International students, and their employers in many cases, were overjoyed to learn that the OPT STEM extensions will now be valid for a full 24 months. Many employers were not so overjoyed to learn about the extra hoops they now have to jump through to get 24 full months with their favorite international student workers.

For those unfamiliar with the Optional Practical Training program (“OPT”), it provides international students in the U.S. a status known as “F-1/OPT”. This status is functionally similar to an internship that allows international students to get practical work experience during or at the end of their university studies. Many of these students have degrees in the fields of Science, Technology, Engineering, or Mathematics, known as “STEM” degrees.

By way of ensuring that the Optional Practical Training (OPT) program is truly about training, rather than a short-term employment solution, Imigration now requires a detailed description of the training resources employers offer their OPT workers, including goals, schedules, and frequency of access to mentors. USCIS has also indicated that site visits may be in store for employers of OPT workers to ensure that said training description is being carried out in practice.

This rule is brand new, so it will take some time to develop intelligence about what an adequate training program looks like in USCIS’s estimation. The first series of requests for evidence and decisions on extension requests are just beginning to trickle in, so stay tuned.