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Update for Transfer Pending/Change of Education Level Students Studying Outside the U.S.

We wanted to share an update with you regarding studying outside the U.S. with transfer pending and change of level I-20s in initial status. Your study outside the U.S. while your I-20 was still pending/in initial status may be counted towards CPT and OPT recommendation eligibility.

In autumn quarter, our advice was based on our reading of the Frequently Asked Questions issued by SEVP on August 7, 2020. Based on the questions 15 and 16 that allowed for a delay in transfer eligibility without an explicit need to maintain full-time enrollment outside of the U.S., we began advising students with transfer pending I-20s that they could enroll or not enroll in courses based on their preference. This advice has not changed.

Our advice for students with transfer pending and change of level I-20’s regarding CPT and OPT eligibility based upon full-time enrollment outside the U.S., however, has varied. Without clear answers from SEVP or USCIS, we have been advising students they will not be eligible for these benefits if they are outside the U.S. We recently had interactions with the SEVP Help Desk and the Seattle region SEVP Rep that suggest we can count full-time enrollment outside the U.S. towards CPT and OPT eligibility for students with transfer pending and change of level I-20s.The same flexibility does not exist for students with new initial I-20s.

Although we believe full-time enrollment outside the U.S. with transfer pending and change of level I-20s may count towards OPT eligibility, USCIS adjudicates all OPT applications and thus they may require additional information and/or deny requests for student applications.

Review our Coronavirus website for additional guidance and support as you consider your plans.