PUBLIC COMMENT: PROPOSED CHANGES TO OPTIONAL PRACTICAL TRAINING

In October, DHS proposed immense fees, to the tune of $70,000, for applications to Optional Practical Training. Below is Students United's official public comment regarding the proposed rule change. A note to students: -These are proposed rule changes. Nothing is in effect yet.
-International Student Services are continuing to operate as normal. -There is a chance that this rule may not go into effect.
The Trump administration has previously tried to attach fees to H-1B visas, but this proposed change was thrown out by the courts. Students United will continue to monitor the situation. We encourage students to submit their own comment on this proposed rule change at Regulations.Gov. The comment period closes on November 9, 2026. Students can submit comment anonymously, and do not need to attach their name or contact information in order to submit comment.
Since 1967, Students United has been the sole advocacy body for the students attending the
seven Minnesota State Universities. Students United works to support students, advocate for their needs at the Minnesota State systems office, Minnesota Legislature, and the United States Federal Government. Students and staff have brought the recent proposed rule changes from the DHS to our attention.
As the sole advocacy body for Minnesota State University students, we are submitting comment regarding the concerning proposed rule change ICEB-2026-0100 from the Department of Homeland Security (DHS) This proposed rule change will create immense, burdensome fees in order to participate in Optional Practical Training (OPT). Students United is opposed to this proposal.
When speaking on this proposal, DHS insisted that this proposal will limit “fraud” in OPT.
Students United believes that fraud and abuse cannot continue in our programs. We’ve been
committed to rooting out fraudulent “ghost students” within the Minnesota State University
System and have worked closely with our allies to ensure critical funding programs are not being taken advantage of by fraudsters.
However, DHS must find a way to eliminate fraud while maintaining the integrity of the 34
year-old OPT program. The Minnesota State University system and its schools are unable to afford the $70,000 per student fee and would certainly slide these costs onto students. By pursuing this course of action, DHS is on track to effectively end the OPT programs for all but an increasingly small handful of international students.
Additionally, DHS cites this move as further protection for American workers. The reality is this: our international student populations are huge economic drivers, not only in Minnesota but across the United States. F-1 and J-1 visa students contributed nearly $43.8 billion to the U.S. economy and supported more than 378,000 jobs in the 2023-2024 academic year. In Minnesota alone, of the 14,975 international students we host, that number is 488 million, with an estimated 3,430 jobs supported by their presence on our campus and in our communities.
Compare the 300,000 jobs created to the more than 194,000 students on OPT, it’s difficult to believe that this relatively small group of students creates any meaningful competition with American workers.
Since World War II, sharing academic knowledge across the globe has been a key part of our
economic and technological advancements as a country. We
rely on international students, as we rely on many international workers, to provide support and input in fields we have yet to lead.
Artificial Intelligence is a key example, where America is quickly being outpaced by countries
like China. Our universities are seen as opportunity for cross-cultural learning and innovation,
thanks in no small part to our international students.
International students serve as valued members of their communities, who deserve the
opportunity to serve their communities and gain the valuable skills they need to enter the global workforce. We encourage DHS to find rational solutions to the issues it is seeking to address without putting incredible, burdensome costs on the backs of our institutions and students.


