Pre-Completion Optional Practical Training (OPT)

In order to be eligible to apply for pre-completion OPT, you must:   

• Currently be in the U.S. in valid F-1 status;  
• Have a valid passport and I-94 record indicating F-1 and D/S (duration of status);  
• Have been continuously enrolled full-time for at least one full academic year (fall and spring semester) in active nonimmigrant status OR will be completing one academic year within 90 days of applying for pre-completion OPT;
• Be enrolled full-time at CU Boulder (or an authorized equivalent) with an on-campus presence in the semester in which you apply for pre-completion OPT;  
• Have not completed more than 365 days of full-time CPT at the current degree level  
• Have not previously completed a higher degree level in the U.S.;   Have not previously been approved for 12 months of OPT at the current degree level or a higher degree level; AND   Only pursue employment directly related to your major field of study.       

Please note: You must be registered for credits that require on-campus presence in your final semester.

You are eligible to apply for pre-completion OPT up to 90 days before you will have completed one academic year (fall and spring semester) in active nonimmigrant status. USCIS has a processing time for OPT of 2-5 months. ISSS recommends choosing a start date at least 2 months in the future to account for USCIS processing times.  

• For students who started their F-1 SEVIS program in the Spring 2022 semester, the first day you can apply for pre-completion OPT is September 15, 2022 – 90 days before completing an academic year in F-1 status. Your requested start date must be after December 14, 2022.
• For students who started their F-1 SEVIS program in the Fall 2022 semester, the first day you can apply for pre-completion OPT is February 9, 2023 – 90 days before completing an academic year in F-1 status. Your requested start date must be after May 10, 2023.
• For students who started their F-1 SEVIS program in the Spring 2023 semester, the first date you can apply for pre-completion OPT is September 21, 2023 – 90 days before completing an academic year in F-1 status. Your requested start date must be after December 20, 2023.

No. When you apply for pre-completion OPT, you are requesting authorization to work in a job directly related to your major field of study during your authorized period of pre-completion OPT. You will choose your requested start and end dates when you apply for pre-completion OPT. You are not required to have a job offer before applying for pre-completion OPT. If USCIS approves your request for pre-completion OPT authorization, they will provide you with your authorized pre-completion OPT start and end date.

On pre-completion OPT you can have a job, internship or volunteer work that directly relates to your major field of study. The hours you can work per-week will depend if you are approved for part-time (20 hours or less) or full-time (more than 20 hours) pre-completion OPT. You may change employers on OPT and can have multiple jobs, internships or volunteer work as long as you do not exceed your allotted work hours per week, each position directly relates to your major field of study, and you submit the required pre-completion OPT relevance statement to ISSS for each training opportunity you undertake. 

Yes, use of any practical training (both pre- and post-completion OPT) is counted cumulatively with only a total of 12 months allowed for practical training (not including the STEM OPT Extension). Pre-completion OPT will count against that 12-month total and reduce time available for post-completion OPT.

• Part-time pre-completion OPT (20 hours per week or less) is deducted from post-completion OPT at a half-time rate. For example, 3 months of approved part-time pre-completion will deduct 1.5 months from your time of post-completion OPT and you will be eligible for only 10.5 months of post-completion OPT.
• Full-time pre-completion OPT (more than 20 hours per week) is deducted from post-completion OPT at a full-time rate. For example, if you are approved for 3 months of full-time pre-completion OPT 3 months will be deducted from your time of post-completion OPT and you will be eligible for only 9 months of post-completion OPT.

Even if you do not work during some or all of your authorized period of pre-completion OPT, the USCIS authorized time will still be deducted from the time available for post-completion OPT.

No, a USCIS authorized period of pre-completion OPT does not reduce time available for the 24-month STEM Extension. However, you must be in an active period of post-completion OPT to apply for STEM OPT so please plan to ensure you have time remaining to use for post-completion OPT if you will be applying for STEM OPT. ISSS recommends you leave at least 3 months of post-completion OPT available to ensure you have enough time to apply for both post-completion OPT and then the STEM OPT extension.

There is no limit to unemployment days while in your authorized period of pre-completion OPT. However, the time you are authorized for pre-completion OPT will deduct from the 12-month post-completion OPT period upon the pre-completion OPT start date granted by USCIS. You cannot recoup any loss of post-completion OPT time, even if you do not end up working during the pre-completion OPT period for which you have been approved. For example, if you are approved for 3 months of full-time pre-completion OPT you will be eligible for only 9 months of post-completion OPT, even if you do not end up using the pre-completion OPT benefit.   Your authorized period of pre-completion OPT does not impact the 24-month STEM OPT extension, if you are eligible for STEM OPT. 

No, pre-completion does not impact your on-campus employment. Students can work on pre-completion OPT and on-campus; you are still subject to the on-campus work hour restrictions and eligibility requirements.

Yes. It is possible to take advantage of both the pre-completion OPT benefit (authorized by USCIS) and the CPT benefit (authorized by ISSS) and at that the same time. However, on pre-completion you may have multiple training or internships as long as they each relate to your major field of study so it is not necessary to have both if authorized for pre-completion OPT.

Your pre-completion OPT requested start date must be after you have completed one academic year and your pre-completion OPT end date must be before your F-1 program end date or last date of enrollment (whichever is sooner). For the fall and spring semesters, the last day of enrollment is the last date of exams listed on the CU Boulder academic calendar.  You can request a minimum of one day and up to one-year of pre-completion OPT at a time. 

Once you have submitted your pre-completion OPT application to USCIS and it is pending with USCIS, the only way to change your requested pre-completion OPT dates is to withdraw your pre-completion OPT application and submit a new application, including another filing fee. Once your pre-completion OPT is approved you cannot change your pre-completion OPT dates. 

When selecting your dates, you need to take into consideration if you are requesting part-time or full-time pre-completion OPT. Full-time pre-completion OPT is not allowed during the academic year (Fall and Spring terms) unless you have completed all coursework for the degree and are in thesis or dissertation stage.    

No. If the EAD was issued for pre-completion OPT, then the EAD is only valid for OPT prior to a student’s degree completion. The student must stop working on or before their program end date and file a separate application for post-completion OPT in order to be authorized for employment after graduation. 

Only the USCIS authorized pre-completion OPT time that occurs prior to the student’s program end date will be deducted from the allotted post-completion OPT time. A student will not lose any unused pre-completion OPT time if they completed their program prior to the end date on their pre-completion EAD card.  

• For example, if a student applied for part-time pre-completion OPT from January 02, 2022, to January 01, 2023, but finished the course of study on June 1, 2022, the student would still have nine months of OPT available (the six months of part-time pre-completion OPT would deduct 3 months of the total amount available at that education level).

If you are eligible for pre-completion OPT you can request part-time pre-completion OPT (20 hours per week or less) during the academic year. Both part-time and full-time pre-completion OPT (more than 20 hours a week) are allowed during official school breaks (spring break, summer vacation, Thanksgiving break, and winter vacation). Full-time pre-completion OPT is not allowed during the academic year (Fall and Spring terms) unless you have completed all coursework for the degree and are in thesis or dissertation stage. 

If summer is your final semester and you are registered for your final coursework in a summer term, you are still allowed to take advantage of full-time pre-completion OPT in the summer, despite being enrolled.  However, keep in mind that on-campus presence is required in a student’s final term, even if the final term falls over the summer.  Also, your pre-completion OPT end date will be based on your last day of enrollment in the summer term.  

Before electronically filing the Form I-765 with USCIS online, students must first submit the Pre-Completion OPT I-20 Request Form to ISSS and ISSS must make the pre-completion OPT recommendation in SEVIS. This is very important. If a student first submits the USCIS online application and then requests the pre-completion OPT recommendation I-20 from ISSS, the pre-completion OPT application will be denied, as the regulations require the recommendation be entered into SEVIS prior to the pre-completion OPT filing.

 

It is possible to mail your application materials to USCIS instead of filing your application electronically with USCIS. The instructions below are for online filing. If you wish to mail your application materials to USCIS, please reach out to ISSS for instructions.

• USCIS has confirmed that an electronically filed pre-completion OPT application is less likely to be rejected. This is because the USCIS online filing system uses logic that limits the questions you will need to answer based on prior answers, diminishing the opportunity for errors.  
• Once the application is submitted online with final payment, students will immediately receive a receipt number and receipt notice. This means that you will not face a receipt notice delay. A paper copy receipt notice will also be mailed to you.   
• Payment will be made on a secure website using a credit or debit card. This means that you'll be able to confirm receipt of payment at the time of application. Once you submit payment, your whole application will be submitted to USCIS. Please make sure that you are ready to submit your entire pre-completion OPT application (including the required pre-completion OPT recommendation I-20 from ISSS, passport photos, and any other supporting documents) when you get to the payment screen.  
• Additional evidence can be uploaded to the application after submitting. However, ISSS urges students to ensure that they submit a complete application at the time of submission to USCIS.  ISSS wants to reiterate that you must first receive the I-20 recommending pre-completion OPT from ISSS before submitting your complete application to USCIS online.  

The first step in applying for pre-completion OPT is to complete the Pre-Completion OPT I-20 Request Form and upload the required documentation for the request. We will review that documentation below. You will be required to enter your graduate program advisor or academic advisor's name and email address on the DocuSign form. Once you complete your section of the form, it will automatically route to your advisor based on the information you have provided. After your academic advisor completes their section of the form, it will automatically be routed to ISSS for processing. After ISSS receives your request form, please allow 2-5 business days for processing. Once ISSS has reviewed your materials, an I-20 recommending pre-completion OPT will be issued to you. 

You will then need to submit your complete application to USCIS by electronically filing the Form I-765 with USCIS online. Please see further instructions below.

ISSS wants to reiterate that you must first receive the I-20 recommending pre-completion OPT from ISSS before submitting your completed documents to USCIS.  

Remember that you must first receive the I-20 recommending pre-completion OPT from ISSS before submitting your completed documents to USCIS. 

To receive your I-20 recommending pre-completion OPT, please complete the Pre-Completion OPT I-20 Request Form.

You will need to upload the following materials to the USCIS online application system. Documents can be uploaded in the following formats: JPG, JPEG, PDF, TIF, or TIFF. Photos can be uploaded as a JPG, JPEG, or PNG.   

Evidence (as listed in online filing system)	Example	Notes
2x2 photo of you	Passport Photo	See “Photo Requirements” U.S. Department of State photo requirements. DOS also has a photo check tool that you can use to check the photo ahead of time.
Form I-94	Entry I-94, or Change of Status I-797	Download your most recent I-94 here: https://i94.cbp.dhs.gov/
Employment Authorization Document	Valid passport biographical page	If you were not previously issued an EAD, you must upload a copy of a government-issued identity document (such as a passport).
Proof of Enrollment	Transcripts, or enrollment verification letter
Previously authorized CPT or OPT	I-20(s) (for CPT) and/or EAD (for OPT) and/or screenshot of SEVIS employment history screen (provided by ISSS advisor	Leave empty if no prior OPT or CPT.
Form I-20	Newest I-20 with pre-completion OPT recommendation	This is only referring to the I-20 recommending OPT, not any prior I-20s

Additional Notes:

• If you have a prior SEVIS ID number, ISSS recommends including the prior SEVIS ID in the additional information section.
• If you have completed less than 1 full year in F-1 status (e.g. started program in H-4 status), ISSS recommends that you upload proof of prior immigration status as well as transcripts showing that you completed 1 academic year of full-time enrollment.

The Form I-765 is the form where you are formally requesting pre-completion OPT authorization from USCIS. When electronically filing the Form I-765 with USCIS online, you will not fill out a paper copy of the Form I-765. The USCIS online filing system uses logic that limits the questions you will need to answer based on prior answers, diminishing the opportunity for errors. You will not be required to submit a copy of your I-765 to ISSS for review. The ISSS advisor who issues the I-20 recommending pre-completion OPT welcomes the opportunity to review your draft I-765 before you make payment and submit your complete application to USCIS. 

When filling out your online application, please be sure to select the proper eligibility category:  (c) (3) (A) Pre-Completion OPT.

• First, make any edits that ISSS has recommended to your post-completion OPT application materials and review all your materials for completion and accuracy.    
• Compile all the USCIS application materials that were listed in section 3. Ensure they are complete and accurate.   
• Now you will submit your materials to USCIS.

To electronically file the Form I-765 with USCIS online, individuals must first create a USCIS online account at myaccount.uscis.gov. Once you have created an account, you’ll be able to complete the filing process. Within your USCIS account, you will be able to:

• Upload your documents;  
  • Documents can be uploaded in the following formats: JPG, JPEG, PDF, TIF, or TIFF. Photos can be uploaded as a JPG, JPEG, or PNG.   
  • File names must contain only English characters (e.g. ABC). Special characters (e.g. @, #, $, &) are not allowed. You will receive an error message if the file format or file name do not meet the standards above.   
• Pay the $410 fee; 
  • Payment will be made on a secure website using a credit or debit card. This means that you'll be able to confirm receipt of payment at the time of application. ISSS understands that once you submit payment, your whole application will be submitted to USCIS. Please make sure that you are ready to submit your entire pre-completion OPT application (including the required pre-completion OPT recommendation I-20 from ISSS, passport photos, and any other supporting documents) when you get to the payment screen.  
• Once you submit your application through the online system, you should:   
  • Receive your receipt notice and receipt number immediately within your USCIS account;  
  • Be able to track the status of your case;  
  • Communicate with USCIS through a secure inbox; and 
  • Respond to Requests for Evidence (RFE). 

USCIS must receive your pre-completion OPT application within 30 days of the date ISSS enters the recommendation for pre-completion OPT into your SEVIS record.

You must have your EAD in hand and be in your authorized period of pre-completion OPT to begin working. 

You can depart the U.S. with a pending pre-completion OPT application. Be sure you have your pre-completion OPT I-20 with a valid travel signature, and active visa.    

There are a few things to be aware of if traveling with a pending OPT application:    

• If additional information is needed for your OPT application, USCIS will mail you a request for evidence (RFE). If you receive an RFE you will need to respond in a certain amount of time and you may have difficulty responding to any request(s) for evidence from USCIS while you are outside of the U.S., which could result in a delay of an OPT approval or an OPT denial.  
• Future travel restrictions could impede your ability to return to the U.S.; travel restrictions may change at a moment’s notice. You will need to carefully consult both the airline and the travel restrictions for the country to which you will be returning to the U.S. from.