Paid vs. Unpaid CPT

CPT authorization is more than just employment authorization to accept compensation. CPT provides a framework for you to apply your academic knowledge in a practical, real world setting.

CPT authorization is required for all paid practical training experiences. Payment includes any remuneration or compensation, such as money, meals, lodging, transportation, etc.

CPT for unpaid practical training experiences is strongly recommended. If the unpaid experience is directly related to your degree program, you should seek CPT authorization. 

Unpaid Internship

Policy effective Summer 2019.

An unpaid internship is a common example of when you should request CPT authorization. UW-Madison adopts the National Association of Colleges & Employers (NACE) definition of an internship,

An internship is a form of experiential learning that integrates knowledge and theory learned in the classroom with practical application and skills development in a professional setting. Internships give students the opportunity to gain valuable applied experience and make connections in professional fields they are considering for career paths; and give employers the opportunity to guide and evaluate talent.

UW-Madison follows the seven NACE criteria to determine an internship, which builds upon the U.S. Department of Labor criteria for an unpaid internship. If your offer meets the following criteria, you should request CPT authorization.

1. The experience must be an extension of the classroom: a learning experience that provides for applying the knowledge gained in the classroom. It must not be simply to advance the operations of the employer or be the work that a regular employee would routinely perform.
2. The skills or knowledge learned must be transferable to other employment settings.
3. The experience has a defined beginning and end, and a job description with desired qualifications.
4. There are clearly defined learning objectives/goals related to the professional goals of the student’s academic coursework.
5. There is supervision by a professional with expertise and educational and/or professional background in the field of the experience.
6. There is routine feedback by the experienced supervisor. 
7. There are resources, equipment, and facilities provided by the host employer that support learning objectives/goals.

If you have an unpaid internship or practical training experience where CPT is not possible, it is important that you and your supervisor understand the Department of Labor criteria. We recommend that you get a letter to acknowledge your unpaid position, including job duties, dates, location, and supervisor, and that you received no remuneration or compensation for the duties performed.

If your department does not have a course enrollment option for CPT for an unpaid internship, requesting authorization for pre-completion OPT may be an option. You should plan 3-5 months in advance to apply for OPT.

You should always consult an ISS advisor before accepting an unpaid position for which you do not intend to seek practical training authorization. If the federal government determines that your unpaid experience should have had practical training authorization, you could face the following consequences.

• denial of your USCIS application for OPT
• potential accrual of unlawful presence
• ineligibility for future visas that allow for work authorization, such as H-1B, O-1, TN, or permanent residency

Volunteering

Policy effective Summer 2019.

It is important to make a distinction between volunteering and unpaid practical training. The U.S. Department of Labor defines a volunteer as an “individual who performs hours of service…for civic, charitable, or humanitarian reasons, without promise, expectation or receipt of compensation for services rendered.” There is typically no direct supervision or mentorship for a volunteer position.

Common volunteer places include a literacy network, homeless shelter, food pantry, animal shelter, etc. Badger Volunteers is a campus resource for volunteer and public service activities.

A volunteer position must meet the following conditions:

1. No expectation of compensation
2. The volunteer cannot displace a genuine employee
3. The services provided by the volunteer should not be the same services for which he or she was previously paid and/or expects to be hired and paid for in the future
4. Services are performed for a non-profit organization for public service, religious or humanitarian objective
5. Work at a for-profit entity is considered employment and must be for pay, or must meet the criteria for an unpaid internship (see above). CPT is strongly recommended for unpaid internships.

If your experience meets the volunteer criteria, then CPT is likely not required.

If you engage in volunteer activities, ISS recommends that you get a letter from the volunteer organization to keep in your permanent records. A template volunteer letter is provided in the “Volunteering at UW-Madison” section below.

Practicum

Policy effective Summer 2019.

A practicum allows a student to integrate what they have learned in the classroom to a real- world work setting with the supervision of a professional in that field of study.

If your degree program requires you to complete a practicum or series of practica, you may need CPT authorization. This will depend on the level of “hands on” practical training involved in your practicum experience. “Hands on” experience is when you are learning by actively doing or performing tasks versus learning in a book or traditional classroom setting. You are taking more of an active role instead of being an inactive observer. Consult with your academic advisor for clarification of practicum in your degree program. 

Some examples of “hands on” experience may include:

• Developing the curriculum and actively teaching a class (education major)
• Taking the lead to conduct home visits or client meetings (social work major)

ISS has defined practicum “tiers” to help clarify when CPT authorization is recommended and when it is likely not required.

Tier 1 : Observation or Shadowing

If the objective of the practicum is primarily your observation or shadowing of a professional in your field of study with little or no “hands-on” experience, CPT is not required.

Tier 2 : Shadowing and Hands-on Training

If the objective of the practicum is  your observation or shadowing of a professional in your field of study and up to 50% “hands-on” experience, CPT is strongly recommended.

Tier 3 : Hands-on Training

If the objective of the practicum is primarily (51% or more) your “hands-on” training and experience, CPT is required.