Pre-Completion OPT

Pre-Completiom Optional Practical Training may be used before graduation.  It is meant to supplement your academic experience with practical experience.

Eligibility & When to Apply

Overview

Optional Practical Training is an F-1 student benefit granted by the U.S. Citizenship and Immigration Services (USCIS).  It allows you to work off-campus in a job related to your major.  It is meant to supplement your academic experience with practical experience.

Who is eligible for Pre-Completion OPT?

To be eligible for Pre-Completion Optional Practical Training, you must document that:

  • you are currently in valid F‑1 status  AND
  • you have been a full‑time student for at least one full academic year (two semesters) AND
  • You are currently completing a degree and will not graduate during or before your pre-completion OPT period.

If applying for Pre-Completion OPT during the academic semester (Fall/Spring) you must be enrolled full-time. You are not eligible for Pre-Completion OPT during the semester in which you are approved for an Academic Reduced Course Load.

When can I use Pre-Completion OPT & how may hours can I work?

Pre-Completion Optional Practical Training may be used during any of the following situations:

a.  during the Fall/Spring semester

  • Only Part-Time is possible; maximum 20 hours per week

b.  during annual vacation periods (summer and winter breaks, when they are not the final semester)

  • May choose full-time (21 hours or more per week) or part-time
  1. After completing all course requirements, while working on one’s thesis or dissertation
  • May choose full-time (21 hours or more per week) or part-time

At the time of application, you must choose part-time or full-time (if eligible for either). It is not possible to change the maximum number of hours per week after submitting your application.

How long is Pre-Completion OPT authorized for?

In general, you choose the start date and end date. However, keep in mind that USCIS processing times are currently 3-5 months.

The dates of any full-time Pre-OPT must align with a semester since ISS must confirm that you meet one of the requirements above. For example, if you want a full-time summer Pre-OPT, your start date must be after the Spring semester ends. The end date must be before the Fall semester begins.

How does Pre-Completion OPT impact Post-Completion OPT?

Any full-time Pre-Completion Optional Practical Training authorization you receive is subtracted from your total 12‑month period. 

  • Ex. A student who is authorized for 3 months of full‑time Pre-Completion OPT during the summer will have only 9 months of OPT remaining.

Any part‑time OPT (20 hours per week or less) is deducted at the rate of one day of practical training for every two part‑time days of OPT authorized. 

  • Ex. A student who is authorized for 4 months of part-time Pre-Completion OPT during the semester will have 10 months of full-time OPT remaining.

When should I apply for Pre-Completion OPT?

The earliest you can apply is 90 days before your chosen work start date.

You may submit your application up to 90 days prior to completing one academic year of study, provided that the period of employment will not begin until the completion of the full academic year.

Your application must be received by the USCIS within 30 days of the issuance of your OPT I-20 and the signature on your Form I-765. If your OPT application does not comply with this requirement, YOU WILL LOSE YOUR OPT BENEFIT.

Application Step 1: Request Your OPT I-20

Step 1 is applying for an OPT I-20 from ISS

Prepare your OPT application and submit it online to ISS following the directions below:

1.    Login to myISSS by clicking on the blue “LOGIN” button on the left side of the screen and using your UBIT Name and Password. Do NOT click on “Administrative Services for University Departments”.

Having issues with myISSS?

Email our office at isss@buffalo.edu.

2.    Click on “F-1 Practical Training Applications” and then “PRE-Completion Optional Practical Training”.

4.    You must complete the entire E-form and upload all required documents before you can submit your application.  Only documents saved as a PDF or JPEG are acceptable.  You must upload:

  • Form I‑765 (fillable online)
    • When completing Form I-765, be sure to include the correct eligibility code (c) (3) (A) for Pre-Completion OPT.
    • Be sure to also carefully review the USCIS instructions. ISS Form I-765 suggestions are available within the OPT E-form application.
    • Before uploading your Form I-765 to myISSS, remember to print the form, sign it, scan it, and then save it as a PDF or JPEG.
    • Be sure that the address you use on your Form I-765 is an address where you will receive mail in 3-5 months.  If you change your address before receiving your EAD, be sure to report your address change to the USCIS.  

5.  “Submit”. After reviewing your application, ISS will enter your OPT into SEVIS, which will produce a new I-20 with the OPT recommendation. You will receive an email when your I-20 is ready for pick-up.

ISS processing time is 5-7 business days.

Application Step 2: Apply for Your EAD

After receiving your OPT I-20 from ISS, submit your complete OPT application for an Employment Authorization Document ("EAD Card") to the USCIS Service Center.

The USCIS must receive the following documents within 30 days of:

 1) the issuance of your I-20 with OPT recommendation, and

2) the signature on your Form I-765.

OPT applications must not be received by the USCIS more than 90 days before the Program End Date on your I-20. If an application is received by the USCIS more than 90 days before the Program End Date, the application may be denied.

ISS recommends that you submit the following documents to the USCIS:

  • Original Form I‑765. Don't forget to sign and include all seven pages!
  • Form G-1145 
  • Application fee of $410.
    • This can be a check (from a U.S. bank), or a U.S. money order.
    • Checks and money orders should be made payable to the "U.S. Department of Homeland Security". 
    • Write the 11-digit number from your I-94 on your check or money order and don’t forget to sign and date the check. Click here to see an example personal check.
  • Photocopy of pages 1 and 2 of your new I‑20 - Don’t forget to sign and date the Student Attestation section of your I-20.
  • Photocopies of all previous I‑20's. Do not send originals!
  • Photocopy of your current, valid passport (biographic and photo pages) and U.S. visa stamp in your passport. If your passport has expired, please go to ISS, Talbert Hall 210 for advice.  Note:  Canadian citizens do not have visa stamps.
  • Photocopy of the front and back of your newest I-94 Card OR print-out of electronic I-94 (available on CBP's website).
  • Photocopy of previously issued an EAD Card, if you were issued one.
  • Two (2) identical natural color photographs of yourself, taken within 30 days of your application and not previously used for another purpose.
    • Please review the specifications for the photos.  Note: If your photos do not meet USCIS requirements exactly, your EAD card will not be issued.
    • In pencil, write your name and I-94 number lightly on the back of each photo.
    • Photos can be taken at most drug stores (Walgreens, CVS, Rite Aid) or at the UB Law Library, 211 O’Brian Hall (Tel. 645-2204).

Be sure to photocopy your entire OPT application for your personal records.

It is extremely important that applicants for OPT submit a complete and accurate application to the USCIS. The USCIS recently announced that they have full discretion to deny applications without first issuing a Request For Evidence (RFE). This means that if there is a mistake in your application or you forget to include a required document, USCIS may deny your application. For additional information see USCIS RFE AND NOID POLICY.   

Where do I send my OPT application?

The address to use depends on the mailing address listed on your I-765. Please refer to the USCIS lockbox facilities page for details.

You should use a reliable, express delivery service (e.g. UPS, FedEx) to mail your application. Utilizing an express delivery service will enable you to track your application and its delivery. Please save your receipt.

While Your Application is Pending with USCIS

What if my mailing address changes?

If your mailing address changes after you submit your OPT application to USCIS, you must notify the USCIS, the Post Office and ISS of your change in address within 10 days of the change. Failure to notify USCIS and the Post Office in a timely manner could result in delays in receiving your EAD.

To notify the USCIS, use their online Change of Address Form. You will need your OPT Application Receipt Number to complete the form. If you move to a new address, you should also notify the US Postal Service (USPS) using their online form.  Finally, to notify ISS, log into myISSS and select F-1 Practical Training Applications from the drop-down menu. Then complete the Update Pending OPT Student Contact Information E-Form.

How long is the OPT application process?

Currently, processing time at the USCIS can be as long as 5 months. However, processing times vary widely, depending on the time of year and workload at the Service Center to which you send your application. We encourage you to regularly review the processing times found on the USCIS website.

If you have a job offer and 120 days has passed since the Receipt Date on your I797 Receipt Notice, you may contact us for assistance. We can inquire with USCIS about the status of your application. However, we cannot guarantee that our inquiry will result in an expedite or change in processing times.

Once you have waited 150 days, or beyond the current maximum published USCIS processing times, we recommend that you take the following actions:

  • Email ISS with a copy of your receipt notice and a description of the actions you have already taken (any communication with USCIS, for example). If ISS has not already inquired with USCIS on your behalf, we will do so.
  • File an "Outside Normal Processing Time E-Request" with USCIS.
  • File a Case Assistance Request with the CIS Ombudsman Office. You can find additional information about the role of the CIS Ombudsman and how to file a request for assistance on DHS' website.

If you received a Request for Evidence, we do not recommend taking any of the actions above until you have waited 60 days after USCIS received your response.

Is it possible to expedite my OPT application?

USCIS expedite criteria are very strict and it can be difficult to provide sufficient evidence to meet the USCIS criteria. Having a job offer or the possibility of losing that job do not generally qualify for an expedite unless you can effectively make an argument that your situation does meet the criteria. If considering an expedite, please ensure that you have sufficient documentation and a compelling argument.

Additional information on expedite criteria and how to file can be found on the USCIS page

How do I communicate OPT challenges with my employer?

We highly recommend that you keep your employer informed about the status of your OPT application. We also recommend communicating that you cannot confirm exactly when your application will be approved, but that you can provide estimated processing times. We have heard from many students whose employers agreed to change their start date multiple times due to processing delays, so it is important to discuss your situation with your employer.

If your employer wants additional information about OPT processing, they are welcome to contact ISS. If you would like your employer to speak to us about the specifics of your case, please send us an email authorizing ISS to discuss your individual situation.

You cannot begin employment until you have received your Employment Authorization Document (EAD) from the USCIS and the “start date” printed on the EAD card is effective.

Employment Reporting & Important Reminders

Important Reminders

  • Reporting employment to ISS is not required. However, we strongly suggest that you keep proof of employment in the form of offer letters, pay stubs, employment contracts or a letter written by the employer confirming employment.
  • Unemployment time is not counted. However, any OPT time spent without employment cannot be re-used or saved.
  • Must choose part-time (20 hours or less) or full-time (only if eligible) when requesting OPT; cannot change after applying.
  • Cannot apply for the 24-Month STEM Extension directly from Pre-Completion OPT. To be eligible for the 24-Month STEM Extension, you must first be approved for Post-Completion OPT.
  • Not eligible for the Cap Gap Extension directly after Pre-Completion OPT. To be eligible for the Cap Gap Extension, one must first be approved for Post-Completion OPT.
  • May extend I-20 during Pre-Completion OPT if extra time is needed to complete degree requirements
  • Must apply for Post-Completion OPT if employment will continue after the degree conferral date. This will require another application fee to USCIS, and is subject to the same standard USCIS processing times.
  • May not also work on campus during Fall/Spring if total hours (Pre-Completion OPT and On-Campus work) exceed 20.