Satire. Every figure below is drawn from the proposed rule and the responses to it; the notice itself is imagined.

Office of International Student Services Notice of Program Fee

Dear Student,

On October 8 the Department of Homeland Security published a proposed rule under Docket No. ICEB-2026-0100. The schedule of fees below takes effect sixty days after a final rule publishes. Please review it before your advising appointment.

Item 1. Initial Optional Practical Training recommendation — $70,000.

Payable by the institution before your Designated School Official may enter the recommendation in the Student and Exchange Visitor Information System. U.S. Citizenship and Immigration Services will not grant your employment authorization unless the fee has been paid. The fee is not tied to any employer, and it does not change if you change jobs.

Item 2. Subsequent recommendation — $30,000.

Applicable to a later recommendation, including a twenty-four-month extension for students in science, technology, engineering, or mathematics. A student who uses post-completion training and then a STEM extension will total one hundred thousand dollars in institutional fees. A student who uses pre-completion and then post-completion training will also total one hundred thousand dollars. A student who earns a master’s degree after using the training once may be charged the seventy-thousand-dollar initial fee again, as though the first time had not happened.

Item 3. Refunds — discretionary.

Available only if the employment authorization has not yet been issued. Once it has been issued, the fee is nonrefundable and carries no administrative appeal.

A spokesperson for the department explained the reasoning: “Optional Practical Training was never meant to be a back door into the American workforce, a subsidy for cheap labor, or a prize for those who game the system.” The department’s solution, the spokesperson added, is to require foreign students to “justify their worth to employers.”

We should be candid about what this means for our institution. The department intends the fee to give schools a “direct stake in the integrity of OPT,” and it “expressly anticipates” that colleges will reduce participation and recommend only students judged “strong candidates.” It estimates that about 60.5 percent of affected small institutions would face costs exceeding one percent of annual revenue, and that 116 institutions would face costs exceeding twenty percent. Should our college decline to pay, no rule compels us to tell you why. Our advice is to ask early.

The department notes that institutions may cover the fee by passing it to the student, to all students, or to the employer, or by seeking outside funding. It warns, however, that “large or unusual financial contributions from foreign sources, especially those tied to programs that rely heavily on OPT,” may serve as “red flags” for further investigation. Please do not organize a fundraiser without speaking with us first.

The funds collected are deposited in the general Treasury rather than retained to operate the program. The department allows that Congress could appropriate the money back “to enhance the integrity of the immigration system.” It also states that, absent these fees, it may be unable to prevent fraud and could “shut down the program entirely.”

The comment period closes November 9.

For your convenience, the fee may be itemized against the position you are trying to accept. On the current market, seventy thousand dollars is roughly one to two years of tuition at a private four-year college, or about the annual salary of the job for which the training qualifies you. You are, in effect, being asked to cost more than you earn before you earn anything at all.

We recognize this notice raises questions. So does the rule. We will answer what we can.

Sincerely,

The Office

Sources

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