MIT currently seems to be treating pre-completion OPT as the main fallback after the new CPT guidance. I posted the argument below to EECS because 6-A is a formal co-op program and the actual regulatory/guidance language may leave more room than that interpretation suggests.

I’m mainly looking for thoughts on two questions: (1) Does this interpretation have reasonable legal/administrative grounding? (2) If so, how can students encourage EECS/6-A to have ISO and outside counsel seriously investigate it, rather than concluding too quickly that CPT is no longer an option?

EDIT: The response on 6.AcAd is as follows. "Please direct this question to the 6A team at 6a@mit.edu. I don't think they're generally on this Piazza and while we work closely together, they will be navigating these changes in CPT where 6A is concerned."

Could the undergraduate office please carefully explore with ISO and MIT’s outside experts whether undergraduate 6-A and MEng 6-A can each separately qualify as an “established curriculum” for CPT? The regulation requires CPT to be “an integral part of an established curriculum” (8 C.F.R. § 214.2(f)(10)(i)), and the more detailed SEVP Broadcast Message 2608-02 repeatedly refers to “all students participating in that curriculum” and “all students enrolled in the same established curriculum” (Qs. 3–5).

I realize the first broadcast (2608-01) says CPT should be necessary for “attainment of a degree” and required for “all students pursuing that degree.” But it does not define the scope of “that degree,” or say that it means everyone in the same major. At the other extreme, reading it as every student pursuing any bachelor’s or master’s degree seems implausibly broad. It therefore seems worth asking whether “attaining the degree under this established curriculum” is a permissible reading, particularly given the regulation and 2608-02’s more specific curriculum-based wording.

6-A seems especially worth examining under that framework. It is explicitly a longstanding cooperative program with a structured curriculum; undergraduate 6-A has also been established since 2022–23. For students enrolled in either undergraduate or MEng 6-A, practical training is part of the 6-A pathway rather than simply an optional internship. ISO’s own email also specifically recognizes training established through a “cooperative agreement” between the school and employer as part of the new framework.

I know pre-completion OPT has been discussed as a fallback, but it is itself exposed to possible upcoming federal changes. Given the seemingly favorable framework for genuine cooperative programs with established curricula, I hope EECS will actively investigate whether CPT can be preserved rather than assuming there are no remaining options.

is anyone still waiting on decisions for the paper submissions??? what is going on...

(our paper is track 1)