Day 1 CPT

Day 1 CPT refers to Curricular Practical Training (CPT) that allows international students to begin working or interning from the first day of their program. Before diving into the specifics of Day 1 CPT, it’s essential to understand the nature of CPT itself.

Difference Between OPT and CPT

The United States Citizenship and Immigration Services (USCIS) offers two types of work authorizations for international students: CPT (Curricular Practical Training) and OPT (Optional Practical Training). Both OPT and CPT require that the work be directly related to the student’s major field of study.

Many students may be more familiar with OPT. Most students use OPT to work in the U.S. for one year or up to three years (for STEM graduates) after graduation. Although OPT can also be used before graduation, any days used before graduation will be deducted from the total OPT duration. To qualify for OPT, a student must have completed at least one full academic year of full-time study in the U.S. and must obtain USCIS approval. Additionally, there is only one OPT allowed per degree level, meaning that if you have used OPT after completing a master’s degree, you will not be eligible for a new OPT unless you pursue a higher degree, such as a Ph.D.

CPT, on the other hand, offers more flexibility compared to OPT. While CPT is limited to use during the course of study, there are no restrictions on its duration or the number of times it can be used. Even if you are pursuing a second master’s degree, you can still use CPT during your studies. More importantly, the issuance of CPT is determined by the Designated School Official (DSO) at the school, without the need for USCIS approval.

Typically, schools require students to complete one academic year before applying for CPT. However, some schools that emphasize practical work experience allow students to start internships from the first day of their program, enabling them to use CPT from day one. These institutions are known as "Day 1 CPT universities."

	OPT	Day 1 CPT
Usage Time	Before or after graduation	Before graduation
Duration	1 year or 3 years (STEM)	From the first day until graduation Master's programs: 2-3 years Doctoral programs: 4-6 years
Authorization	USCIS	School DSO
Employer Requirement	No	Yes
Frequency	Once per degree level	Unlimited
Note	Pre-graduation usage deducts corresponding days from total OPT	If you work full-time using CPT for 12 months, you will be ineligible for OPT after graduation

How Day 1 CPT Works

So, how does Day 1 CPT enable someone to legally work in the U.S.?

As mentioned earlier, CPT is a work authorization issued by USCIS for international students. To use CPT, a student must first hold F-1 student status. To utilize Day 1 CPT, a student must apply to a "Day 1 CPT university." Once accepted and enrolled, they can legally remain in the U.S. as an F-1 student.

Traditional universities usually offer only two entry points each year, in the spring and fall. In contrast, Day 1 CPT universities often have 4-6 entry points per year, making them particularly suitable for those whose OPT has expired or whose H-1B visa application was denied.

After maintaining their legal status, the next step is to secure a job. With a job offer in hand, the student can apply to their Day 1 CPT university for CPT authorization. Once approved by the DSO, the CPT work authorization is added to the student’s I-20 form. Based on the CPT start and end dates listed on the new I-20, the student can legally work full-time, part-time, or intern.

In summary, Day 1 CPT works by allowing students to legally remain in the U.S. with F-1 student status while working legally through CPT.

Day 1 CPT Schools

West Coast

• Westcliff University
• CIAM
• Sofia University
• Humphreys University

East Coast

• Monroe College
• Saint Peter's University
• McDaniel College
• New England College
• National Louis University

Midwest & South

• Tennessee Wesleyan University
• Ottawa University
• Dallas Baptist University
• Trine University

 

Day 1 CPT is an ideal option for several groups of international students and professionals facing various challenges related to maintaining their legal status in the U.S. while continuing their education or work. Below are the primary groups for whom Day 1 CPT is particularly suitable. Day 1 CPT provides a versatile solution for maintaining legal status and pursuing career goals, making it a valuable option for those in complex or transitional situations.

Hybrid Learning Model

"Day 1 CPT schools" typically use a hybrid learning model. This means that students can attend online classes via Zoom during weekday evenings or weekends, or watch recorded lectures at their convenience. However, students are also required to attend regular on-site classes.

Due to the restrictions of the F-1 visa, international students are limited to taking only 3 of their minimum required 6 credits per semester through online courses. As a result, most CPT programs require students to attend on-site classes at least once per month or once per semester, with these sessions usually scheduled on weekends.

U.S. immigration regulations explicitly state that international students on F-1 visas cannot be enrolled in programs that are 100% online while residing in the U.S. In fact, if a program allowed 100% remote learning, there would be no legitimate reason for international students to remain in the U.S. This is why it is crucial for students to adhere strictly to the on-site class requirements. Failing to attend these sessions would be a direct violation of immigration rules, potentially leading to a loss of legal status.

Weekly Study Commitment

Each semester, students must enroll in at least 6 credits of coursework (typically two courses) and a 0.5-1 credit CPT elective course (some schools integrate the CPT requirement directly into the program curriculum, eliminating the need for a separate CPT course). Based on our research, students taking 6 credits per semester for a CPT program typically need to dedicate around 4-6 hours per week to fulfill course requirements, including reading and completing assignments.

Program Duration

For CPT master's programs, most students complete the program within 1.5 to 2 years, although some programs may require up to 3 years of study. For some students, a longer program duration can be beneficial, as it allows them more opportunities to apply for the H-1B lottery while enrolled in Day 1 CPT. An additional year in the program means an extra chance to secure an H-1B visa.

Some students choose to take more credits each semester to graduate early, potentially earning their master's degree within one year. However, this approach can result in significant academic pressure, making it difficult to balance work and study, so it requires careful consideration. Additionally, not all programs allow for an accelerated timeline, so thorough research is necessary when selecting a school.

Students are encouraged to use course and professor evaluation systems to help choose the right courses and avoid potential pitfalls.

Risk of Status Change

While Day 1 CPT typically does not affect the approval of an H-1B visa, students working through Day 1 CPT might face a Request for Evidence (RFE) from USCIS after being selected for H-1B. The USCIS may ask for additional documentation to prove that the student maintained their legal F-1 student status.

For example, if a student completes a STEM master’s program and uses up their 3 years of OPT, and then enrolls in another master’s program, USCIS may issue an RFE after the student is selected for H-1B to confirm that the student attended on-site classes during the second master’s program and did not participate in a 100% online program.

Since President Biden took office, the number of RFEs related to Day 1 CPT has generally decreased, especially for students who choose established, well-accredited, and regionally recognized schools (and who select appropriate programs). Even if an RFE is issued due to CPT, students should not panic—consult an immigration lawyer promptly to discuss response strategies. Many attorneys are experienced in handling H-1B applications involving CPT-related RFEs. They can assist students in explaining the intent and legitimacy of CPT, covering the reasons for applying, the application process, and the specific usage of CPT. Additionally, they can provide evidence of coursework, research projects, and continued academic participation to support the legality of full-time CPT during the student’s enrollment.

Besides legal support, another critical factor in successfully responding to an RFE is the support provided by the Day 1 CPT school. Established Day 1 CPT schools often prepare a comprehensive "RFE support package" to help students demonstrate that they were maintaining a full course of study and that CPT was not misused.

A typical "support package" includes the following materials:

• RFE Support Letter: An official letter from the school (a core support document) explaining that the student’s CPT work was a program requirement and not a misuse of CPT.
• Attendance Report: Records of class attendance.
• CPT Corporate Agreement: A copy of the CPT agreement.
• Enrollment Verification: Proof of enrollment.
• Official Transcript: The student’s official academic transcript.
• Academic Record: A detailed record of the student’s academic performance.
• Tuition Record: Documentation of tuition payments.

Typically, as long as these materials are included in the RFE response, USCIS will accept them. In some cases, however, USCIS may approve the H-1B petition but deny the change of status application, requiring the student to leave the U.S. and re-enter on an H-1B visa (consular processing).

It’s important to note that students who pursue a master’s program after completing a bachelor’s degree or a doctoral program after a master’s degree generally do not face RFEs related to Day 1 CPT.

F-1 Visa Renewal Risk

Although Day 1 CPT programs are designed within the framework of U.S. immigration law and are legal and compliant, long-term work through Day 1 CPT can raise concerns during F-1 visa renewal. Visa officers might question whether the applicant’s primary intent is to complete their studies or to secure or maintain employment. In such cases, it’s generally advisable to wait until you’ve secured an H-1B before traveling abroad. If your F-1 visa expires and you need to renew it while abroad, consult with your school advisor or an immigration lawyer in advance to prepare the necessary documents and understand how to respond to potential questions from immigration officers.

Three Major Pitfalls of Day 1 CPT

While there are potential risks with Day 1 CPT, students can minimize these risks by adhering to USCIS and school CPT regulations. Most of the risks associated with Day 1 CPT stem from misuse of CPT and violations of related regulations.

Here are three common pitfalls of Day 1 CPT. Avoiding these pitfalls can help you use CPT legally and responsibly.

Pitfall 1: Attending Unaccredited Schools

The first rule in choosing a Day 1 CPT school is to ensure it has proper accreditation. Avoid schools that lack accreditation or have had their accreditation revoked, usually due to poor course management, inaccurate attendance records, or involvement in visa fraud. Schools to avoid include:

• Silicon Valley University
• International American University
• International Technological University
• ACISI-affiliated schools (e.g., UoNA, Stratford University, American University of Fairfax)

Another category of schools to avoid is those set up by USCIS as "sting operations" to catch students who violate visa regulations by offering programs with no coursework or attendance requirements. Students caught in these operations face deportation and may be permanently barred from re-entering the U.S. Examples of such sting operations include:

• University of Farmington
• University of Northern New Jersey

Pitfall 2: Failing to Meet Course and Attendance Requirements

As a Day 1 CPT student, you are still an F-1 student, meaning that even if you have a full-time job, you must dedicate time to your coursework. To renew your CPT, you must maintain a GPA of 3.0 or higher. Failure to attend classes or submit assignments can result not only in losing your CPT but also in losing your F-1 status, forcing you to leave the U.S.

Attending on-site classes is especially crucial for CPT students. Because on-site attendance is directly tied to USCIS regulations, many schools explicitly state that students who do not meet on-site requirements will be expelled. Schools that relax these requirements risk losing their accreditation, as seen with several universities. Therefore, Day 1 CPT schools enforce strict on-site attendance policies.

Pitfall 3: Not Following School CPT Policies

Another major pitfall of Day 1 CPT is working without proper CPT authorization. Students must follow their school’s policies and renew their CPT each semester or academic year. Working without applying for or renewing CPT constitutes unauthorized employment, which can lead to serious consequences, including the loss of legal status.

Applying to a Day 1 CPT school is quite straightforward. Just follow the seven-step application process outlined below:

After obtaining Day 1 CPT, students can continue working and studying in the U.S. Day 1 CPT does not require you to be tied to a specific employer, offering much more flexibility than the H-1B visa when it comes to changing employers. During job interviews, you can emphasize the flexibility and legality of Day 1 CPT to potential employers.

OPT (Optional Practical Training)

If your Day 1 CPT degree is at a higher level than your previous degree and is in a STEM field, you may be eligible for an additional 3 years of OPT. However, if you have already worked full-time using CPT for a year (with "full-time" defined as more than 20 hours per week), you will lose your eligibility for OPT. One strategy is to work full-time under CPT for 11 months, then switch to part-time to preserve your OPT eligibility.

H-1B Visa

If you were previously unsuccessful in obtaining an H-1B visa, you can continue entering the lottery while on Day 1 CPT. A two-year master's program provides you with two chances to enter the H-1B lottery, and a longer doctoral program offers even more opportunities. If you win the H-1B lottery and your application is approved, you can switch from F-1 to H-1B status.

If you already had an H-1B visa but lost your job and enrolled in a CPT program, you can switch back to H-1B once you secure new employment, without needing to re-enter the lottery.

Green Card

U.S. immigration law does not specify that a particular visa is required to apply for a green card, so F-1 students can apply as well. If, during your Day 1 CPT period, your employer or partner sponsors your green card application, you can secure permanent residency, allowing you to stay in the U.S. indefinitely without worrying about visa status.