The Department of Homeland Security (DHS) proposed a $70,000 fee on October 8 for a school to recommend an international student for Optional Practical Training, a program that lets students work in their field of study. Another recommendation would generally cost $30,000 after the initial fee had been paid. For a student approaching graduation, the proposal could make the chance to use an American degree depend on whether a school, employer or family can finance that additional expense. The proposal leaves schools room to seek the money from others.

That gives universities a decision well beyond checking whether a student qualifies. They would have to decide whose training they can afford to support. Employers would face a related choice about helping cover the cost of hiring a graduate.

DHS says the financial commitment would make schools scrutinize applications more closely and protect American workers. International educators argue that the fees would drive away graduates whose skills benefit the country. Understanding that disagreement starts with what the program does and how the proposed payment would work.

Optional Practical Training, usually called OPT, allows eligible students with F-1 academic student status to take temporary work directly related to their studies. A school recommends the student, then U.S. Citizenship and Immigration Services decides whether to authorize employment. The school’s recommendation alone does not give someone permission to start work. These are separate steps.

The ordinary allowance is up to 12 months, used before or after graduation. Qualifying graduates in science, technology, engineering and mathematics, known as STEM fields, can receive an additional 24 months. An engineering graduate, for example, could use that period to gain experience designing equipment or developing software related to the degree.

The underlying idea has a long history. Federal regulations have allowed school-recommended practical training since 1947. The George W. Bush administration extended the period for eligible STEM graduates in 2008 and the Obama administration expanded it again in 2016. Both cited the contributions of international students and American competitiveness, according to the Congressional Research Service.

That history helps explain the competing expectations. Universities and employers have built around a route that connects education with work experience. DHS emphasizes that F-1 status is for temporary study and argues that schools should be able to attract students on the strength of their education. Its proposal places greater financial responsibility on schools that recommend the work experience.

Under the proposed payment rules, the school would pay before a member of its own staff, called a designated school official, records the student’s OPT recommendation in the federal student-tracking system. The student would then submit an application for permission to work to U.S. Citizenship and Immigration Services. That federal agency would decide whether to approve it; payment alone would not authorize employment.

The initial charge would be $70,000 for each student. A later recommendation for that student would cost $30,000 once the initial fee had been paid. For someone moving from an initial year of OPT into a qualifying STEM extension, those two charges would total $100,000. Changing employers would not itself trigger another fee.

Schools would be responsible for sending the payment, but DHS expressly contemplates their recovering the expense from students, employers or other sources. That means the financial burden could spread beyond the institution named on the bill. A university might fund selected recommendations, ask an employer to contribute or decide it cannot support a student’s participation. The proposal permits those choices without guaranteeing which one any institution would make.

There is also a transition detail that matters for people already working. A new recommendation dated on or after the eventual effective date would trigger the $70,000 charge if the initial fee had never been paid. That includes a recommendation for a STEM extension. A student already using ordinary OPT could therefore encounter the initial charge when seeking more training time.

The notice is a proposal, so it does not impose those charges on publication. DHS proposes an effective date 60 days after a final rule appears. Its transition provisions turn on the date of the recommendation; they do not announce blanket cancellation of existing work authorizations.

The department’s affirmative case is that schools should have more at stake when recommending students. It describes fraudulent employment arrangements and work unrelated to students’ degrees, arguing that expensive recommendations would encourage institutions to investigate more carefully.

DHS also wants to reduce the use of OPT as a route to low-paid employment that it says can displace American workers. It expects more selective recommendations to narrow participation and make oversight easier for the government. For American graduates competing for jobs, the promised benefit is stronger protection against employers using an educational program to obtain cheaper labor.

The mechanism depends on a judgment about incentives: a school facing a large bill would have reason to examine whether a placement is worthwhile and legitimate. DHS presents the fee as a relatively fast way to change that behavior without adding the same enforcement workload as more inspections. The money would go to Treasury, and U.S. Immigration and Customs Enforcement would have no authority to keep it for enforcement. Paying the fee would therefore create a financial stake without automatically funding more investigators.

Fanta Aw is executive director and CEO of NAFSA: Association of International Educators, a nonprofit professional association focused on international study and student exchanges. In its October 7 statement, she argues that practical training lets graduates put their degrees to use in American workplaces, fill shortages in skilled jobs and help develop new products and technologies. Her concern is that the fees would push those graduates to take their skills elsewhere.

DHS’s examples of fraud include employers offering jobs that exist only on paper and work unrelated to a student’s degree. Educators worry that charging for every recommendation could also make legitimate training unaffordable. Ability to pay does not establish whether a placement follows the program’s rules.

The size of the effect remains uncertain. DHS acknowledges that it cannot confidently predict how much participation would fall. Its estimates use different participation scenarios. Those calculations cannot tell readers how many American workers would gain jobs or how many legitimate placements would disappear.

There is a concrete enforcement option between leaving oversight unchanged and adopting this fee structure. DHS considered extending safeguards used for STEM training to OPT more broadly, including training plans, additional reporting and site visits.

A training plan identifies what the student is supposed to learn; reporting and inspections help check whether the work matches it. Federal staff would have to review records, visit workplaces and investigate suspected violations. That takes time and public money, alongside compliance work by schools and employers. DHS rejected broader use of those safeguards as its initial response, arguing that existing STEM requirements have not prevented fraud and that wider enforcement would demand more resources. The alternative could preserve access to training while targeting violations, but policymakers would have to fund and staff that oversight.

The useful comparison is how effectively each approach identifies abuse and what it costs legitimate participants and the government. Evidence about fraudulent placements, the results of existing oversight and schools’ capacity to pay would help test the department’s reasoning.

Comments on the proposal are due November 9. DHS can revise its approach after reviewing them.

Schools, students and employers can use that process to describe the placements they could finance and those they would forgo. They can also explain the checks they use to match the work to a student’s education. Those accounts would help test the administration’s central claim that a large financial commitment produces better oversight. The decision would then rest on evidence about both the abuse prevented and the legitimate training opportunities lost.

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