Is "Day 1 CPT" Legal? Understanding USCIS Requirements and Key Considerations for International Students

For international students in the United States, understanding Curricular Practical Training (CPT) is essential—especially when it comes to the often-discussed "Day 1 CPT". The legality of integral CPT, referred to as Day 1 CPT by students, hinges on strict adherence to U.S. Citizenship and Immigration Services (USCIS) regulations, and students must carefully evaluate programs offering this option to ensure compliance. This article explores the USCIS requirements that allow a university Designated School Official (DSO) to authorize CPT during your first semester at the graduate level and additional considerations for students selecting a program with integral CPT.

Understanding Integral CPT and USCIS Regulations

Integral CPT, authorized by a university Designated School Official (DSO) during your first semester (aka from day 1), refers to Curricular Practical Training experiences that are required as part of an academic program. While some question its legality, USCIS regulations do allow for CPT from the beginning of a program, provided that certain conditions are met.

According to 8 CFR 214.2(f)(10)(i), CPT must be:

• An integral part of an established curriculum – The alternative work/study, internship,

  cooperative education, or any other type of required internship or practicum that is

  offered by sponsoring employers through cooperative agreements with the school must

  be directly related to the student’s field of study and required as part of the academic

  program.

• Authorized by the university’s Designated School Official (DSO) – The institution must confirm that the student meets eligibility requirements and provide proper authorization through SEVIS.

• Offered by an accredited institution – The school must be authorized to issue Form I-20 and be compliant with SEVP (Student and Exchange Visitor Program) regulations.

• Tied to a structured academic requirement – This means CPT must be linked to a credit-bearing course or a program requirement, such as an internship, practicum, or cooperative education component.

For graduate programs to legally offer CPT from day 1, they must have integrated practical training experience as an academic requirement. Many MBA, MS, and DBA programs that offer CPT from the first semester do so by integrating practical training into their curriculum through learner-practitioner and experiential learning delivery models, including application- and project-based learning.

Other Considerations When Selecting a Program with Integral CPT

While USCIS permits CPT from the first semester (aka from day 1) under specific conditions, international students must consider several factors before enrolling in such a program:

1. Accreditation and SEVP Approval

   • Verify that the institution is accredited and listed on the SEVP-approved schools list.

   • Programs that are not properly accredited may put your immigration status at risk.

2. Academic Integrity of the Program

   • Ensure that the program offers a rigorous academic curriculum rather than serving primarily as a means to gain work authorization.

   • USCIS has increased scrutiny on programs that appear to exploit CPT regulations rather than provide genuine educational experiences.

3. On-Campus vs. Hybrid Requirements

   • Many CPT programs require hybrid or weekend residencies. Confirm how often you need to attend in-person sessions.

   • Avoid programs that do not require any physical presence, international students are not permitted to enroll in fully online programs.

   
   

Final Thoughts

CPT authorization from the first semester is legal when properly structured within the academic framework of a graduate program, as permitted by USCIS regulations. However, students must carefully vet their programs to ensure compliance, maintain their F-1 status, and avoid unintended immigration consequences. Choosing a reputable, accredited institution with a strong academic foundation is key to maximizing the benefits of CPT while staying within legal boundaries.

Explore SEVP Approved Programs with Integral CPT