Recently published guidance from the Student and Exchange Visitor Program (SEVP) for F-1 students and Designated School Officials (DSOs) should be viewed as a signal that Immigration and Customs Enforcement (ICE) will more closely monitor compliance with the recommendations.
The policy guidance, titled, “Practical Training: Determining a Direct Relationship Between Employment and a Student’s Major Area of Study,” clarifies the responsibilities for students and DSOs as they document Optional Practical Training (OPT).
Most importantly, the guidance emphasizes two primary responsibilities for F-1 students and DSOs for documenting the direct relationship between OPT and a student’s studies:
- Students must provide a description of how OPT relates to their major area of study
- The DSO must review and maintain the information to maintain SEVP compliance
F-1 students on OPT are responsible for providing documentation for the SEVIS record or their student file. Documentation of the direct relationship should include:
- A student’s job title
- Employer name
- Major area of study
- Whether the position is full-time, or average hours worked per week
- A brief explanation of how the job is directly related to the student’s studies. The explanation should illustration how the student’s degree facilitates and informs, or is furthered by, the job responsibilities.
SEVP allows students to submit the information directly into the SEVIS system using their SEVP Portal – information should be included in the text field titled “Relation to Field of Study: Explain how this job relates to the degree that qualified you for this OPT.” Alternately, information can be submitted to the DSO, who can add it to the SEVIS record or the student’s file.
The policy guidance reiterates the responsibilities of the DSO to assess the relationship between the job and the student’s primary area of study –
When a DSO recommends a student for OPT or STEM OPT, the school assumes additional responsibilities to monitor and update the student’s SEVIS record. Consistent with those responsibilities, a DSO must make determination of whether there is a direct relationship between the job and the major area of study.
DSOs should review OPT documentation on a case by case basis. In some cases, a position in the student’s field might not directly apply to their field of study, in others, the direct relationship might not be immediately clear.
While the policy guidance is not a shift from current policy, the increased emphasis on the roles and responsibilities of students and DSOs in the documentation and assessment of OPT jobs is a reminder to foreign student offices that SEVP compliance necessitates thorough record keeping and attention to detail. If you have questions about SEVP compliance, download our free SEVP guide or contact us today for a complimentary consultation.