Hiring Foreign Students: Federal Compliance Scrutiny Impact on Recruiting

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Updated guidance for Curricular Practical Training is affecting many elective opportunities for international students. Schools and employers must reassess which placements still qualify and plan accordingly.

The Department of Homeland Security (DHS) Student and Exchange Visitor Program (SEVP) in August 2026 issued two messages (Broadcast Messages 2608-01 and 2608-02) directing Designated School Officials (DSOs) to apply heightened scrutiny to Curricular Practical Training (CPT).

CPT is a temporary employment authorization for eligible international students that allows them to work through alternative work/study, internships, cooperative education or other practicums when the work is "integral to an established curriculum."

While the messages do not change the governing CPT regulation, they do articulate a more restrictive interpretation of when practical training is permissible.

A number of schools have responded to the updated guidance by reassessing or pausing elective- and course-credit-based CPT arrangements; some LeadingAge members have reported that staff working under CPT have been impacted.

Under SEVP's guidance, a CPT placement must be directly related to the student's major and required for all students in the established curriculum, regardless of citizenship. A course that an individual student can elect to take in order to support an internship generally will not satisfy that standard. Schools, not employers, make CPT determinations through their DSOs, but employers may experience delayed start dates, narrower candidate pools, and requests for more detailed training documentation for existing program.

Immediate Hiring Implications

Some students and employers may learn that a placement previously expected to qualify no longer meets their institution's CPT criteria, potentially affecting planned start dates or the viability of an internship offer.

Students with already-issued CPT should confirm the validity of their existing authorization-and any request to extend it-with their DSO. In general, SEVP is increasing scrutiny of CPT approvals to ensure compliance with regulatory requirements.

Where CPT Still Works

Programs that require a practicum, clinical placement, internship, or cooperative-education component for every student as a condition of completion are the clearest candidates for CPT authorization under SEVP's stated interpretation. Employers recruiting from these programs should be prepared to provide the documentation relating to the practical training experience that the school requires. Note that an agreement between the school and the employer does not, by itself, make an otherwise elective placement eligible for CPT.

Employers should confirm with institutional contacts which programs have required, integral practical-training components and which CPT pathways have been restricted. It may be helpful to begin eligibility discussions with the student and school well before the intended start date-ideally allowing several weeks of contingency time if the placement requires curricular review.

Documentation and Formalization

SEVP's guidance emphasizes that schools and DSOs must be able to substantiate each CPT authorization. Schools may need to demonstrate that the training is directly related to the student's major, required by the established curriculum, and necessary to complete the program. DSOs are also expected to maintain records supporting the authorization and ensure the student's SEVIS record is properly updated.

Employers should expect some schools to request more detailed information about job duties, supervision, training objectives, duration, and the educational relationship between the placement and the student's program. That documentation can help the school evaluate the CPT request, but it does not replace the requirement that the training be integral to the established curriculum and, under SEVP's stated interpretation, required for all students in that curriculum.

Moving Forward

Members who employ foreign students under CPT should consider auditing the current international-student workforce and documenting CPT authorization end dates; contacting institutional partners to identify programs with a required, integral CPT component; and consulting immigration counsel when recruiting from a new institution.

CPT has not been eliminated. It remains available where the placement satisfies the applicable curricular standard. However, in response to Broadcast Messages 2608-01 and 2608-02, schools may be applying more restrictive eligibility assessments, administrative processes may take longer, and the documentation supporting a placement matters more than before.

This article was prompted by, and drafted with, input from LeadingAge Iowa and members affected by the changes. Contact Associate Director for Immigration Advancement with questions or concerns about how immigration policy affects the workforce, or to report direct impact.