Student Reporting Requirements During Post-Completion OPT
Students in F-1 status authorized for employment under OPT are responsible for maintaining their nonimmigrant status. According to Federal Regulations, F-1 students are required to report information within 10 calendar days directly to the ISO (via iMIT) regarding their employment, as well as changes to personal information and immigration status. Failure to comply with these reporting requirements may result in denial of future benefits (i.e., extension of employment under the H-1B OPT Cap-Gap rule and STEM OPT program) and termination of status and OPT authorization.
What Needs To Be Reported?
Students are required to report the following information (via iMIT.mit.edu) within 10 calendar days.
- Change of legal name or citizenship.
- Change of current residential address.
- If mailing address is different than residential address, then the student must report both addresses, within 10 calendar days of the change.
- Change of U.S. telephone number.
- Change of primary and alternate email addresses.
- Beginning and end date of all employment.
- Name of the employer(s) and mailing address.
- Type of employment – whether the job is self-employment as business owner, contractual/work for hire, multiple gigs, or volunteer in the students field of study.
- Number of hours the student will work, full time (at least 20+ hours per week) or part time (20 hours or less per week).
- Unemployment longer than 10 days (report date of last job).
- Decision to end employment/OPT and leave the U.S.
- Transfer and/or beginning of new program of study.
- Change of U.S. immigration status (provide documentation of change of status (COS))
NOTE: The same reporting is required during the H-1B Cap-Gap extension of OPT and penalties for failure to comply also apply. See the section below for ‘How To Report’.
How to Report
- Go to iMIT.mit.edu.
- For students or alumni with active Kerberos IDs, login to ‘Full Client Services for Students’.
- For alumni without active Kerberos IDs, login to ‘Limited Client Services for Alumni’.
- If applicable, the student must ‘Request a PIN’ to access iMIT. If a student does not receive a PIN, then they have not updated the ISO with their current contact information (i.e., a personal email address – Gmail, Hotmail, etc.). If this occurs, then the student must email ISO Advisor directly with their new email address information.
- Click on the ‘F-1 Practical Training’ link (located on the left sidebar of the students iMIT Home Page) > Click on the ‘OPT / STEM OPT Reporting’ tab > Click on ‘Start a New Request’ > and then submit all the following e-Forms as necessary:
- ‘Submit OPT / STEM OPT EAD Card’ e-Form
- REQUIRED if the student has not previously submitted a copy of their most recently issued EAD card.
- ‘Update Contact Information for Alumni’ e-Form
- ONLY available to alumni students on Post-Completion OPT (i.e., after the program completion end date listed on a student’s OPT Form I-20).
- Current Students (i.e., before the program completion end date listed on a student’s OPT Form I-20) should update their contact information through WebSIS.
- ‘Update Addresses for Alumni’ e-Form
- Alumni Students: Available to alumni students on Post-Completion OPT (i.e., after the program end date listed on a student’s OPT Form I-20).
- Current Students: Not available to current students (i.e., before the program end date listed on a student’s OPT Form I-20). Current students should update their contact information through WebSIS.
- ‘Add New Employer Information on OPT / STEM OPT’ e-Form
- ‘Edit / End Current Employer Information on OPT / STEM OPT’ e-Form
- ‘Report Departure from U.S., Visa Status Change (e.g., Cap Gap I-20 Request), or Unemployment on OPT’ e-Form
- ‘Submit OPT / STEM OPT EAD Card’ e-Form
Travel During Post-Completion OPT
Travel during an APPROVED period of Post-Completion OPT is not restricted if the student has all the materials/documents required for entry into the U.S.
Travel AFTER Program Completion End Date – OPT Approved: If a student plans on re-entering the U.S. AFTER the program completion end date listed on their OPT Form I-20, then ICE (U.S. Immigration Customs and Enforcement) states under the question, ‘Can I reenter if I left while on OPT?’: “If USCIS has approved your OPT you will be expected to have your EAD in hand to re-enter the United States, in addition to your Form I-20, valid passport and visa, and a letter of employment if you have one. If you exceed the limits on unemployment while outside the United States, you will not be eligible to re-enter the United States in F-1 status.”
Therefore, a student will need the required documents listed below to re-enter the U.S. after the program completion end date listed on their most recently issued OPT Form I-20:
- Valid passport (valid for 6 months into the future).
- Valid F-1 visa sticker (NOT expired), except for Canadians, Bahamians, and Bermudians.
- Students should NEVER use a tourist visa (B-1/B-2) or Visa Waiver Program (VWP / ESTA) to enter the U.S. while on OPT, as that will cancel their OPT authorization.
- Most recently issued Form I-20.
- If the student’s EAD Card has been approved, then their employer information should be reported to iMIT and listed on page 2 of their most recently issued Form I-20.
- Most recently issued Form I-20 signed for travel (page 2) within the past 6 months. See below for steps on how to obtain a travel signature.
- Approved OPT EAD card.
- Employment/Job Offer letter for OPT (if applicable).
- Letter should include the dates of employment/training, job duties, location of training activity, supervisor contact information, and any salary/stipend received.
- Proof of vaccination against COVID-19.
NOTE: If a student is missing any of the above mentioned documents, they risk being denied entry into the U.S. and/or losing their F-1 status and OPT benefit(s). The ISO can never guarantee re-entry into the U.S. or predict what may happen at the U.S. border point-of-entry.
Students can find additional information regarding travel during a student’s F-1 OPT/STEM OPT period on the ISO’s website and I.C.E’s website.
Do I Need An Updated Travel Signature? How Can I Request An Updated Travel Signature?
Students MUST review the ISO’s ‘Traveling During F1-OPT/STEM OPT’ webpage for detailed information regarding:
- How to determine whether or not an updated travel signature is required.
- How to request an updated travel signature during Post-Completion OPT/STEM OPT.
During an approved period of OPT (i.e., Post-Completion OPT or STEM OPT) a travel signature on a Form I-20 is ONLY valid for 6 months from the travel signature date listed on page 2 of a student’s most recently issued document. Therefore, it is important for student’s to remember that their U.S. immigration status is their responsibility and they must validate that all their OPT reporting requirements and contact information are up-to-date BEFORE submitting a request in iMIT.
Unemployment Time During Post-Completion OPT
After completion of a student’s degree program,they remain in F-1 status while on Post-Completion OPT; remember ‘OPT’ is not a U.S. immigration status, but rather a benefit of one’s F-1 status.However, instead of the student’s F-1 status being tied to their academics, their F-1 status is now tied to their work/employment in the U.S.Students are NOT permitted to accumulate more than a total of 90 days of unemployment time for the entire duration of their 12-month period of Post-Completion OPT.
Unemployment Time During Post-Completion:
- ONLY begins to accumulate from the start date listed on a student’s approved OPT EAD card.
- All students on Post-Completion OPT accumulate unemployment time if they are not working/employed in their degree/major field of study (i.e., qualified employment). See the section below for ‘Qualified Employment During Post-Completion OPT’.
- Can ONLY be 90 calendar days (MAX) for the whole 12-month duration of Post-Completion OPT (this include weekends and holidays).
- ATTENTION: Accumulating more than 90 days of unemployment time is a violation of a student’s F-1 immigration status and could trigger termination of their F-1 status and any F-1 practical training benefits (e.g., STEM OPT Extension, H-1B, etc.). For more information, see the ISO webpages on STEM OPT Extension or Cap-Gap rule.
- Can be utilized prior to starting work/employment, some examples are:
- If a student’s EAD card has a start date of June 15, 2023, but they will not begin their employment until June 30, 2023; then the student has used 15 days of their OPT unemployment time.
- If a student’s OPT EAD card was approved with a start date of June 15, 2023, but they did not receive their EAD card until June 20, 2023, then the student accumulated 5 days of OPT unemployment time.
- Can be utilized between periods of employment/employers during an OPT authorization period, some examples are:
- If a student ends employment with Employer A on December 15, 2023, but they do not start with Employer B until January 15, 2024, then the student accumulated 30 days of OPT unemployment time.
NOTE: Students are required to keep track of their OPT unemployment time/days. Accumulating more than 90 days of unemployment is considered a violation of F-1 status by DHS, and can have serious implications to one’s U.S. immigration status and benefits.
Qualified Employment During Post-Completion OPT
During a student’s Post-Completion OPT duration they must be working in “Qualified Employment” to maintain their F-1 status in the U.S.
What is considered “Qualified Employment”?
- Work/Employment must be directly related to the student’s degree/major and provide practical experience in their field of study.
- Work/Employment must be in the U.S. and the student must be maintaining a U.S. address.
- Working/Employment must be 20 hours or more per week.
- Two or more employers/jobs during an approved period of Post-Completion OPT is allowed.
- e.g., a combination of one full-time job (20 hours or more a week) and one part-time job (less than 20 hours a week) combined.
- Two or more part-time employers/jobs combined, to equal 20 hours or more a week, is allowed.
- e.g., a combination of two part-time jobs, that when combined, equal 20 hours a week or more. However, we would recommend that at least one of the employers/jobs should be for 20 hours a week or more.
- Two or more employers/jobs during an approved period of Post-Completion OPT is allowed.
- Student must have reported all employment and/or changes within 10 calendar days of starting employment and/or when any changes occur. This must be reported to the student’s iMIT account.
- NOTE: Students can ONLY begin work/employment (paid or unpaid) if they have the physical EAD card and are within the dates listed on the card.
What else can be considered “Qualified Employment”?
- Paid employment.
- Unpaid employment. See the section below for ‘Volunteer or Unpaid employment?’.
- Employment with multiple employers.
- Short-term employment and/or contract work.
- Evidence of duration of the contract, name of the company and address needed.
- Self-employment (e.g., one’s own start-up/business owner).
- Proper business documentation and licensing are needed. Also, evidence of active engagement in business is needed.
- Employment through a staffing agency or consulting firm.
Volunteer or unpaid employment?
- A student may work as a volunteer or unpaid intern on Post-Completion OPT, where this practice does not violate any labor laws.
- The work/employment must be at least 20 hours per week or more.
- The work/employment must be related to the student’s degree/major and provide practical experience in their field.
- A student must be able to provide evidence (job offer letter, etc.) acquired from the student’s employer to verify dates and hours of employment, as well as a brief job description.