What are OPT and CPT?
Optional Practical Training (OPT) is defined by U.S. Citizenship and Immigration Services (USCIS) as a practical work experience for students in valid F-1 visa status that is directly related to their degree program, commensurate with their degree level, and intended to enhance and supplement the formal classroom education. Currently all international students in valid F-1 visa status, provided that they maintain their immigration status, are eligible to apply for OPT.
Curricular Practical Training (CPT) is employment that is directly related to a student’s field of study, commensurate with their degree level, and an integral part of an established curriculum. It is an internship, practicum, or other type of employment that is either required for the degree program or taken for credit toward the degree. Currently Princeton approves CPT for graduate students in some specialized programs, but not for any undergraduate students.
Why doesn’t Princeton approve CPT for undergraduates?
As noted above, USCIS regulations require that CPT only be used for work or internships that are “an integral part of an established curriculum” at the student’s institution. Princeton has historically been guided by interpretations from USCIS and the Student and Exchange Visitor Program that permit CPT only in situations where an internship conveys course credit and/or is required for the student’s major field of study. The existing structure of Princeton’s undergraduate curriculum does not make CPT appropriate since we do not treat internships as an integral part of an established curriculum for undergraduates according to either component of this definition.
Why can’t Princeton make a change and begin to offer CPT right away, in time to help students who are affected by the current OPT processing delays?
Approving CPT would require either that Princeton offer undergraduate students course credit for internships or change the curriculum to make practical experience a requirement (perhaps for a subset of undergraduate concentrations). Either of these changes would require approval from the appropriate channels of University governance, including the Committee on the Course of Study (COCS) and the University’s faculty. This would take months to accomplish, just as Yale’s recent decision to offer CPT was the culmination of work that began early in the spring of 2019.
Why doesn’t Princeton offer course credit for internships?
Every course at Princeton undergoes careful review by the Office of the Dean of the College before it is listed as part of the undergraduate curriculum to ensure that the work and requirements are appropriate for a Princeton course. This means that Princeton would offer course credit for a summer internship only if it was confident that it would be the equivalent of a Princeton course.
Offering course credit for CPT-related internships would also raise questions about fairness and equity — we could not allow some students to earn course credit for internships while others do not have this option. This would require us to consider course credit for other forms of summer internships as well. Currently, domestic students must frequently turn down unpaid internships because their prospective employers make earning course credit a condition of participating in unpaid summer work.
Addressing these questions about course credit for summer internships would also need to account for the fact that Princeton has no formal summer term of instruction, and faculty frequently devote their summers to research and scholarship projects that might prevent them from advising and supporting students during their summer work experiences.
Couldn’t internships be offered for half-credit?
For more than a century, Princeton has used a system in which all undergraduate courses count for one unit of course credit, and changing that would require approval by pertinent governance bodies and the faculty. Other schools that offer course credit for internships may offer half-credit courses or they may use a credit hour system that allows awarding a fraction of course credit for a summer internship. The current structure of our undergraduate curriculum would need to be revised to permit this as an option. Although half-credit courses exist in the graduate curriculum, undergraduates permitted to enroll in these courses do so in groups of two, so that together both courses equal one credit.
Could independent work or independent projects be sufficient grounds for awarding CPT?
Our current approach does not permit students to be paid for research that is connected to a University requirement. The principal example involves research that is connected to the senior thesis. A student working in a lab for the summer could either be paid for that work as a research assistant, or could use the research toward a senior thesis project, but could not do both. For this reason, students who are participating in paid summer internships are normally ineligible for senior thesis funding during that same period.
Why can’t undergraduate students take the graduate courses that offer CPT? How are these different from other graduate courses that undergraduates can apply to take for credit?
Princeton offers CPT for certain graduate programs -- including the MPA and the two- year Masters in Finance degree -- which require summer internships. Beyond that, a few doctoral programs have courses that are available to international graduate students who need work authorization, mostly in fields related to engineering. International undergraduate students frequently ask to take these courses to facilitate CPT approval. We have had to reject these requests because CPT must be “an integral part of an established curriculum” for their concentration, which these courses are not.
What about certificates that require an internship, or departments like WWS that require field experience?
Internships required by certificate programs or minors are excluded from CPT under USCIS guidelines. Immigration regulations require that CPT be related to the “student’s major area of study.” In practice, this means that CPT can only be approved if the employment is related to the degree listed on their transcript and, consequently, on the student’s I-20 (certificate of visa eligibility).
The WWS does require something called “Field Experience,” which students can satisfy in a range of ways, including summer internships in public policy settings. We have not heard of any cases in which a student was prevented from participating in this fieldwork due to immigration regulations. One key difference may be that students participating in this fieldwork have not been receiving funding from their host organizations. But this is an ongoing conversation, and could provide an example of how a department could include practical experience into its curricular requirements for the degree that would be appropriate for CPT.
How will the University explore the possibility of offering CPT in the future?
The Office of the Dean of the College will convene a small working group this summer to explore the range of ways that this kind of practical learning could potentially be connected to the curriculum for all undergraduate students. Any changes along these lines would need to be supported by the faculty in the academic departments, and ultimately approved through the appropriate channels of University governance. For example, curricular changes require formal approval from the Committee on the Course of Study, which makes decisions about course units and credits as well as changes to departments’ requirements for the degree. Significant changes would also require the endorsement of the Academic Planning Group, and eventually, a majority of Princeton’s voting faculty.
How can students stay involved in this process?
Student perspectives will be critical to the working group’s deliberations. As the plans for the working group take shape, we will be in touch with students to continue to solicit input and feedback. This could take the form of student representation on the working group, surveys and focus groups with students, or both.