- The general public comment period closed November 9 after nearly 9,000 comments.
- An October 2026 survey found 69% of 734 current and former international students would likely avoid U.S. enrollment.
- Comments on the information collection are due December 7, 2026, under docket ICEB-2026-0100.
Checked against the Federal Register
A university coalition urged the Department of Homeland Security to withdraw proposed charges of $70,000 for an initial OPT recommendation and $30,000 for a subsequent one, warning that the costs could drive international students away from U.S. campuses.
The proposal would affect schools recommending F-1 students for optional practical training, including STEM extensions. It remains under review, and students can continue using the current process while the agency considers the rule.
The Presidents' Alliance on Higher Education and Immigration filed its objection on November 9, the day the general comment period closed. The coalition represents nearly 600 colleges and universities.
DHS published the proposal on October 8, 2026. The charge would be paid by institutions making OPT recommendations, with schools allowed to seek reimbursement from students or employers.
The proposal would put the largest charges on institutions recommending students
The proposed amount depends on whether a school is making an initial or subsequent recommendation. A student applying for initial OPT and then a STEM extension could trigger both charges.
Students currently pay an application fee of about $500. The proposed institutional payments are separate from that charge.
| Charge | Proposed amount | Applies to |
|---|---|---|
| Initial recommendation | $70,000 | Each student a school initially recommends for OPT |
| Subsequent recommendation | $30,000 | A later recommendation, including a STEM OPT extension |
| Initial and one subsequent recommendation | $100,000 | Combined institutional payments for those two recommendations |
| Current student application fee | About $500 | The student’s OPT application |
The proposal places the payment obligation on the recommending institution. A school could ask the student or a prospective employer to reimburse it, but would transmit the payment to DHS.
OPT permits F-1 students to gain work experience related to their field of study. It may take place before or after program completion. Students generally may receive 12 months, with qualifying STEM graduates potentially eligible for an additional 24 months.
Boston University and the Presidents' Alliance warn that enrollment could fall
Boston University President Melissa Gilliam and Provost Colin Duckett told DHS they expect the fee to affect enrollment, classrooms and research. They warned that students and employers may not be able to cover the proposed amount.
“The reduced international enrollment resulting from the proposed rule would threaten the vibrancy of BU’s classrooms and laboratories, impeding our ability to advance our academic and research missions.”
Gilliam and Duckett also said few students could afford a $70,000 charge and many employers would struggle to pay it. They said BU could be forced to choose among eligible students based on who could afford the cost.
Willis Wang, BU’s vice president and associate provost for global programs, said the proposal “creates immense and unwelcome uncertainty for our international student community.” He also warned that the fee structure could steer talented people away from the United States.
The alliance cited an October 2026 Institute for Progress survey of 734 current and former international students. In it, 69% said they probably or definitely would not have enrolled in a U.S. institution if the fees had been in place. Among STEM students, the figure was 70%.
DHS estimates that OPT participation among international students would initially fall by 27 percent under the proposal, with the decline potentially reaching 50 percent. Those figures are agency projections, not reported enrollment changes.
Schools could absorb the charges or restrict recommendations
Some universities say they could not cover the proposed payments from their budgets. An analysis of comments by Association of American Universities member institutions found that Tulane University estimated annual costs of $13 million. Eight institutions, including Arizona State University, estimated bills above $100 million annually.
The alliance also cited estimates from schools of different sizes. One institution with fewer than 500 international students projected costs of $5.4 million a year, more than its net tuition revenue from F-1 students. A public institution with 6,000 international students projected annual costs of $60 million.
If schools cannot absorb the expense, students or employers could face requests to reimburse them, or institutions could make fewer recommendations. BU’s leaders warned that ability to pay could become a factor in which eligible students receive access. Employers hiring OPT participants could therefore face reimbursement requests or fewer potential hires.
The alliance projected participation could fall by as much as 79 percent if institutions paid the full $100,000 for an initial recommendation and extension. That is a coalition projection, distinct from DHS’s lower initial estimate and possible later decline.
DHS says the fees are intended to address fraud and protect U.S. workers. The alliance questioned whether the charges would prevent fraud, while university objections argue that the payment requirement could burden institutions and students who follow program rules.
State officials added their opposition on November 12, 2026. Connecticut Attorney General William Tong said he joined a multistate comment letter opposing the proposal; Maryland Attorney General Anthony G. Brown also joined. The attorneys general argue DHS lacks authority to impose the charge without congressional approval and that the agency did not adequately consider harms and less burdensome alternatives.
Their letter says more than 294,000 students took part in OPT nationwide during the 2024-2025 academic year. Maintaining participation at that level could cost institutions $12.9 billion annually, the attorneys general said. Separately, NAFSA estimates cited by the alliance put international students’ contribution to the U.S. economy at $42.9 billion and their support for more than 355,000 jobs during the 2024-25 academic year.
Applicants can keep using the current school recommendation and USCIS filing process
Students considering OPT should continue with the existing school and USCIS steps. A designated school official recommends the student for OPT and issues Form I-20. The student then files Form I-765 with USCIS.
Work can begin after the student receives the employment authorization document, or EAD. The proposed institutional fees have not replaced this process.
The general public comment period closed November 9. The remaining December deadline applies to comments on the information collection, not a reopening of the broader comment period.
DHS has not set a date to publish a final rule or an effective date for the proposed fees. The proposal says the charges would take effect 60 days after a final rule’s publication. Boston University’s International Students & Scholars Office has scheduled OPT workshops through December for its students.
