At a glance
- Pre-completion OPT requires USCIS approval and an Employment Authorization Document before work starts.
Reviewed November 10, 2026
U.S. District Judge Julia Kobick heard arguments on a preliminary injunction request in Massachusetts and took it under advisement without ruling. The August guidance remains in effect for F-1 students and the schools that authorize their Curricular Practical Training (CPT).
The case, Association of American Universities v. DHS, No. 1:26-cv-14520, challenges the interpretation set out in two Student and Exchange Visitor Program messages. Four higher-education groups filed suit on October 5, 2026.
The groups want any court order to cover their member schools, including Stanford. The judge has not granted that request. The guidance remains active while the case proceeds.
The August interpretation narrows which internships can count for CPT
CPT lets eligible F-1 students undertake practical training connected to their academic programs. The challenged messages, issued on August 12 and August 24, 2026, say training must be integral to an established curriculum and required for every student in the relevant degree program to graduate.
That standard may exclude optional internships taken for course credit. The plaintiffs say the government changed its position without explaining the shift or seeking public comment. They argue the messages upended a practice schools had followed for more than 35 years.
The groups suing are the Association of American Universities, the Presidents’ Alliance on Higher Education and Immigration, NAFSA: Association of International Educators, and the Association of Independent Colleges and Universities in Massachusetts. They brought claims against U.S. Immigration and Customs Enforcement, the Department of Homeland Security and the Department of Justice.
The Justice Department disputes the plaintiffs’ standing because no school has faced an enforcement action. It also argues the messages clarify existing requirements rather than create a new policy. The government says a school may still authorize CPT when training is integral to a student’s field of study.
Stanford students discussed the policy the day before the hearing
The Associated Students of Stanford University hosted the Stanford International Student Roundtable on Thursday. The court hearing followed on Friday, November 6. The event and hearing were separate; the roundtable’s specific venue has not been identified by ASSU, and the hearing was in Massachusetts.
Undergraduate Senate co-chair Laila Ali ’28 said students’ experiences across academic fields could help Stanford consider its response.
“We’re particularly interested in understanding how changes to CPT policies have affected students across different majors and career paths. We want to hear what’s worked, what hasn’t and whether there are solutions already being implemented in certain departments or at other universities that Stanford could learn from.”
Stanford’s Bechtel International Center has paused CPT applications for internships not required to complete a degree, until further notice. The Earth Systems Program may qualify for an exception because its declared majors must complete an internship to graduate. But students on the roundtable said Bechtel had not confirmed that the program meets the federal test.
ASSU is working with Bechtel and the Office of the Vice Provost of Undergraduate Education on possible responses. The Undergraduate Senate is also consulting on proposals. Ashton Dolce ’29, co-chair of the Senate’s Communications Committee, said students should have a role in shaping those discussions.
“Often the folks with the best solutions are the closest to the problem. It’s no different here.”
Dolce added that international students’ concerns should reach Stanford’s administration.
Other universities have kept different CPT processes in place
School policies vary. Berkeley suspended Course Credit CPT applications but continues processing placements that programs document as graduation requirements for all students. Penn resumed considering requests for training that is required within an established curriculum.
Declarations from the plaintiffs describe reduced approvals elsewhere. The University of Wisconsin reported a 60% drop in CPT approvals between fall 2025 and fall 2026. Cornell said it stopped authorizing CPT for internships tied to course requirements, its engineering co-op program and dissertation research.
Students can ask about CPT eligibility and pre-completion OPT
Pre-completion OPT may be another route. It requires a recommendation from a designated school official and USCIS approval, including an Employment Authorization Document, before a student starts working. Using it reduces the time available for post-completion OPT.
On September 1, 2026, Stanford’s Bechtel International Center paused CPT applications for internships not required for degree completion; the pause is also posted on the center’s website.
This article provides general information and is not legal advice. Consult a qualified immigration attorney about your specific case.
Keep reading
All USCIS updates →What to do now
- Ask your designated school official whether your program and internship qualify for CPT.
- Check what documentation your school requires.
- Ask about pre-completion OPT if CPT is unavailable, and wait for USCIS approval and an Employment Authorization Document before working.