New Guidance May Significantly Impact Curricular Practical Training Approvals

The Student and Exchange Visitor Program (SEVP) recently issued two Broadcast Messages (2608-01 and 2608-02) announcing increased scrutiny of curricular practical training (CPT) following "a rise in CPT authorizations that do not meet the regulatory requirements." The Broadcast Messages were in response to reported violations of CPT authorizations related to approval of training that is not an "integral part of an established curriculum," as required by 8 C.F.R. § 214.2(f)(10)(i). This latest guidance provides institutions with insight into the new interpretation of the CPT regulations; however, it does not amend those regulations or itself constitute binding authority. As the Broadcast Messages significantly impact previous treatment of CPT requirements, institutions should review this client alert and assess their CPT policies, program requirements, authorization procedures and communications to their campus communities.