Faculty Guide to Immigration Issues for International Students

This guide provides general information for Mason faculty working with international students, specifically those in F-1 (student) and J-1 (exchange visitor/student category) status.  However, this information should not be used in place of specific guidance for situations affecting individual international students.  Faculty members are invited to contact staff in the Office of International Programs and Services (OIPS) for assistance.  You can reach our receptionist at 703.993.2970 or our Executive Director at 703.993.2949.

Demographics

To Whom Does the Term “International Student” Refer?

In the context of the University’s official demographics, “international student” means any enrolled student who is not a US citizen and not a Lawful Permanent Resident (“green card” holder). Compiled by Institutional Research and Reporting (IRR), these demographics include Mason students within the US as well as those abroad (studying at Mason Korea or living abroad and taking online courses). They include undocumented students, sometimes referred to as “DACA” or “dreamers.” IRR demographics reference enrolled students only, so those international students whose legal status is sponsored by Mason while they undertake post-graduation training employment are not included.

IRR data can be found here:

https://irr2.gmu.edu

How Many International Students Attend Mason?

The Office of International Programs and Services produces an annual report detailing enrollment of non-immigrant students, those international students who are studying in temporary status and those engaged in post-graduation training employment—Optional Practical Training (OPT) and Academic Training. Because enrollment demographics change daily, the report is based on a snapshot—data from the fall census taken in mid-October. You can find it here:

https://oips.gmu.edu/oips-data-report/

Note: This online information for Mason faculty advising international students is under construction.  Please consult with OIPS for questions or to offer suggestions for additions or improvements. E-mail the Interim Executive Director at clehnert@gmu.edu and please watch for further updates.

Visas & Legal Status

What, Exactly, is a Visa?

The word “visa” is used frequently and often vaguely, to refer to individuals, documents, categories of students, and many other things. But “visa” has a specific meaning. As used in this document, a visa refers to a US entry visa which, when stamped in a passport, allows the bearer to request entry into the US. The visa is typically requested and issued in the student’s country of origin, although in some cases it may be issued in a third country. The expiration date, which is stamped or printed on the visa itself, is the last date on which the visa can be used to request entry. A visa may also have a limit on the number of times it can be used; for example, a “single entry” visa may be used only once. Visas are always issued outside the US at consular posts abroad, with the exception of those for diplomats, which may be issued within the US by the Department of State.

The US Department of State, which controls all US visa issuance processes, determines the length of visa validity, usually based on reciprocity with the student’s home country. Some students may receive a visa valid for only three months; this means they have to enter the US within the visa’s validity period, and then they may remain to study and complete a degree program. However, if they exit the US after the visa expires, they need to apply for a new visa to re-enter. Other students receive visas valid for the expected length of their degree programs—three, four, five years. These students may travel and re-enter for as long as they remain students and their visas remain valid. A visa is used for entry to the US only. Its validity does not relate to the length of time the student is authorized to remain here.

Visas and Legal Status

  • Most international students attend Mason in F-1 status.
  • F-1 is the student classification for US entry visas. Dependents (spouse and dependent children) enter in F-2 status.
  • Each F-1 student receives an I-20 form which states the student’s degree level, major field of study and expected completion date. The I-20 must be up-to-date at all times. If a student changes major or degree level, or needs additional time to complete the program, he or she must request an updated I-20 from OIPS.
  • The University is required to enter data on every student into the national SEVIS database—Student and Exchange Visitor Information System. These data include all information on the I-20 form as well as the student’s contact information (US residence address and telephone number). Students are required to report changes in address within ten days of moving.
  • Students must keep their passports valid at all times. For nationals of most countries, passports must be valid for six months into the future. Exceptions can be found on the website of the US Customs and Border Protection (cbp.gov).
  • Fewer than 10% of Mason’s international students are in J-1 (exchange visitor/student category). These individuals hold a DS-2019, similar to an I-20; their data is also entered into the SEVIS database, and they must keep their DS-2019 forms up-to-date at all times.
  • Some individuals on other visas enroll at Mason “incident to status”—meaning that being a student is not their primary reason for entering the US, but they are permitted to study in addition to their main non-immigrant purpose. Most of these individuals are the spouses or dependent children of individuals authorized to work full-time.

Note: This online information for Mason faculty advising international students is under construction.  Please consult with OIPS for questions or to offer suggestions for additions or improvements. E-mail the Interim Executive Director at clehnert@gmu.edu and please watch for further updates.

Legal Status in the US

Maintaining F-1 Status

The responsibility to maintain F-1 status in the United States rests with the student. Information on how to do so is provided online and in multiple orientation and informational venues. Status violations can have negative consequences, some of them dire. Advise students to meet with an international advisor in OIPS to clarify anything related to their legal status in the US.

To remain in F-1 status, a student must:

  • Attend the school listed on his or her I-20 form;
  • Formally report to the SEVIS coordinator in OIPS so that he can be registered in the SEVIS database;
  • Maintain a valid passport (typically six months into the future);
  • Enroll for a full course of study every fall and spring semester (see below for details), and not enroll for more online credits than permitted—usually one online course per semester;
  • Make normal progress toward her educational objective;
  • Ensure that his/her I-20 form is accurate by promptly notifying OIPS of any change in major or expected date of completion;
  • Ensure that her/his residential address is always correct, and updated in Patriotweb within ten days of any change, so that it can be uploaded to the SEVIS database;
  • Request a program extension from OIPS if he/she will not complete his program by the expected completion date listed on the I-20 form;
  • Follow regulations governing F-1 employment, never working on-campus in excess of permitted hours, and never working off-campus without the appropriate authorization in writing;
  • Follow appropriate procedures for school transfer, and depart the US as required within the governing grace period.

The Full-Time Study Requirement for F-1 Students

  • F-1 students must take a “full course of study” during fall and spring semesters. Summer study is optional.
  • “Full-course of study” aligns with the University Registrar’s definition of full-time status.
  • Only one fully online course can be counted toward the credits required to be full-time. A student in his or her final semester who has only one course remaining may not take that course in a fully online format.
  • Exceptions are rare. Those permitted in the regulations are:
    • Physical or psychological illness that prevents a student from maintaining a full course of study. Students in this situation must visit the Office of Disability Services and seek certification of temporary disability. If the Director of Disability Services recommends a reduction in course load, the Executive Director of OIPS will approve the request and issue a new I-20 with the authorization in writing.
    • Academic difficulties, which are limited to the following:
      • Initial difficulties with the English language (first two semesters of study in the US);
      • Unfamiliarity with American teaching methods or reading requirements (first two semesters of study in the US);
      • Improper course level placement (student enrolls in a level of a course for which he or she is under-prepared or over-prepared and is unable to make an adjustment because the first graded assignment is returned after the last day to add).
    • To complete the course of study in the current term. Students who are in their final semester of a degree program and need fewer than a full-time course load to meet degree requirements may carry only those credits needed to finish their program.
  • A student may request an exception to the full course of study requirement by asking for an “RCL,” a Reduction in Course Load. For the medical/psychological RCL, the student should contact the Office of Disability Services. For any other RCL, the student should download the Reduced Course Load Form from the OIPS website and submit the form with the required signatures and/or attachments.
  • Medical RCL authorization is limited to an aggregate of 12 months at each degree level. Academic RCL authorization is limited to one at each degree level. The final semester of study RCL is typically authorized once, but if a student fails to graduate one additional final semester RCL may be authorized.
  • Similar federal requirements apply to J-1 students. Faculty or students should consult with a J-1 advisor in OIPS for details.

Making Normal Progress Toward the Educational Objective

The rate at which students progress toward their educational objectives varies widely. Graduation in four years, considered normative in the past, is achieved by fewer than 50% of undergraduates. A student can complete an undergraduate degree in eight semesters by taking 15 credits in every semester and planning carefully to meet all core and degree requirements.

International students are required to enroll full-time every fall and spring semester, but many enroll for only 12 credits, especially when they first arrive in the US. While it is not uncommon for an F-1 student to complete an undergraduate degree in eight semesters, a student who enrolls for 12 credits will require at least ten semesters. A student in such a situation must, in requesting a program extension (a new “expected completion date” on the I-20 form), document “compelling academic or medical reasons” to justify the need for the extension. In every case, the advisor must make a recommendation on the standard program extension form; if the justification is academic rather than medical, the advisor will also be requested to provide information to support the extension request.

Federal regulations require the University to ensure that each F-1 student has the financial means to complete his or her academic program. Therefore, when requesting a program extension, a student must submit updated financial documents with the extension form.

A student whose I-20 has already expired is not eligible to request a program extension. Students must attend to the date of expiration and seek a program extension at least four weeks in advance to make certain that they meet the deadline.

Note: This online information for Mason faculty advising international students is under construction.  Please consult with OIPS for questions or to offer suggestions for additions or improvements. E-mail the Interim Executive Director at clehnert@gmu.edu and please watch for further updates.

Employment

On-Campus Employment for F-1 Students

  • F-1 students may accept employment on-campus incident to status, meaning that no specific authorization is required. The student may be employed by George Mason University or by contractors that provide direct services to students (such as food services, parking services, the bookstore, etc.)
  • The student must follow the usual requirements for employment on campus, such as completing a form I-9 in a timely manner and visiting the international tax office in Fiscal Services.
  • Employment is limited to 20 hours per week while school is in session. Full-time employment is permitted during winter and spring breaks, and during the summer.
  • A student who violates any condition of his or her F-1 legal status is no longer eligible for employment.

Off-Campus Employment for F-1 Students

  • Written authorization is always required for off-campus employment, irrespective of the type.
  • Practical Training is employment that is related to the student’s major field of study and commensurate with the level of study.
    • Curricular Practical Training (CPT) is a part of the student’s curriculum.
    • Optional Practical Training (OPT) is related to the student’s major field of study and commensurate with the level of study but is not a part of the curriculum itself.

Note: This online information for Mason faculty advising international students is under construction.  Please consult with OIPS for questions or to offer suggestions for additions or improvements. E-mail the Executive Director at clehnert@gmu.edu and please watch for further updates.

CPT Fact Sheet

What is CPT  

CPT is one type of pre-degree-completion practical training that is available to F1 students. It is most commonly used for off-campus internships or research. The experience must be related to the student’s degree, and also either 

  • required or 
  • integral to an established curriculum as described in the catalog. 

If it is not a degree-required internship, the academic department must determine whether the experience is integral to the established curriculum. The US Code of Federal Regulations defines CPT as “alternate work/study, internship, cooperative education or any other type of required internship or practicum which is offered by sponsoring employers through cooperative agreements with the school” [8CFR 214.2(f)(10)(i)]. 

Important Notes for Advisors: 

  • Failure to fully ascertain the integral nature of the experience to the degree curriculum may impact the student’s future applications for immigration benefits. 
  • Students who begin working without proper authorization may jeopardize their immigration status or future applications for immigration benefits. 

Eligibility 

To be eligible for CPT, students must: 

  • Complete two full-time semesters in the US (excluding summer) in degree status, including at least 1 semester in F-1 status in their chosen degree program 
  • Be in good academic standing and be making good progress towards earning their degree.   

OIPS relies on academic departments to confirm good academic standing and progress during the CPT application process, including confirming that the student will be eligible to graduate or enroll in the next semester and that pursuing this off-campus experience will not delay degree completion. 

Employment must be directly related to a student’s declared degree.  Students may not participate in CPT that is only related to minors or concentrations. 

Course Enrollment Requirements: 

Students must enroll in an approved internship or practicum course (1+ credit) in the semester they want to be authorized.  This course must be within the student’s degree program, or from a related degree program and approved by the student’s academic advisor.  Independent Study and Research credits do not qualify for CPT. 

Ph.D. and master’s students completing their thesis /dissertation can use their enrollment in 799/999 for CPT. These students must provide a letter from their thesis or dissertation advisor detailing how the internship contributes to thesis/dissertation research (see Required Documents section below). 

CPT is given on a semester basis (Spring CPT, Summer CPT, Fall CPT).  If an internship opportunity spans two semesters, the student must apply for CPT two times, once for each semester. 

Limitations to CPT:  

  • A student cannot be authorized for CPT with the same employer more than three times. 
  • During academic terms (Fall, Spring), CPT is limited to 20hrs/week.  During summer, students can work more than 20hrs/week on CPT. 

On-Campus Employment and CPT: 

  • Students are allowed to pursue CPT and on-campus employment, including Graduate Assistantships (GA), at the same time.  An additional letter of support will be required from the GA advisor during CPT application process (see Required Documents section below). 
  • During academic terms (Fall, Spring), both CPT and on-campus employment are limited to 20hrs/week each (40hrs/total).  During summer, students can work full-time on CPT and on campus. 
  • No authorization is required for on-campus employment. 

Application process

Please allow up to 6 weeks for the CPT application process to be completed and for the student to receive their required authorization document (CPT I-20). 

Step 1: Pre-approval from OIPS 

Students must seek pre-approval from an OIPS advisor before beginning the online CPT application.  When pre-approved, students will receive a pre-approval email that confirms OIPS approval to proceed with CPT application process. 

*Students must be registered for an appropriate course before proceeding to Step 2.  Reminder that only Internship/Practicum or Thesis/Dissertation credits qualify for CPT. Research and Independent Study credits are not allowed. 

**OIPS can authorize a student for CPT as long as course enrollment in the appropriate term can be secured and the minimum number of hours required by the course can be met within the authorization period. 

Step 2: Online Application 

Student provides internship details including course enrollment information, company and supervisor information, learning goals, and required documents. 

Required Documents: 1) Offer letter; 2) Proof of course enrollment 

Students who have CPT and GA positions in the same semester must provide a letter of support from the GA advisor confirming that GA contract does not limit or prohibit additional employment.  This letter should be on department letterhead, signed, and should include confirmation that the GA contract does not restrict additional employment and that the GA advisor supports the student’s pursuit of CPT. 

Ph.D. and master’s students completing Thesis/Dissertation CPT must provide a letter of support from their thesis or dissertation advisor detailing how the internship/off-campus experience contributes to the completion of their required research.   This letter should be on department letterhead, signed, and should include information about current research, remaining work before the defense, and how the experience will contribute to research or defense preparation. 

The online application is electronically signed by the student’s academic department and employer. 

With their electronic signature, the academic department must confirm 1) previously completed coursework that is relevant to the internship, 2) that the student is making good progress toward their degree and will be eligible to graduate or enroll next semester, and 3) that completing the internship will not delay the student's expected date of degree completion. 

With their electronic signature, the employer must confirm that the employment opportunity is a temporary training opportunity for curricular purposes. 

Once all 3 sections of the online application are submitted (student, academic department, employer), OIPS will generate the CPT I-20 and send it to the student via email.  Students cannot begin working for off-campus employers until CPT I-20 has been received.
 

 Published Resources and Government Links 

US Government Code of Federal Regulations (CFR): 8 CFR 214.2 (f)(9)(ii)(A) and 8 CFR 214.2(f)(10)  

https://www.ice.gov/sevis/practical-training
…If you are an F student, you have the option of training in the United States by engaging in practical training during your program or after it ends. Practical training can provide valuable work experience by sharpening and adding to the skills you are learning in school. There are two types of practical training available for F-1 students: curricular practical training (CPT) and optional practical training (OPT)….
 

Curricular Practical Training (ice.gov) 

FAQs and “…CPT and OPT are not interchangeable. CPT accommodates individuals enrolled in a program of study that requires participation in an internship or practicum. It is not a supplemental training 

experience but rather an “integral part of an established curriculum…” 

SEVP reminds US schools that CPT, OPT are not interchangeable | ICE 

“…We know schools are trying to find solutions to recent processing delays in OPT authorization requests, and SEVP has noticed an uptick in schools using CPT as an alternative,” said Rachel Canty, SEVP director. “SEVP cautions schools about this practice since CPT must be an integral part of an existing curriculum and must be implemented in accordance with federal regulations...”

SEVIS HELP HUB F-1 Curricular Practical Training (CPT)
…Complex rules apply to CPT because the training opportunity must comply with both: 

Federal regulations and School policies regarding internships, experiential learning, etc.…