Curricular Practical Training (CPT)
CPT provides an F-1 visa regulatory framework for experiential learning activities outside the classroom, including internship, training, co-op education, and even employment that is tied directly to your major.
The U.S. government defines CPT as:
“a curricular practical training program that is an integral part of an established curriculum. Curricular practical training is … alternative work/study, internship, co-operative education, or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school."
Regulatory citation: 8 CFR 214.2(f)(10)(i) CPT provides an F-1 visa regulatory framework for experiential learning activities outside the classroom, including internship, training, co-op education, and even employment that is tied directly to your major.
For simplicity, the word training is used throughout the CPT guidance here to cover the range of possible CPT activities because that word appears in the term CPT.
For reasons that will be explained below:
- If you will be paid for the training, CPT authorization is required. Payment includes any remuneration or compensation, such as money, meals, lodging, transportation, etc.
- If you will not be paid for the training, CPT authorization is not required but it is strongly recommended.
CPT authorization is provided in writing by GEO and, if it is required (vs. recommended), it must be obtained before you start your training. CPT authorization cannot be provided retroactively by even one day.
Yes. To be eligible for CPT authorization, the training must be directly tied to the major field indicated on your current VCU I-20.
Some students, training organizations, and even other VCU units use definitions of training that do not necessarily tie the activity directly to your major.
But, according to DHS, to be eligible for CPT authorization, the training must be directly tied to the major indicated on your current VCU I-20. Some students, training organizations, and even other VCU units use definitions of training that do not necessarily tie the activity directly to your major.
But, according to DHS, to be eligible for CPT authorization, the training must be directly tied to the major indicated on your current VCU I-20.
Yes. CPT authorization can be used for training at VCU. However, CPT eligibility requirements and authorization procedures are complex.
If you will be paid an hourly wage as a VCU employee for the training, the training could be authorized as a form of On Campus employment.
For information about On Campus employment authorization, please go to https://global.vcu.edu/students/immigration/f-1_on-campus_employment/
Yes. CPT authorization can be used for training outside of VCU. Most CPT authorization is for training off campus.
Yes. Training authorized by CPT can be paid or unpaid.
As noted above, CPT provides an F-1 regulatory framework for your training and it can be paid or unpaid.
CPT is not primarily employment authorization. It is not simply a way for you to be employed in the U.S. (on- or off-campus) in order to make money.
However, CPT authorization automatically includes employment authorization for the training, whether on- or off-campus, so that if you will be paid for your authorized CPT you will already have the needed employment authorization for the training.
If you will be paid for the training, CPT authorization is required. Payment includes any remuneration or compensation, such as money, meals, lodging, transportation, etc.
If you will not be paid for the training, CPT authorization is not required but it is strongly recommended. Payment includes any remuneration or compensation, such as money, meals, lodging, transportation, etc.
CPT authorization is recommended (but not required) for unpaid training because unpaid internships can easily change from unpaid to paid.
Example: Your training starts out as unpaid but, after a few weeks, the training organization offers to pay you for the training. The unpaid training is now a paid training. CPT authorization is required for paid training. If you obtain CPT authorization for an unpaid training, you will already have the needed CPT authorization for the paid training in hand.
Yes. The U.S. Department of Labor (DOL) has the authority to review employer records to ensure that all workers (domestic and international) have employment authorization (if needed) and are being treated fairly by their employers.
If DOL determines that a worker does not have the required employment authorization, they can penalize the employer (fines and other sanctions).
DHS has the authority to review international student record to ensure that they have not been employed without authorization while in the U.S.
If DHS determines that you were employed in the U.S. without authorization, they could penalize you for it (loss of status, difficulty in resuming status, denial of future visa applications, etc.)
To be eligible for CPT authorization the training must be:
- Tied directly to the major field indicated on your current VCU I-20, and
- Conducted according to the terms outlined in your Request for CPT Authorization (form). For information about the Request for CPT Authorization, please see below.
To be eligible for CPT authorization, the training must meet the eligibility criteria above and you must be:
- In F-1 status and not have completed the program of study on your current VCU I-20.
- Enrolled for at least one academic year of full-time study at VCU in a nonimmigrant status in the U.S. One academic year means two consecutive semesters: either fall plus spring or spring plus fall. See NOTE below for the only exception to this rule.
- Enrolled during the course of CPT authorization in either:
- A major that officially requires all students enrolled in it to undertake training in order to graduate from VCU with a degree in the major. Officially means published in the current VCU Bulletin, OR
- A VCU class in your major that provides academic credit for training. Example: A class in your major called Independent Study, Fieldwork, or similar.
NOTE: The only legal exception to the rule (item 2 above) that you be enrolled for at least one academic year of full-time study is the following. If you are a graduate student and your program of study officially requires all students enrolled in the program to engage in training during the first year of the program, you may be eligible for CPT authorization. Officially means published in the current VCU Bulletin.
Yes. CPT can be authorized for the fall and/or spring semesters.
NOTES:
- CPT can be authorized only for one semester (fall or spring) at a time. The dates of the semester are determined by the VCU academic calendar.
- Each period of CPT authorization (fall or spring) is distinct and requires a separate CPT application to GEO. All CPT eligibility requirements apply to each period of CPT authorization.
- CPT authorization has effective dates: a start date and an end date. The effective dates of each CPT authorization must either align with the first and last day of classes for the semester as listed in the VCU academic calendar or they must fall between those dates.
Yes. CPT can be authorized for winter or summer breaks.
NOTES:
- CPT can be authorized only for one semester (fall or spring) at a time. The dates of the semester are determined by the VCU academic calendar.
- Each period of CPT authorization (fall or spring) is distinct and requires a separate CPT application to GEO. All CPT eligibility requirements apply to each period of CPT authorization.
- CPT authorization has effective dates: a start date and an end date. The effective dates of each CPT authorization must either align with the first and last day of classes for the semester as listed in the VCU academic calendar or they must fall between those dates.
Yes. Part-time CPT authorization is available for training activity of 1-20 hours per week.
NOTES:
- Undergraduate and Graduate students are eligible for part-time CPT authorization.
- If you are authorized for part-time CPT, you remain eligible for On Campus employment authorization.
- Prior to graduation you are not permitted to be employed in the U.S. for more than 40 hours per week through any single or combined employment authorization.
- While engaged in authorized CPT training you must continue to enroll in a full course of study (FCS) or have received a Reduced Course Load (RCL) or Full Time Equivalent (FTE) authorization from GEO. RCL and FTE authorization cannot be provided simply to allow you to engage in CPT.
Yes. Full-time CPT authorization is available for training activity of 21-40 hours per week.
NOTES:
- Undergraduate students are eligible for full CPT authorization during winter and/or summer breaks only.
- Undergraduate students are not eligible for full-time CPT authorization during the fall and/or spring semesters.
- Graduate students are eligible for full-time CPT authorization during fall and/or spring semesters and during the winter and/or summer breaks.
- If you are authorized for full-time CPT you are not eligible for on-campus employment authorization.
- Prior to graduation, you are not permitted to be employed in the U.S. for more than 40 hours per week through any single or combined form of employment authorization.
- If you are authorized for full-time CPT for a period of 365 days you are not eligible for Optional Practical Training (OPT) authorization.
- While engaged in authorized CPT training you must continue to enroll in a full course of study (FCS) or have received a Reduced Course Load (RCL) or Full Time Equivalent (FTE) authorization from GEO. RCL and FTE authorization cannot be provided simply to allow you to engage in CPT.
As long as you meet the CPT eligibility criteria listed above you may be eligible for several CPT authorizations prior to the completion of the program identified on your current VCU I-20.
If you are authorized for full-time CPT for a full year (365 consecutive days) you will not be eligible for post-completion Optional Practical Training (OPT). Part-time CPT authorization has no effect on OPT eligibility.
As noted above, CPT authorized training can be paid or unpaid. If you will be paid for your training, you can be paid:
- A wage as an employee of the internship organization. In this case, you should must record the actual number of hours you work per week the training organization’s time recording system and be paid an identifiable wage for each hour worked. This is to ensure that you and your employer can both document the number of hours you work per week to show your respective compliance with the CPT regulations.
- A stipend, honorarium, or other flat amount by the internship organization. In this case, you and your training organization should identify a way for you both to keep track of the number of hours you work per week. This is to ensure that you and your employer can both document the number of hours you work per week to show your respective compliance with the CPT regulations.
If you start your training before obtaining CPT authorization, and the activity is paid, you will have engaged in unauthorized employment, which is a violation of the F-1 regulations that leads to immediate loss of F-1 status.
CPT authorization is provided by GEO in the form of an updated I-20 marked for CPT authorization. U.S. government authorization is not required for CPT.
You need to plan ahead for CPT authorization. To help you do so, here are the steps (in order) to CPT authorization:
- Review the CPT eligibility criteria here to ensure that you are or will be eligible for CPT as of the start date of your training.
- Attend a GEO CPT Workshop.
- Consult with your major field academic advisor to clarify how the training will be tied directly to your major.
- Search for a training opportunity that fits within the CPT eligibility criteria and restrictions above. Apply for the training and receive an offer from the organization to join them for training.
- Obtain a Request for CPT Authorization (form) from GEO. Complete the Request for CPT Authorization and return it to GEO
- GEO will review your Request for CPT Authorization. If the request can be legally approved, GEO will provide an updated I-20 for CPT authorization.
- Start your authorized CPT activity.
All of the work required for steps 1-5 are your responsibility, so GEO cannot estimate the time needed to complete these steps.
For step 6, please see “How long does it take GEO to provide CPT authorization?” below.
GEO CPT Workshops are regularly scheduled group workshops for students interested in knowing more about CPT including how to obtain CPT authorization from GEO.
GEO cannot consult with you individually about CPT until after you have attended a GEO CPT Workshop. For information about GEO CPT Workshops, please send an email to GEOIS@vcu.edu
The Request for CPT Authorization is a GEO form used by Immigration Advisors to gather the information and documents needed from you to review your request for CPT authorization.
The form:
- Is completed by you, your major department academic advisor, and an official from your training organization (usually your supervisor).
- Requests such critical information as: name of the training organization; your expected worksite address(es); your training duties; how the training relates to your major; how the duties will be evaluated during the course of your training; how the training will be evaluated at the conclusion of your training; whether you will be paid for the training and, if so, how much; name and contact information of your supervisor(s) at the training organization, etc.
- Clarifies the CPT compliance issues that apply to you — and to your training organization.
The form must be signed by you, your major academic advisor, and your training organization.
The Request for CPT Authorization form is not a U.S. government form and is not submitted to the U.S. government during CPT processing.
The form is not available online. It is available from GEO only by email request (GEOIS@vcu.edu).
You can submit a Request for CPT Authorization to GEO:
- No sooner than 60 days before the anticipated first day of training
- No later than 30 days before the anticipated first day of training
GEO cannot accept a Request for CPT Authorization submitted 61 or more days before the anticipated first day of training.
The 30-day deadline is not absolute but the later you submit a completed Request for CPT Authorization to GEO, the more likely you will not be able to start your activity in time to start the training when planned.
If you submit a complete Request for CPT Authorization to GEO, you may expect a response from us within 10 business days.
A complete Request for CPT Authorization means all questions on the form are answered; all required signatures obtained; and all required documents are attached.
For compliance and customer service reasons, GEO cannot review Request for CPT Authorizations that are incomplete. If you submit an incomplete Request for CPT Authorization to GEO, it will be returned to you for completion and re-submission.
For help finding a training opportunity, please consult with our colleagues in Career Services and VCU REAL.
Some students, outside organizations, and even other VCU units use definitions of training that do not tie the activity directly to your major.
But according to the F-1 regulations, CPT authorization can be provided only for training that is integral to an established curriculum — that is, directly tied to the major indicated on your current VCU I-20.
GEO cannot provide information about how to find a training opportunity.
As part of GEO’s review of your completed Request for CPT Authorization, we will look closely at the terms of the training.
If GEO has concerns about the training’s eligibility for CPT authorization (or about any of the information or documents provided with the Request for CPT Authorization), we will bring them to your attention in writing (email) so that you can address the issues.
For compliance and customer service reasons, GEO cannot preview the terms of a training opportunity prior to your submission of a completed Request for CPT Authorization.
If the CPT training will be paid, you will need a SSN. For information about obtaining a SSN, go to global.vcu.edu/students/immigration/social_security_number/
Maybe. For general information about U.S. tax obligations for F-1 students, visit global.vcu.edu/students/immigration/taxes/