Overview
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.
Background on CPT Programs
Eligible F-1 students are permitted to participate in practical training in the United States directly related to their major area of study. An F-1 visa is a nonimmigrant visa that permits a foreign national to seek admission to the United States to pursue a full course of study at an SEVP-certified educational institution. There are two primary types of authorized practical training: (i) CPT and (ii) Optional Practical Training (OPT). Under 8 C.F.R. § 214.2(f)(10)(i), CPT is defined as an "alternative work/study, internship, cooperative education or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school." A primary requirement for CPT authorization is that the training is an "integral part of an established curriculum."
Historically, SEVP has interpreted the "integral" requirement to permit certain internships to qualify as CPT, provided they were either required by the degree program itself or required by a course for academic credit (commonly referred to as Course Credit CPT). Under this approach, CPT could be authorized for an internship or other practical-training experience even if participation in the training was not a program requirement. This interpretation of "integral" has allowed institutions to expand its CPT offerings, which is reflected by the large number of institutions that have listed Course Credit CPT offerings that are not degree requirements.
This interpretation of integral in the CPT regulation has largely remained consistent since the final rule was promulgated in 1991. A large number of institutions have routinely offered Course Credit CPT and described such training on their websites.
Broadcast Messages
On August 12, 2026, SEVP published its first Broadcast Message to remind all designated school officials (DSOs) that federal regulations require CPT to be an integral part of an established curriculum. The Broadcast Message warns that improper CPT authorizations may result in increased scrutiny and potential action by SEVP and Homeland Security Investigations. It also provides that the signature on the Form I-20 constitutes a certification under penalty of perjury that the information provided is true and correct to the best of the DSO's knowledge.
On August 24, 2026, SEVP issued its second Broadcast Message, which provided additional guidance on CPT requirements and, in particular, an updated interpretation of the "integral part of an established curriculum" requirement. Under this guidance, CPT may be authorized only when the practical training is a required component of the academic program and necessary for the student to complete the degree. To qualify as a required component, the practical training must be required for all students enrolled in the same curriculum and, as such, elective courses are likely not permitted because participation is optional. The Broadcast Message expressly aligns this updated interpretation of "integral" to the definition of the term in the Merriam-Webster dictionary, which provides that "'integral' means 'essential to completeness' as in, 'an integral part of the curriculum.'"[1]
The Broadcast Messages indicate that CPT noncompliance may lead to potential liability for both the institution and individual DSOs. An institution may be subject to a range of consequences, including sanctions and potential withdrawal of SEVP certification. DSOs may face personal liability, including potential consequences for knowingly inaccurate certifications made under penalty of perjury when signing Form I-20s.
Additional Guidance in the Broadcast Messages
The August 24 Broadcast Message includes additional guidance in its Frequently Asked Questions section related to the interpretation of current regulations. One issue concerns the requirement that CPT be offered by sponsoring employers through "cooperative agreements" with the school, as required in 8 C.F.R. § 214.2(f)(10)(i). The regulation does not define "cooperative agreement," which has been interpreted to require either (i) a signed cooperative agreement or (ii) a letter from an employer.
The Broadcast Message provides in its response to Question # 6 that "[s]chools should only enter into cooperative agreements with legitimate, bona fide employers who are able to provide a quality practical training experience to students." This language has created some uncertainty as to whether a signed agreement is required for all CPT or if an employer letter remains sufficient for these purposes.
The current language of the Student and Exchange Visitor Information System (SEVIS) website and Help Hub[2] indicates that an employer letter is still sufficient for purposes of the regulation. The website specifically provides: "CPT requires a signed cooperative agreement or letter from the employer." Even if an employer letter is sufficient, institutions may want to instead rely on a short-form cooperative agreement. A cooperative agreement is helpful in supporting the administrative record and will provide further clarity as to the employer's responsibilities and the connection between the training and the academic program. Schools should continue to monitor future SEVP communications and guidance for clarification.
Impact on Institutions of Higher Education (IHEs)
As a result of the Broadcast Messages, a number of institutions have reportedly suspended applications for certain CPT, including Course Credit CPT, while others have stated that they are reviewing the recent SEVP guidance and will provide updated information regarding any impact on their CPT approval process. The Broadcast Messages appear primarily focused on the standards and processes governing future CPT approvals, but it is unclear as to whether currently approved CPT will be impacted.
The many questions from the higher education sector signal the significant impact that the revised guidance is likely to have on future CPT offerings. Some IHEs and associations may consider legal challenges to this latest guidance.
In the meantime, IHEs should consider the following immediate measures:
- Convene Stakeholder Response Team: IHEs should convene a group of school officials, international student services personnel, DSOs, and other pertinent individuals to evaluate the immediate effect of the Broadcast Messages. This stakeholder group should identify pending CPT requests, upcoming employment start dates, and academic programs that rely on Course Credit CPT or other practical training arrangements. As a number of IHEs have recently started their academic terms, IHEs should consider whether interim review procedures, additional documentation requirements, or temporary delays in certain CPT approvals are appropriate while the IHE evaluates its policies. Institutions should also consider targeted communications regarding any changes to CPT review timelines or procedures.
- Schoolwide Review of CPT: Conduct a comprehensive review of the School's CPT to identify: (i) CPT that is a required component of an established academic curriculum; and (ii) CPT authorized solely for course credit. The School should create an accurate inventory of all currently authorized CPT approvals.
- Support DSOs and Review: DSOs are likely already overwhelmed in dealing with several other changes to CPT and related programs. Since the Broadcast Messages warn against personal liability for DSOs, IHEs should provide DSOs with clear written procedures and access to appropriate institutional support. Institutions should establish an escalation process for complex CPT requests and ensure that DSO determinations, supporting documentation, and SEVIS reporting are subject to appropriate review.
- Restructure CPT Offerings: Institutions should review and, as applicable, restructure CPT-related courses and program requirements to ensure that practical training is an integral and required component of the established curriculum for all students in the applicable program. If the practical training is optional or is not required for completion of the relevant curriculum, it should likely not be offered through CPT.
- Strengthen Documentation Practices: Institutions should strengthen their documentation practices to demonstrate that each proposed placement satisfies applicable CPT requirements. The record should clearly identify the student's academic program, thoroughly describe the proposed training and its learning objectives, and explain the relationship between the placement and the established curriculum. Additionally, the record should include supporting materials such as the offer letter from the employer, the cooperative agreement, course materials, and any eligibility determination. As stated above, this recommendation may include an increased reliance on cooperative agreements. Such agreements should be reviewed to make sure that they properly satisfy all CPT requirements.
- Experiential Learning Requirement: Schools may consider viable workarounds, such as including an experiential learning requirement for all academic programs – and, therefore, for all students. The presence of such a requirement may support the argument that CPT is integral to an academic program, as it is part of the experiential-learning requirement. This requirement alone does not establish CPT eligibility; however, it may support CPT eligibility where the practical training is itself an integral aspect of the curriculum.
Steptoe will continue to monitor developments related to this matter, including further SEVP guidance. Our attorneys are available to assist IHEs in assessing the effect of the Broadcast Messages on existing CPT policies and pending requests and in developing tailored response plans that address curriculum and documentation practices, institutional communications, and related legal, governance, operational, and reputational considerations.
[1] See Integral, Merriam-Webster.com Dictionary, https://www.merriam-webster.com/dictionary/integral (last visited Mar. 27, 2026).
[2] Updated on August 24, 2026.
