CPT Policy Statement - International Office

INTERNATIONAL OFFICE

To ensure that foreign students attending SMU on F-1 student visas maintain their status and operate well within the parameters of the Code of Federal Regulations, the following University policy has been implemented. This action is taken to ensure that foreign students on F-1 visas will not now or in future be subject to Department of Homeland Security immigration penalties.

The CPT Policy

The Code of Federal Regulations states that Curricular Practical Training (CPT) must be an “integral part of an established curriculum” and directly related to the student’s major area of study. The regulations define curricular practical training 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.” [8 C.F.R. 214.2 (f) (10) (i)]

The Designated School Official (DSO) at SMU may grant CPT off-campus work authorization under the following conditions:

A student must have been in continuous F-1 status for at least one academic year.
The work experience is a required part of a degree program for all students. (For example, the SMU School of Engineering Co-op Program qualifies for CPT work authorization). If the work experience is a required part of a degree program for all students, the practical training does not have to be credit-bearing.

If the work experience is part of an elective course (independent study and “special readings” courses do not qualify for CPT work authorization), it must be for credit and count toward degree requirements in the student’s course of study. For doctoral students receiving credit for their dissertation, the work must be required to complete their dissertation. However, doctoral students in the School of Engineering are required to be in the Engineering Co-OP program in order for work authorization to be granted. International students may take only credit-bearing internships.

It is important to remember that CPT work authorization allows students to work off-campus because that work is an integral part of an established curriculum. If a student’s primary purpose is to gain work experience, he or she should apply for Optional Practical Training (OPT) which is available prior to completing a degree program or after completion of a degree program.

CPT work authorization must not serve as a means to delay graduation. Consequently, students who receive CPT work authorization for a credit-bearing course must also be registered for a full course of study. [8 C.F.R. 214.2 (f) (6) (i) (A)-(E)] Undergraduate students must be registered for at least 12 credit hours and graduate students must be registered for at least 9 credit hours. The only exception to this requirement is when a student is in the last semester of a program, and needs only one or two courses to complete degree requirements.

Because CPT work authorization can only be granted for courses that require work experience as an integral part of the course, students registered for such courses must apply for work authorization prior to the end of the University mandated add/drop period.

CPT work authorization will not be granted until an Internship Agreement signed by both the employer and Southern Methodist University is in place. The Internship Agreement is available from the Internship Coordinator at the appropriate school.

Applying for Curricular Practical Training Work Authorization

In accordance with the University Curricular Practical Training Policy (http://www.smu.edu/international/cpt-policy.asp), a number of requirements must be met before the Designated School Officials in the SMU International Center may grant CPT work authorization.

The following steps must be completed prior to submitting documents to the SMU International Center for work authorization:

1) The student will secure a letter from the employer on company letterhead (which provides the information required on the CPT Application Form).

2) The student will complete the student section of the Curricular Practical Training Application Form (available on the International Center web site: www.smu.edu/international/forms.asp). The application form is located under the Work Authorizations section.

3) The student will meet with an academic adviser, the faculty member teaching the course, or the Internship Coordinator and have that individual complete the appropriate section of the CPT Application Form.

4) The student must meet with the Internship Coordinator in the department or school which offers the course or program requiring work experience and submit the offer letter from the employer and the completed CPT Application Form. The Internship Coordinator mails two original Internship Agreements to the employer requesting that the employer sign each agreement and return the signed documents to the Internship Coordinator. The Internship Coordinator makes two copies of the signed Internship Agreement (one for the student’s file and one for the student to submit to the International Center). The Internship Coordinator forwards the signed originals to the SMU Office of Legal Affairs for the University officer’s signature. A final copy that is signed by both parties should be sent by the Internship Coordinator to the International Office to be placed in the student's file. For a list of department Internship Coordinators, please click here.

5) The student must be registered for the internship course (if applicable) before seeking CPT approval.

6) The student will bring the copy of the signed Internship Agreement, the letter from the employer, and the completed CPT Application Form to the International Center and request CPT work authorization.

Designated School Officials will not grant work authorization until all the documents mentioned above have been submitted. Students may not begin work prior to work authorization being granted by the International Center. Working prior to authorization will automatically result in the student being out of status. SMU is required to report all out of status students to the federal government.