USCIS provides additional guidance and Q&A on the OPT Interim Final Rule:

Cap gap provisions

  • Process for converting an H-1B petition/approval from consular notification to change of status
  • Definition of “timely filed”
  • Provision only extends status and work authorization held at time of filing
  • 60 day grace period after rejection/denial/revocation
  • Travel during cap gap
  • Unemployment provisions during cap gap
STEM extension
  • DHS will not be adding additional CIP codes during comment period
  • Previous STEM degrees, dual majors, minors
  • Reporting Requirements
  • E-Verify
I-9 Compliance for cap gap documentation and pending STEM extensions

Unemployment provisions
  • 90 days allowed for each period of OPT split between two degrees at same level (for a total of 180 days)
  • 10 day grace period between employment periods
  • Effect of travel