On Wednesday August 12, 2026 BIO received a Guidance Memo from Immigration and Customs Enforcement (ICE) related to the liability of school officials when processing applications for Curricular Practical Training (CPT). The memo outlines stricter criteria for CPT authorization and highlights significant personal legal liability for Designated School Officials (DSOs), as well as potential risks to an institution's SEVP certification for non-compliant approvals. A second Guidance Memo from ICE was sent on Monday, August 24 that confirmed this guidance, with content that was even more restrictive in nature.
Core Shift in CPT Guidance
Federal regulations require CPT to be an "integral part of an established curriculum." Historically, universities have met this requirement via two pathways:
- Degree Requirement CPT: Practical training that is mandatory for all students in a specific degree program in order to graduate.
- Course Credit CPT: Practical training tied to an elective or independent study course that counts toward the degree, but is not an absolute graduation requirement for all students in the major.
The August 12 ICE guidance narrows the interpretation of "integral," specifying that CPT should only be authorized in cases in which the CPT is a requirement of the degree for all students in the degree program, and without which the degree would be unattainable. Under this strict interpretation, optional internships taken for elective course credit would not meet the requirements. In light of these strict standard updates and heightened liability risks, BIO suspended all applications for "Course Credit CPT" effective August 13, 2026, until further notice.
This action was taken to minimize legal risk to BIO advisors, protect the university's institutional SEVP certification, and prevent F-1 international students from unknowingly risking their future immigration status or benefits.
Current CPT Processing
BIO will process CPT applications for the following situations:
- Degree Requirement CPT: BIO continues to process CPT applications for degree programs where an internship or field placement is a documented graduation requirement for all students.
- Master's Thesis/Doctoral Dissertation Requirment CPT: BIO may authorize CPT in specific cases in which practical training/internship required to complete the Master’s thesis/ or Doctoral dissertation, is an integral part of the student’s degree requirements, and is not reasonably replaceable by an alternative method or data collection process. This is only possible for Master’s (Thesis Track) or Doctoral students who have Advanced to Candidacy.
Students whose course credit CPT applications have already been fully processed and who have already received a CPT I-20 from BIO were not affected by this pause and were able to participate in the ongoing or upcoming CPT opportunity specified on their CPT I-20.
Next Steps
University of California leadership, BIO, and campus legal counsel are actively reviewing the federal guidance, analyzing its impact on academic programs, and consulting on potential administrative or curriculum adjustments. BIO will share any updates as they become available.
For more information on the current CPT practices and processes, visit BIO's CPT web page