remains unclear.

The suspension covers undergraduates. Students in six master’s programs that require an internship or practicum remain eligible for CPT; other master’s students do not.

Six master’s programs keep CPT eligibility

CPT is work authorization for practical training connected to a student’s curriculum. Brown’s change applies to undergraduate authorizations across the university, rather than only to students in particular concentrations.

Some Brown undergraduate programs have optional professional tracks that include an internship requirement. Those track requirements are distinct from the university’s stated reason for suspending undergraduate CPT: internship experience is not a graduation requirement for undergraduates overall.

The graduate exception is narrower. Eligibility remains for students in the six master’s programs where internship or practicum experience is required. Brown’s policy does not extend that eligibility to other master’s students.

Brown changed course after SEVP narrowed its reading of CPT

The Student and Exchange Visitor Program (SEVP), part of U.S. Immigration and Customs Enforcement, sent universities a message in August setting out its interpretation of CPT eligibility. SEVP said practical training must be required to complete a student’s degree. It also warned that noncompliance could affect a university’s ability to enroll international students.

After that message, ISSS stopped approving CPT requests that did not meet the stated requirements and began reviewing Brown’s guidelines. The university’s policy followed that review.

Brown’s reasoning turns on the difference between a degree requirement and an internship that may be part of an optional academic track. While some undergraduates can pursue professional tracks that require internship experience, Brown said internships are not required for undergraduate graduation. The university’s policy therefore suspends undergraduate CPT authorizations indefinitely.

Pre-completion OPT shifts approval to USCIS and uses OPT time

Brown identifies pre-completion OPT as the alternative for undergraduates seeking off-campus work. Unlike CPT, which Brown approved, OPT requires students to apply to U.S. Citizenship and Immigration Services (USCIS). The application costs $470.

Time spent on OPT before graduation counts toward the one year of OPT allowed per degree level. Students considering this route should account for that deduction when weighing when to use the authorization.

ISSS said advisers can discuss students’ program requirements and practical training options. Its announcement also offered help with questions:

“ISSS advisors are available to discuss your specific program requirements, explore practical training options, and assist with any questions.”

Undergraduates considering off-campus work should discuss their plans with ISSS advisers and apply to USCIS for pre-completion OPT, the alternative Brown identifies.