As of Friday, April 11, 2008, all schools should have
received their OPT Validation Project lists from SEVP. The OPT Validation
Project, coupled with the new OPT Rule (effective 4/8/08), has resulted in new
reporting requirements for students, schools, and employers.
Acknowledging that there is overlap between reporting requirements stipulated by the Validation Project and the Rule, each has its list of reporting requirements (see chart). Many institutions are looking at the two jointly while others are viewing these as two separate reporting projects.
Reporting for all students on OPT
Reporting for all students on OPT
Reporting for students on 17-month extension OPT
*Note: In the supplementary information to the Rule, and later SEVP Policy Guidance, SEVP has stated that maintaining information in the employer name and address fields in SEVIS is related to the regulatory requirement to report "interruption of employment" and will also assist DHS in its assessment of periods of unemployment when adjudicating eligibility for benefits.
SEVP has provided guidance regarding how a DSO may update SEVIS with the information reported by students. See OPT Validation Project FAQ and SEVP Policy Guidance on OPT.
This practice resource focuses only on reporting requirements for the OPT Validation Project. However, schools will also want to consider what infrastructure will be developed to meet all reporting requirements. One decision that will need to be made is how the information will be collected. Will the reporting be conducted electronically or by paper? For some schools, the decision may be based on whether the school's software/database has fields for employer name and address, and/or whether the school's database is linked to online forms where students can submit information that automatically updates the school's database.
Several schools have already developed a process to comply with the OPT Validation Project, due to SEVP by 06/15/2008, and have agreed to share their methods of contacting students and receiving the relevant information. The following examples can be used in an electronic or paper-based environment.
If a school is unable to comply with the full validation project, SEVP has advised the school to prioritize. Schools should note that the spreadsheet with student information only includes a limited group of students who were approved for post-completion OPT prior to January 31, 2008, and whose OPT ends after May 1, 2008. In particular, SEVP advised that schools could:
- Disregard students whose regular period of 12-month OPT will end before June 15, 2008.
- Focus first on validating the student's name and address before validating employer name and address.
Gathering Information and Updating SEVIS
The OPT Validation Project does not provide batch capability. Schools will need to track information based on the Excel Spreadsheet that was sent to the PDSO to track students who have reported (or not reported). Schools will need to define a process by which the information is gathered efficiently and effectively. Information handling could be streamlined by utilizing some of the following processes:
- Create a specific e-mail address and e-mail box for OPT students.
- Use an existing e-mail address and request that the student use a prespecified Subject Line to allow easy filtering of messages.
- If using an online form, link the Web fields to a spreadsheet and then extract the information to a single data file.
Schools will also need to determine a schedule for updating SEVIS. Because of the possible ramifications of the 90-day limit on unemployment, some schools are collecting all of the information but waiting to update SEVIS records of students, especially those who are currently unemployed, until closer to the deadline.