Pre-Completion OPT

The information below focuses on Pre-Completion OPT. For information on Post-Completion OPT, please see https://oiss.rice.edu/opt.

Optional Practical Training (OPT) gives F-1 students 12 months of "temporary employment for practical training directly related to the student’s major area of study" [8 CFR § 214.2(f)(10)(ii)]. OPT is available to F-1 students who have been in full-time student status for at least one academic year in the United States. OPT does not require a job offer. A student may be eligible for a new 12-month period after completing a new degree program at a higher education level. Although most students will choose to apply for the full 12 months as Post-Completion OPT (i.e., work authorization after completing their academic degree), students may also be eligible for Pre-Completion OPT, where they use part or all of the 12 months during their studies.

Important: OPT is not an entitlement but a benefit that is granted at the discretion of USCIS after a thorough review of your application.

Quick Facts about OPT

  • OPT work authorization is available for 12 months.
  • Students can apply for Pre-Completion OPT during their studies (part-time employment only during the semesters, may be full-time during summer and winter breaks) or Post-Completion OPT based on a completed degree (full-time employment).
  • Pre-Completion OPT time will be subtracted from the total 12-month OPT eligibility. For example, if you apply for 2 months of Pre-Completion OPT, you are only eligible for 10 months of Post-Completion OPT.
  • You must be in the United States to apply for OPT.
  • A job offer is not required for OPT application.
  • Employment on OPT must be directly related to the student's major field of study and commensurate with the degree level.
  • Employment on OPT can be paid or unpaid.

How to Request Pre-Completion OPT I-20 from OISS

Step 1: Meet with OISS Advisor

If you are considering Pre-Completion OPT, please schedule an individual appointment with an OISS advisor.

Step 2: Work with your faculty advisor to complete the Pre-Completion OPT Faculty Advisor Form

Student completes the top section, and Rice faculty member/advisor completes the bottom section. Click here to access the Faculty Advisor Form.

Step 3: Complete your Pre-Completion OPT request form online

The Pre-Completion OPT request form, which includes your requested Pre-Completion OPT dates and the Pre-Completion OPT SOU, is available online at https://bit.ly/precompOPTrequest. In addition to completing the form, you must also upload the following documents:

1) Pre-Completion OPT Faculty Advisor Form
2) Your transcript
3) Your most recent I-94 record, available at https://i94.cbp.dhs.gov/I94

How to File Online Pre-Completion OPT Application

Step 1: Prepare application materials

While OISS works on your new I-20 (please allow 1-2 weeks for processing), please make sure you have the remaining application items ready:

1) A passport-style photo taken within the last 6 months
2) Digital copies of your passport, most recent F-1 visa, and current I-94 record
3) Digital copy of the front and back of any previous EAD card(s), if applicable
4) Digital copy of transcript showing full-time enrollment for at least one academic year
5) Digital copies of previous CPT and OPT I-20s
6) Additional supplemental documents as appropriate

Step 2: Attend a Pre-Completion OPT follow-up appointment with an OISS advisor

When your OPT I-20 is ready, an OISS advisor will contact you to schedule a Pre-Completion OPT follow-up appointment, during which the advisor will discuss the rest of the application process.

Step 3: Create a USCIS Online Account

Create the USCIS Online Account at https://myaccount.uscis.gov/.

For detailed step-by-step instructions, please see https://www.uscis.gov/file-online/how-to-create-a-uscis-online-account.

Step 4: Complete the Form I-765 online

Please note that you must complete the online application very carefully. The system allows you to submit an incomplete application without all the required evidence, which can lead to delays and additional difficulties. If you start working on your online I-765 in advance, USCIS will keep your draft for up to 30 days, allowing you to return to finish it later. Do NOT submit the payment and application until you have received the OPT recommendation I-20 from OISS and uploaded it under the Evidence section!

The guidance below is not intended to be legal advice but general suggestions for how you might proceed when completing the online I-765 application.

If you choose to file a paper-based application instead, please see https://www.uscis.gov/i-765 for more information.

Complete the Form I-765 online
Screenshot from USCIS online account. Select what you want to do. File a form online option is circled.

Login to your USCIS Online Account and select "File a form online"
Screenshot from USCIS website. Select the form you want to file online. I-765 is checked from the list of forms.

Select the Form I-765 and click on "Start form"

Read through all the provided information very carefully before proceeding to the questions.
Screenshot from online I-765 form. What is your eligibility category.

Although the menu on the left allows you to skip to any section of the I-765, it is recommended that you complete the form in order to ensure no responses are missed.

Under eligibility category, select "c(3)(A) Student Pre-Completion OPT"

Screenshot from online I-765. What is your reason for applying with Initial permission to accept employment selected. Have you previously filed Form I-765?

Reason for applying should be "Initial permission to accept employment"

Make sure to report any previously filed I-765, if applicable.

Screenshot from online I-765. Is someone assisting you with completing this application?

If a preparer or an interpreter assists you with completing the application, you must disclose it and answer additional questions regarding the preparer and/or interpreter.

Screenshot from online I-765. What is your current legal name? Have you used any other names since birth?

Enter your name exactly as it is listed on your Form I-20. Make sure to also report any other names you may have used, alternate spellings, and any alternate order in which your names may sometimes be listed, if applicable.

Screenshot from online I-765. How may we contact you? What is your current U.S. mailing address? OISS address is listed on the example as follows: OISS, Rice University. 6100 Main Street, MS-365, Houston, Texas 77005.

Please make sure to respond to all questions carefully and accurately.

If you use your own address for mailing, you should leave the “In care of name” field blank. If you use the address of a family member or friend, please enter their name in the "In care of name" field.

You are welcome to use the OISS address for mailing purposes! Please list it as follows:
OISS, Rice University
6100 Main Street
MS-365
Houston, Texas 77005

Screenshot from online I-765. Is your current mailing address the same as your physical address? No is selected as the response. Where in the United States do you live?

If you use a separate mailing address, i.e., an address where you do not currently physically live, you MUST report your physical address separately. This address should match what is reported as your physical address in SEVIS, so please make sure your address is current in ESTHER before submitting your OPT application.

Screenshot from online I-765. What is your gender? What is your marital status?

Please select the options that best apply to you.

Screenshot from online I-765. What is your city, town, or village of birth? What is your state or province of birth? What is your country of birth? What is your date of birth?

Please make sure to respond to all questions carefully and accurately. All dates should be listed in the MM/DD/YYYY format.

Screenshot from online I-765. What is your country of citizenship or nationality? What is your Form I-94 Arrival-Departure Record Number? When did you last arrive in the United States?

Please make sure to respond to all questions carefully and accurately.

If you are a citizen of more than one country, report them all by selecting "+ Add country" as needed.

Your I-94 number is listed at the top of your I-94 record as “Admission (I-94) Record Number.”

Your Status at last arrival is most likely F-1, so select “F-1 - F-1 - Student, Academic or Language Program” from the dropdown.
Exception: If you originally entered the U.S. in a different visa status, filed and were approved by USCIS for a change of status to F-1, and have not traveled internationally since then, please make sure to select the correct status at the last arrival!

Screenshot from online I-765. What is the passport number of your most recently issued passport? What is your travel document number (if any)? What is the expiration date of your passport or travel document? What country issued your passport or travel document?

Please make sure to respond to all questions carefully and accurately.

Most F-1 students do not have a travel document, so you may leave that question blank.

Screenshot from online I-765. What is your current immigration status or category? F-1 Student Academic or Language Program has been selected. What is your Student and Exchange Visitor Information System Number?

In order to qualify for Pre-Completion OPT, your current immigration status must be F-1. Please select “F-1 - F-1 - Student, Academic or Language Program” from the dropdown.

Your SEVIS Number is available at the top of your Form I-20.

Screenshot from online I-765. What is your A-Number? What is your USCIS Online Account Number? I do not have or know my number has been checked on both questions.

Unless you specifically have and know your A-Number and/or your USCIS Online Account Number, you may select that you do not have or know these numbers.

Screenshot from online I-765. Has the SSA ever officially issued a Social Security card to you? Do you want the SSA to issue you a Social Security card? Consent for Disclosure: I authorize disclosure of information from this application to the SSA as required for the purpose of assigning me an SSN and issuing me a Social Security card.

Please make sure to respond to all questions accurately. If you have an SSN, you will be asked to provide it. If you do not have an SSN, you have the option of requesting for a Social Security card to be issued on the Form I-765. In that case you must give USCIS consent to disclose your information to SSA, and you will be asked a few additional questions related to the Social Security Number application.

Screenshot from online I-765. What is your father's birth name? What is your mother's birth name?

These additional questions only apply to students who request that a Social Security card be issued on Form I-765.

Screenshot from online I-765. 2X2 Photo of you.

Please read through the photo requirements carefully. Use the link to access the Department of State’s photo composition tools if you need to resize or otherwise adjust your photo to meet the requirements.

Pay attention to the file requirements, including accepted file formats, file names, and maximum file size.

Screenshot from online I-765. I-94 Arrival and Departure Record.

Please upload a copy of your I-94 record (available at https://i94.cbp.dhs.gov/I94) or a copy of your USCIS I-797A Approval Notice if you have changed status to F-1 inside the U.S. and have not traveled internationally since then.

Pay attention to the file requirements, including accepted file formats, file names, and maximum file size.

Screenshot from online I-765. Employment Authorization Document or Government ID.

Although the instructions for this section only request that one identity document be uploaded, we strongly recommend that you upload all of the following:
1) Passport biographical page
2) Most recent F-1 visa stamp, even if it has expired (if applicable)
3) Previous EAD card(s) (if applicable)

Pay attention to the file requirements, including accepted file formats, file names, and maximum file size.

Screenshot from online I-765. Proof of enrollment.

Please upload a copy of your transcript showing enrollment for one full academic year.

Pay attention to the file requirements, including accepted file formats, file names, and maximum file size.

Screenshot from online I-765. Previously authorized CPT or OPT.

Please upload a copy of the SEVIS employment history document, which will be provided by OISS together with your OPT I-20. We strongly recommend that you also upload copies of all previous I-20s that contain CPT and/or OPT authorizations.

Please note that in addition to uploading the supporting evidence, you must also report any previous CPT and OPT authorizations in the Additional Information section. See below for more information.

Pay attention to the file requirements, including accepted file formats, file names, and maximum file size.

Screenshot from online I-765. I-20, certificate of eligibility for nonimmigrant student status.

Please upload a copy of the new OPT I-20 provided by OISS. No other I-20 copies should be uploaded in this section. Please make sure you have signed the I-20 (by hand in ink; electronic signatures from students are not accepted).

The online application must be submitted to USCIS within 30 days of the issue date of your OPT I-20!

Pay attention to the file requirements, including accepted file formats, file names, and maximum file size.

Screenshot from online I-765. Additional information, the following text entered: Previous CPT authorization: include at least dates and degree level, perhaps also name of employer and if CPT was part-time or full-time.

In addition to uploading the supporting evidence, you must also report any previous CPT authorizations in the Additional Information section of the online I-765, if applicable. Please make sure to include the degree level at which the CPT was granted, as that detail is specifically listed as required in the official USCIS I-765 Instructions.

Screenshot from online I-765. Additional information, the following text entered: Previous OPT authorization: include at least dates and degree level, perhaps also clarify if pre-completion OPT, post-completion OPT, or STEM OPT extension.

In addition to uploading the supporting evidence, you must also report any previous OPT authorizations in the Additional Information section of the online I-765, if applicable. Please make sure to include the degree level at which the OPT was granted, as that detail is specifically listed as required in the official USCIS I-765 Instructions.

Screenshot from online I-765. Additional information, the following text entered: Previous SEVIS ID number: include at least the number, perhaps also dates, sponsoring institution and clarify visa type, especially if other than F-1.

You must also report any previous SEVIS IDs in the Additional Information section of the online I-765, if applicable. Visa types that have a SEVIS record are F-1, F-2, J-1, J-2, M-1 and M-2.

Screenshot from online I-765. Check your application before you submit.

Please review any alerts and warnings very carefully. Although USCIS allows you to add unsolicited documents at a later stage, the application itself cannot be changed after submission.

Screenshot from online I-765. Review the I-765 information.

Please review your responses very carefully. The system allows you to submit your application without all the required documentation, and although USCIS allows you to add unsolicited documents at a later stage, submitting an incomplete application can lead to delays and additional difficulties.

Screenshot from online I-765. Applicant's statement.

If you did not report having used an interpreter, you must attest to having read and understood every question and instructions related to the Form I-765.

Screenshot from online I-765. Applicant's declaration and certification.

Please read the declaration very carefully and sign the online I-765 digitally by typing your full legal name where requested.

Screenshot from online I-765. Pay for and submit your application.

Your OPT application will be submitted to USCIS once you have paid the application fee online. The available payment methods include a withdrawal from a U.S. checking or savings account or payment with a U.S. debit or credit card. USCIS does not accept foreign debit or credit cards.

If you choose to start working on the I-765 in advance, USCIS will keep your draft for up to 30 days, allowing you to return to finish it.

DO NOT SUBMIT THE PAYMENT AND APPLICATION until you have received the new OPT I-20 from OISS and uploaded it under the Evidence section (under Form I-20).

Screenshot from online I-765. Upload unsolicited evidence.

After you submit your application, an electronic receipt notice will be immediately available under Your Cases in the Documents tab. USCIS will also mail you a hard copy receipt notice, which you should receive in a few weeks.

If you wish to add additional documentation to your application, you may upload them as unsolicited evidence.

Step 5: Respond to any requests from USCIS, if applicable

If USCIS issues a Request for Evidence (RFE) for your OPT application, you will receive the notification through your USCIS Online Account. Please read through the request carefully, paying special attention to the response deadline. Contact OISS if you need any assistance, and upload your response through your USCIS Online Account as quickly as possible.

FAQ for Pre-Completion OPT

When is Pre-Completion OPT recommended?

Most F-1 students use CPT (Curricular Practical Training) work authorization for any off-campus practical training opportunities taking place during their studies. However, there are situations where the practical training opportunity does not qualify for CPT, and Pre-Completion OPT is the more appropriate choice. This includes practical training opportunities that are directly related to your major field(s) of study but are not required for or an integral part of your degree program.

Entrepreneurial activities do not qualify for CPT, but instead, they would require an approved Pre-Completion OPT during your studies.

For more information on the differences between CPT and Pre-Completion OPT, please see the F-1 Student Employment Authorization Comparison Chart at https://oiss.rice.edu/studentwork, under Student Work Off-Campus for F-1 Students.

When can I apply for Pre-Completion OPT?

You become eligible for Pre-Completion OPT once you have been enrolled full-time in lawful status for at least one academic year. Your application may be submitted to USCIS before reaching this requirement, but the requested start date must be after eligibility is reached. In addition, you may not submit your application more than 90 days before your requested Pre-Completion OPT start date.

Your application must also be received by USCIS within 30 days of the Pre-Completion OPT I-20 issuance date.

Can I apply if I've used any type of OPT before?

Students are eligible for 12 months of OPT per advancing degree level, so if you have not yet reached 12 months of OPT at your current degree level, you may be eligible to apply for Pre-Completion OPT. Please schedule an appointment with an OISS advisor to discuss your plans in more detail.

How does Pre-Completion OPT affect Post-Completion OPT eligibility?

Pre-Completion OPT time will be subtracted from the total 12-month OPT eligibility for your current degree level, with part-time Pre-Completion OPT being subtracted at 50% of the time authorized.

For example, if you apply for 2 months of full-time Pre-Completion OPT, you are only eligible for 10 months of Post-Completion OPT. If you apply for 2 months of part-time Pre-Completion OPT, only 1 month is subtracted, and you are eligible for 11 months of Post-Completion OPT.

Time approved by USCIS for Pre-Completion OPT cannot be reclaimed for Post-Completion OPT even if you end up not using the Pre-Completion OPT work authorization for work/practical training.

I don’t have a job offer. Can I still apply for Pre-Completion OPT?

Yes, you can apply for OPT even if you don’t have a job offer.

How do I submit the Pre-Completion OPT request to OISS?

Please submit your Pre-Completion OPT request electronically through https://bit.ly/precompOPTrequest.

What happens after the OPT application is submitted online/mailed to USCIS?

1) USCIS sends an I-797 Notice of Action once your application is received, usually in a few weeks. When applying online, the receipt notice is immediately available electronically as well. This notice will contain a receipt number to check the application status at https://egov.uscis.gov/casestatus/landing.do.
2) USCIS mails your OPT EAD card (Employment Authorization Document). Processing times vary but may take 90+ days.

What if my EAD card does not arrive in time?

You are not eligible to begin employment, even unpaid, until you have received the OPT EAD card (Employment Authorization Document issued by USCIS when OPT is approved) and are within the validity dates indicated on the card.

What are the requirements for maintaining status while on Pre-Completion OPT?

The standard rules for maintaining status as an F-1 student still apply; please see https://oiss.rice.edu/maintaining-status for more information. While approved Pre-Completion OPT provides authorization to work, employment is not required to maintain status.

If your Pre-Completion OPT was approved for part-time work authorization, your practical training may not exceed 20 hours/week.

Can I start my own business or work for a start-up company on Pre-Completion OPT?

Yes, as long as the work is directly related to your major field of study and commensurate with your degree level. Please also keep in mind that you are limited to the period of authorized employment indicated on the Pre-Completion OPT EAD card.

Can my Pre-Completion OPT application be expedited?

Possibly, as USCIS has made Premium Processing available for OPT applications. The premium processing filing fee for OPT applications is $1,500, and the guaranteed processing time with premium processing is 30 days. To learn more, please see https://www.uscis.gov/i-907.

OISS is not able to provide detailed guidance or advise on adding Premium Processing to your Pre-Completion OPT application, but USCIS has instructions available under the "Forms and Document Downloads" section of their Premium Processing webpage.

For information on standard processing times without premium processing, please see https://egov.uscis.gov/processing-times.

Pre-Completion OPT is very nuanced. We strongly recommend discussing your plans with an OISS advisor if you are considering Pre-Completion OPT.