Pre-Completion OPT

Regulations

Pre-Completion OPT allows students to use the OPT BEFORE the end of their Program.  Using Pre-Completion OPT does count against Post-Completion OPT. An applicant for Pre-Completion OPT can file his or her documents up to 90 days before being enrolled for one academic year as long as the period of employment will not begin prior to the completion of the full academic year. This allows first year students to obtain Pre-Completion OPT in the summer after their first year. Like Curricular Practical Training (CPT), the training MUST be directly related to the area of study and not just serve as an opportunity to work. Students may engage in OPT for any employer in any location for the duration of OPT authorization, as long as the employment qualifies under OPT standards. During Pre-Completion OPT, students must maintain a full course of study during the period of employment (unless done during school breaks). Pre-Completion OPT cannot be extended under the STEM OPT extension provisions (including Cap-Gap Extension).

Timing

• Pre-Completion OPT is authorized to be worked before the student's program end date. Graduate students who have completed all coursework and have only their thesis or dissertation to complete would qualify for pre-completion OPT (as well as post-completion OPT).

• A student cannot begin OPT employment until the start date indicated on the EAD issued by USCIS. The effective date of the Employment Authorization Document (EAD) issued by USCIS for standard pre-completion will be either the start date requested by the DSO when the recommendation was done in SEVIS, or the date USCIS approves the application for work authorization, whichever occurs later.

Duration

• Pre-Completion Optional Practical Training has a limit of 12 months per educational level.

• Previous use of full-time Curricular Practical Training (CPT) for one year or more eliminates eligibility for any Optional Practical Training.

• Use of pre-completion OPT impacts availability of post-completion OPT - Full-time pre-completion OPT is deducted from the 12 month cumulative limit at the full-time rate; Part-time pre-completion OPT is deducted from the 12 month cumulative limit at a 50% rate.

• There is a 20 hours/week limit for pre-completion OPT done while school is in session and student still has coursework to complete.

• Full-time employment can be requested for pre-completion OPT done during official school breaks, and for students who have completed all requirements for their degree except for thesis or dissertation.

• Travel outside the U.S. during the OPT application process is at the student's own risk. In some cases, students have been denied re-entry to the United States even with proper documentation.

Employment

A job offer is not required in order to apply for Pre-Completion OPT; however, a student is limited to a total of 90 days of unemployment and any time of unemployment counts as part of the 12 month limit. The 90 days begins when the EAD card is issued. Once the student has gained employment, it is his or her responsibility to submit this information to the Baylor ISSS Office. Thesis/Dissertation students are not subject to the unemployment provisions, and may receive a program extension.

Applying: The student is responsible for the application process for OPT. This includes submitting a request to the Baylor ISSS Office. All documents must be submitted to USCIS within 30 days of the date that the DSO enters the OPT recommendation into SEVIS and signs the I-20.

Process

1. The student attends an OPT Workshop. Dates and a registration link are below.

2. Within 2 days after attending the OPT Workshop, the link to begin the OPT application is emailed to the student.

3. The student completes the OPT application in Global Bears.

4. After determining eligibility, the DSO updates SEVIS with an OPT recommendation.

5. The DSO prepares a new Form I-20.

6. The student files documents (paper submission or online) within OPT filing deadlines and within 30 days of the Baylor DSO recommendation. Documents sent to USCIS should include:

   • Photocopy all prior Forms I-20

   • Photocopy any previous employment authorization documents (EAD)

   • Form I-765, Application for Employment Authorization, marked with the proper code for pre-completion OPT

   • Check or obtain a money order for the Form I-765 filing fee (currently $410 but check the DHS website), made payable to "U.S. Department of Homeland Security."

   • Two identical immigration-style photos, taken within 30 days of filing Form I-765 (see 16.9 Photo guidelines for visas and immigration benefits and see 16.9.2 USICS applications requiring photos)

   • Photocopy of Form I-94 (both sides on cardstock I-94 or copy of electronic Form I-94 printout)

7. USCIS reviews and approves or denies OPT request.

8. If approved, USCIS will send the I-797 Receipt within 2 weeks and an EAD (Employment Authorization Document) within 90 days to the address that the student provides on the Form I-765.

9. Upon receipt of the EAD, the student will verify that the information on the card is correct, and then upload a copy of both sides of the card in Global Bears.

10. The student will receive an email from the SEVP Helpdesk with a link to enroll in the SEVP Portal where they will update employer information. More guidance can be found HERE.

11. The student must update changes in address, email, and phone number in Global Bears.

Optional Practical Training Workshops

Students are required to attend an OPT workshop in order to be eligible to apply for OPT.  Students may attend a workshop at any time prior to applying for OPT if they are applying to Pre-Completion OPT.  Please go to the International Student and Scholar Workshops webpage to register for an OPT Workshop