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Santa Clara University

Experiential Learning Courses and International Students

Evaluating Experiential Learning for CPT Requirements 

To accommodate all students regardless of their citizenship or immigration status, academic programs may wish to develop curriculum that requires experiential learning of all students so that no immigration authorization is needed.  Likewise, we encourage faculty and staff developing academic programs to define experiential learning in academic terms, rather than as “on campus” employment. This is because many non-F-1 students (H-1, H-4, L-1, etc.) cannot participate in “on campus employment” unless they have an unrestricted right to work. F-1 students who are doing 19 hours/week of on-campus employment are not eligible for simultaneous CPT. 

Analysis: Is Immigration Employment Authorization Required? 

In order to determine if an experiential learning activity requires immigration employment authorization, we review three elements of the activity: 

1. Supervision, Direction and Evaluation 

Supervision, direction and evaluation are hallmarks of an employment relationship. If the student will receive substantial supervision, direction, or evaluation from a company, CPT authorization may be required. 

  • Who develops the problem and/or defines the scope of the project that the students will solve? 
  • Who will provide supervision and oversight of the day to day activity? 
  • Who will provide direction or instructions about the activity? 
  • Who will provide the tools and technologies needed to perform the activity? 
  • To whom will the student report progress or go to with questions? 
  • Who will evaluate the student’s progress or product?
    • How does the evaluation of the end product relate to the evaluation of whether the student has achieved the learning objective? 
    • If the company will contribute to the evaluation, to what degree will the company’s evaluation determine the student’s grade? 
    • Will the students have supervision when they are at the company location? 

2. Location 

The location of activity is relevant to an immigration analysis and contributes to the assessment of whether the activity is purely curricular or whether the off-campus engagement is substantial enough to require immigration employment authorization. Additionally, if immigration employment authorization is needed, the primary location of the activity is also one component needed to determine what kind of authorization is appropriate for F-1 students. 

  • Where will the primary activity be performed? 
  • How many hours during the term will be spent in class? 
  • How many hours during the term will be spent engaged in research or group work outside of class and not at the company’s location? 
  • How many hours during the term will be spent at the company’s location? 
  • What activities will take place at the company’s location?
    • Observation, reflection, shadowing, informational interviews 
    • Gathering data or requirements, giving presentations 
    • Using the company’s tools or technologies 
    • Development or implementation of project, solution, tools, or technologies (productive activity)

3. Remuneration 

If the student will be paid, either by the company or by the university, immigration employment authorization will always be required and a determination of whether the employment meets the eligibility criteria for CPT or on-campus employment must be made. If the student will not be paid but the university will be paid, the general counsel's office and sponsored projects should be consulted. 

  • • Will the student be compensated for the activity? o How will the student be paid? 
    • What entity will pay the student?
  • Will the university be paid for the activity? 
  • Who will “own” the intellectual product? 

Example of Experiential Learning which does not require CPT authorization 

1. Supervision, Direction, and Evaluation 

Supervision, Direction, and Evaluation is performed by SCU faculty member. 

  • SCU faculty develop the problem and define the scope of the project. Faculty may consult with company in developing problem and defining scope. Faculty presents project to students. 
  • SCU faculty provides supervision and oversight of the day to day activities. 
  • SCU faculty provides direction or instructions about the activity. 
  • Tools and technologies needed to perform the activity are provided either by SCU or by student. 
  • The student reports progress to assigned SCU faculty member. 
  • Student questions about the project are addressed by SCU faculty. 
  • SCU faculty is responsible for evaluation of student’s progress and final product. 

2. Location 

  • Primary activity will be performed at SCU or within group work which is not at company site. 
  • Minimal time will be spent at company site. 
  • Activities at the company’s location are limited to:
    • Observation, reflection, shadowing, informational interviews 
    • Team site visit to gather data or requirements at the start of the project 
    • Team site visit to give presentation at the conclusion of the project 

3. Remuneration 

  • Student receives no compensation from the company, including but not limited to salary, hourly wage, stipend, gifts, paid lunches, and entitlement to a job at the conclusion of project. 
  • If student receives remuneration from SCU, this may require alternate immigration work authorization (on-campus employment for F-1 students). 

Activities that may require CPT authorization 

1. Supervision, Direction and Evaluation 

If the student will receive substantial supervision, direction, or evaluation from a company, CPT authorization may be required. 

2. Location 

If the primary location is on-site at a company, CPT authorization may be required. If the student engages in activities that could be considered productive work, CPT authorization is required. 

3. Remuneration 

If the student will be receive any type of remuneration from a company CPT will always be required