Pre-Completion OPT is Optional Practical Training used before finishing the program of study. Students applying for Pre-Completion OPT often have three initial questions:
- Where do I apply? Students will request an I-20 with OPT Recommendation from ISSA and file the I-765 OPT application with USCIS.
- When can I apply? Students cannot file their I-765 OPT application with USCIS more than 90 days before their requested authorization start date, but students can adjust that authorization start date to allow for more USCIS processing time.
- Does this deduct from my overall OPT? Yes, this will deduct from your 12 months of OPT at this degree level. See more below.
Eligibility Requirements
To be eligible to apply for Pre-Completion OPT employment authorization at the current academic level, the student must:
- be in valid F-1 status at the time of the application
- have been enrolled full-time in the U.S. for at least one consecutive academic year
- not have completed OPT at this same academic level
- have less than 12 months of full-time CPT authorization at this academic level
- be present in the U.S. when filing
USCIS Filing Timelines
Students must ensure USCIS receives the completed application:
- No earlier than 90 days before the requested OPT start date listed on page 2 of their Form I-20
- No later than 30 days after the student is endorsed for OPT by the Designated School Official (i.e., the ISSA advisor)
While Premium Processing is available for Pre-Completion OPT, the expected processing time is 30 business days from the scheduled biometrics appointment. Students should still anticipate a 2-month processing time, even with Premium Processing.
Information about filing the I-765 application can be found here.
Employment during Pre-Completion OPT
All employment during the authorization period must be directly related to the student's major area of study listed on their Form I-20. Available employment types can include:
- regular paid employment,
- payment by multiple short-term employers,
- independent contractor positions,
- self-employment,
- employment through an employment agency, or
- volunteer or unpaid internships, where no labor laws are violated.
Full-time authorization means employment that is more than 20 hours each week. This will typically only be available to students during designated school breaks when they are not required to be full-time enrolled.
Part-time authorization means employment that is 20 hours or less each week.
It is the student's responsibility to maintain documentation of all reported employment. SEVP recommends that the student maintain evidence for each job documenting the position held, proof of the duration of that position, the job title, contact information for the student’s supervisor or manager, and a description of the work.
Deducting from available OPT at this degree level
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Full-time Pre-Completion OPT is deducted from the 12 months of total OPT time at 100% rate.
- Ex. Using 3 months of full-time Pre-OPT for a summer internship leaves 9 months for Post-OPT after graduation.
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Part-time Pre-Completion OPT is deducted from the 12 months of total OPT time at a 50% rate.
- Ex. Using 4 months of part-time Pre-OPT during the spring semester leaves 10 months for Post-OPT after graduation.
Considerations for Pre-Completion OPT
- Authorization end date must be on or before the program end date listed on your I-20; anything after that end date would be “post-completion.”
- Pre-completion OPT and Post-completion OPT are separate applications–each requiring their own process and fee.
- Submit your Pre-OPT application strategically to account for your Post-OPT application timeline; ISSA does not advise having more than one I-765 application pending with USCIS at a time
- There are no University resources to assist students in paying OPT fees