- The coalition estimates $12.9 billion in annual institutional costs at 2024–2025 participation levels.
- More than 294,000 students participated in OPT nationwide during that academic year.
- DHS says the proposal targets fraud and abuse and discourages OPT use to bypass H-1B requirements.
The University of Michigan opposed proposed OPT fees on November 10, 2026, joining a multistate coalition challenging charges of $70,000 for an initial recommendation and $30,000 for a later one, including a STEM OPT extension.
The proposed F-1 OPT Fee Rule would place the payment obligation on colleges and universities recommending students for practical training. F-1 students, schools and employers could face consequences if the plan advances, but DHS has not announced a final-rule or effective date.
Schools could seek reimbursement from students or employers, but they would still have to send the payments to DHS. The coalition and Michigan have urged the department to withdraw the proposal.
The dispute concerns the cost of access to training connected to a student’s field of study. OPT generally allows eligible F-1 students to gain practical work experience after graduation.
A qualifying STEM graduate may seek more time. The fee proposal covers both initial recommendations and later ones, including extensions for eligible STEM graduates.
The charges remain proposed. Here is how the amounts compare with the training periods students may seek:
The proposal would attach large payments to school recommendations
| Recommendation or training period | What the proposal or current program provides |
|---|---|
| Initial OPT recommendation | Institution would pay $70,000 before recommending a student. |
| Subsequent recommendation | Institution would pay an additional $30,000, including for a STEM OPT extension. |
| General OPT eligibility | Students are generally eligible for 12 months. |
| Qualifying STEM graduates | May receive an additional 24-month extension. |
Institutions would transmit the payments to DHS. They could seek reimbursement from students or employers, but the proposal places the payment and remittance responsibility on the institution.
That structure leaves schools weighing a potential charge against whether they will recommend students. Employers could be asked to reimburse a university, but reimbursement is not described as mandatory.
DHS’s stated rationale, as summarized by Michigan, is to address fraud and abuse and discourage using OPT to get around H-1B caps, fees and prevailing-wage requirements. Michigan argues the department has not shown why the proposed amounts are needed to meet those aims.
States and universities warn the charges could restrict training and hiring
Maryland Attorney General Anthony G. Brown said he joined a coalition submitting comments against the proposal. Connecticut Attorney General William Tong later announced his participation in the same coalition.
The coalition argues DHS lacks authority to impose the charge and characterizes it as a tax Congress has not authorized under the Immigration and Nationality Act. It also says the department allowed only 30 days for public comment without adequate justification.
The coalition estimates that maintaining participation at 2024–2025 levels could cost institutions $12.9 billion annually. More than 294,000 students participated in OPT nationwide during that academic year, according to the coalition’s figures.
Tong called the proposed combined charge a threat to universities and the economy. “This unlawful $100,000 fee punishes our universities, drives away talent, and threatens our economy.”
The University of Michigan’s comment letter urges DHS to withdraw the proposal in its entirety. The university says the department has not adequately demonstrated the need for the rule or shown that the proposed amounts are necessary to achieve its stated objectives.
The Presidents’ Alliance on Higher Education and Immigration also submitted comments opposing the fees and seeking withdrawal. Its president and CEO, Miriam Feldblum, said the charges could put practical training beyond the reach of most students and campuses if implemented.
“If implemented, the proposed fees will put practical training out of reach for most students and campuses, effectively dismantling the OPT program as we know it, making it harder for employers to hire U.S.-educated international graduates, and driving away new international students.”
The Alliance describes itself as representing 580+ college and university presidents and chancellors. Its members’ institutions enroll over five million students in 42 states, D.C., and Puerto Rico.
A Brown-RISD Dual Degree student, who was granted anonymity because of concerns about visa status, described uncertainty about future work. The student planned to work in the United States for three years using a STEM extension, but said job opportunities could be limited if the administration continued without constraint.
“The visa uncertainty and fear is always tied to the political uncertainty and fear,” the student said. The statement reflects concern about the broader immigration climate, not an account of fees already being charged.
A separate rule would replace duration-of-status admission
A different DHS rule addresses how long certain F, J, and I nonimmigrants may be admitted to the United States. Published July 17, 2026, it would remove duration-of-status, or D/S, references and move to fixed periods of authorized stay.
That rule also includes transition provisions for OPT applicants. During the first six months after it takes effect, certain applicants for post-completion OPT or STEM OPT employment authorization would receive a temporary reprieve from filing an extension-of-stay application.
An F-1 student who timely files such an application may continue a full course of study after the admission period expires while USCIS considers the filing. A student who no longer qualifies for the current nonimmigrant category cannot remain in the United States during the described gap.
The immediate question for schools and students is whether DHS changes course after receiving comments. No implementation date has been set for the fee proposal.
There are no supported filing steps for students or employers to take under a fee rule that has not been finalized. Watch DHS for a decision on whether it will withdraw or revise the proposal and for any final-rule and effective-date announcement.
