Adrian Kulesza

Ananya Indwar ’20, an international student from India, moved into her housing for the summer, unpacked and was more than ready to start her internship at an investment firm in New York City last week.

The only problem? U.S. Citizenship and Immigration Services had still not processed her Optional Practical Training employment authorization application that she submitted on March 5.

Indwar is one of many Yale international students who were forced to indefinitely delay their summer internships due to widespread processing delays of OPT applications, which grant temporary summer and post-graduate employment authorization to students on F-1 visas.

But international students previously in employment limbo have reason to be optimistic, following a swift University response to student concerns. Just days after 169 international students signed and delivered a petition urging University President Peter Salovey to help navigate and alleviate the uncertainties they face due to the processing delays, Executive Director of the Office of International Students and Scholars Ann Kuhlman announced on Tuesday that Yale College will offer a new course in the fall that will allow the University itself to approve off-campus employment licenses for international students.

According to Kuhlman, processing times for OPT applications — which have typically ranged from 75 to 80 days in previous years — are stretching beyond 90 days this year, causing some students to miss their scheduled start dates for summer internships. By enrolling in new Yale College course this coming fall called “PRAC 471a: Fieldwork Practicum Analysis,” students can now work at a US company this summer with a Curricular Practical Training employment authorization, rather than an OPT.

It remains unclear how many students delayed or were at risk of delaying their internship start dates due to OPT processing delays. According to Kuhlman, over 500 students on F-1 visas in Yale College and the graduate and professional schools submitted applications for OPT authorization this year.

According to the USCIS website, CPT employment must be required for one’s degree or count for academic credit. Unlike OPT employment, CPT employment must be authorized by the international student office at the applicant’s university, and the USCIS must be notified. OPT employment authorization, on the other hand, is processed by the USCIS itself and is granted for “temporary employment that is directly related to an F-1 student’s major area of study,” per the USCIS website. According to USCIS rules, F-1 students — or those with full-time student visa — may not submit applications for OPT more than 90 days in advance of their projected start dates.

In a Tuesday email to international students, Kuhlman explained that University administrators have been discussing the possibility of providing a fall semester course for a CPT employment authorization for months. By the end of the spring term, the OISS had a CPT proposal for the next academic year, and Yale College Dean Marvin Chun recently approved the plan, Kuhlman said.

Chun explained in an email to the News that discussions about the creation of PRAC 471 began about a year ago, and he had planned to announce the course this fall after receiving approval at the October faculty meeting.

“My plan was to bring this course proposal to the Yale College faculty in the fall, since the faculty’s final meeting for approving courses, in early May, had passed by the time the proposal was complete,” Chun wrote. “But due to the urgency created by unprecedented delays in approving optional practical training, I was able to use the authority entrusted to me every summer by the Yale College faculty to approve courses in its absence.”

Chun added that by the time he received the June 1 petition, he had already approved the course — which was modeled after a practicum offered in the graduate school — “after extensive consultation and review,” and about 40 students had already asked him to institute the course immediately.

According to Kuhlman, students engaging in an internship relevant to their degree and coursework this summer can enroll in Fieldwork Practicum Analysis in the coming fall. The course will be graded on a Pass/Fail basis and will carry a .5 credit that will appear on students’ transcripts, but it will not satisfy any graduation requirements, Kuhlman explained. She added that enrolled students will submit a reflection paper identifying ways in which the experience enhanced their understanding of their academic fields of study.

In the Tuesday announcement, Kuhlman also cautioned students that there may be a “possible immigration drawback” to also seeking a CPT authorization while the government is processing the OPT application. Students who start seeking for a CPT authorization now will likely have both an approved OPT and CPT with similar dates, which the USCIS “has recently been scrutinizing,” Kuhlman explained. She added that having dual work authorizations may create problems when a student is filing immigration applications or petitions in the future and recommended  that students gather enough documentary evidence to defend their authorization requests.

Prior to Kuhlman’s announcement on Tuesday, students penned a letter to Salovey and explained the difficulties they are facing due to OPT processing delays. The letter proposed three potential “short-term options” to help with the problem: Modifying the existing curriculum to allow CPT for undergraduate students, sending an official inquiry to the Department of Homeland Security/USCIS about the current OPT delays and offering financial assistance to students who lose their internships due to the processing delays.

In an email to international students on May 25, OISS advisor Ozan Say recommended students inform their employers about USCIS’s slower OPT processing times this year and said they may have to delay their start dates if their employment is not authorized in time.

“At the moment we have already received [Employment Authorization Document] cards for about 30% of applications that were receipted on February 22nd and about 20% of applications that were receipted on February 25th,” the email stated. “As of Friday (May 24th), we received only one EAD card for an application that was receipted on March 1st. … I hope this gives you an idea about where OPT processing is this year so that you can strategize regarding your prospective employment start dates.”

Ryo Tamaki ’20, who plans to work for an economic consulting firm in New York City this summer, told the News on Sunday that he flew home to Singapore to wait for approval for an internship that was set to start on May 20. After hearing about the widespread delays in OPT processing and having not received his EAD, he requested on May 15 the firm’s alternate start date of June 17.

But Tamaki noted that because the end date for OPT cannot be changed even if processing delays result in a later first day, the total length of his internship would have to be cut short.

“It means that my end date would still be that of the first internship start date, so it’s no longer 10 weeks, but 10 minus the number of weeks elapsed since May 20, which, beyond the forgone learning opportunities and wages, would likely affect the prospect of a return offer,”  Tamaki said.

When he woke up on Wednesday morning in Singapore to the news that Yale had decided to offer a CPT option, Tamaki said it “made [his] year.” He said he plans to apply for CPT this summer, especially given the ability it would give him to extend his end date.

The OPT processing delays come at a time of rising tension in US trade relations and growing scrutiny of immigrants and international scholars. In a University-wide statement last month, Salovey pointed out that increasing strains in US-China relations and “scrutiny of academic exchanges have added to a sense of unease among many international students and scholars” at Yale.

“We pair our unequivocal commitment to careful research stewardship with another: international students and scholars are welcome and respected on our campus,” Salovey said. “I will continue to advocate for government policies that support the ability of international students and scholars to study and work in the United States.”

In a statement to the News on Tuesday, Salovey emphasized that the University “remains committed to protecting  [international students’] welfare and ensuring that they are able to participate fully in university life.”

Serena Cho | serena.cho@yale.edu

Asha Prihar | asha.prihar@yale.edu