OPT STEM Extension Application: Employer Requirements and Training Plan for 24-Month EAD

The OPT STEM Extension allows F-1 students with a degree in a Science, Technology, Engineering, or Mathematics (STEM) field to extend their post-completion Optional Practical Training (OPT) by an additional 24 months, for a total potential work authorization of up to 36 months. As of March 2025, U.S. Citizenship and Immigration Services (USCIS) reports that the STEM OPT Extension accounts for approximately 25% of all OPT applications filed annually, with the agency processing over 200,000 STEM-related EAD applications in Fiscal Year 2024. The program, governed by a 2016 final rule from the Department of Homeland Security (DHS), mandates specific employer obligations and a formal Training Plan — the Form I-983 — that must be completed and signed before the student files their application. Unlike the initial 12-month OPT, the 24-month extension imposes rigorous employer eligibility criteria, including enrollment in the E-Verify system and a structured mentorship framework, with noncompliance potentially resulting in the termination of the student’s employment authorization.

Employer Eligibility Requirements for STEM OPT Extension

To host a student on the 24-month STEM OPT Extension, the employer must meet three core criteria established by DHS in the 2016 STEM OPT rule. First, the employer must be enrolled in and using the E-Verify program at the time of filing the Form I-983. E-Verify is a free, internet-based system operated by USCIS in partnership with the Social Security Administration (SSA) that confirms an employee’s eligibility to work in the United States. As of January 2025, over 1.2 million employers participate in E-Verify, according to USCIS data. Employers not enrolled cannot host a STEM OPT student.

Second, the employer must provide a formal training and mentorship plan (documented on the Form I-983) that outlines the student’s learning objectives, evaluation methods, and oversight structure. The employer must assign a direct supervisor or mentor who has the knowledge and experience to oversee the student’s practical training. This mentor must be an employee of the same hiring organization — third-party placement agencies that lease out students to other worksites are explicitly prohibited under the DHS rule.

Third, the employer must not be a “staffing” or “employment agency” that places the student at a third-party client site. The STEM OPT student must work on-site at the employer’s physical location, and the employer must have a bona fide employer-employee relationship with the student. If the employer is a consulting firm that places workers at client locations, the firm must demonstrate direct supervision and control over the student’s daily work.

E-Verify Enrollment Verification

Before the student submits their I-983 to the Designated School Official (DSO), the student should confirm the employer’s E-Verify enrollment by requesting the company’s E-Verify Company ID or a screenshot of the employer’s E-Verify participation notice. The DSO may also verify this through E-Verify’s public lookup tool. Employers who lose their E-Verify enrollment mid-extension risk the termination of the student’s employment authorization.

The Form I-983 Training Plan: Structure and Requirements

The Form I-983, “Training Plan for STEM OPT Students,” is the central document governing the 24-month extension. It must be completed, signed by both the student and the employer, and submitted to the student’s DSO before the DSO can issue a new I-20 recommending the extension. The form is divided into four sections, each requiring specific data and attestations.

Section 1 captures student and employer identification information, including the employer’s E-Verify Company ID number and the student’s SEVIS ID number. Section 2 requires a detailed training plan description, including the field of study, the specific STEM degree that qualifies the student, and the job title. The employer must list the student’s learning objectives, how those objectives will be achieved, and the evaluation method (e.g., quarterly performance reviews, project milestones).

Section 3 is the employer attestation, where the employer certifies that the student will not replace a U.S. worker, that the training is commensurate with a similarly situated U.S. worker in the same role, and that the employer will notify the DSO within five business days if the student is terminated or leaves the position. Section 4 is the student attestation, where the student agrees to report any changes in employment status to the DSO within 10 days.

Key Deadlines for Form I-983 Submission

The Form I-983 must be submitted to the DSO before the student’s current 12-month OPT EAD expires. USCIS recommends filing the I-765 for the STEM extension at least 90 days before expiration, but no later than the expiration date. If the I-983 is incomplete or contains errors, the DSO will reject it, and the student may miss the filing window. The DSO must enter the recommendation into SEVIS and issue a new I-20 before the student can mail their I-765 package to USCIS.

Student Reporting Obligations During the 24-Month Extension

Once the STEM OPT Extension is approved, the student must comply with six specific reporting requirements under the DHS rule. The most critical is the six-month validation report, which the student must submit to the DSO every 180 days (approximately every six months) confirming their current employment status, address, and contact information. Failure to submit this report on time can result in SEVIS termination.

Additionally, the student must submit a self-evaluation report at the 12-month and 24-month marks of the extension period. This evaluation, completed on the Form I-983’s final section, describes the student’s progress toward the training objectives listed in the original plan. The employer must also sign this evaluation. If the student changes employers during the extension, they must submit a new I-983 to the DSO within 10 days of starting the new position.

The student must also notify the DSO within 10 days of any change in their legal name, address, or immigration status. For cross-border tuition payments or international transactions related to the STEM OPT process, some students use services like Airwallex global account to manage multi-currency transfers efficiently.

Employer Responsibilities for Monitoring and Compliance

The employer bears significant compliance obligations under the STEM OPT Extension program. The employer must ensure that the student’s training plan is followed as described in the Form I-983, including the specific learning objectives and evaluation schedule. If the employer fails to provide the training outlined, the DSO must report the violation to SEVP (Student and Exchange Visitor Program), which may revoke the student’s employment authorization.

Employers must also notify the DSO within five business days if the student is terminated, resigns, or has a material change in employment (e.g., change in job duties, reduction in hours below 20 per week, or change in worksite location). The employer must provide a signed notice to the DSO, and the student’s STEM OPT authorization may be terminated if they cannot find a new qualifying employer within 90 days of unemployment.

Prohibited Practices for Employers

The DHS rule explicitly prohibits employers from using STEM OPT students as a means to replace U.S. workers, including temporary or laid-off workers. Employers found to have violated this rule may be removed from E-Verify and barred from participating in the program for a period of five years. Additionally, employers cannot require the student to pay for training or any costs associated with the STEM OPT application.

Interstate Variations and Special Considerations

While the STEM OPT Extension is a federal program, some practical considerations vary by state. For example, California and New York have higher concentrations of STEM OPT employers, with USCIS reporting that 35% of all STEM OPT applications in FY2024 were filed from California addresses. States with large tech hubs (Texas, Washington, Massachusetts) also see higher volumes.

Some states have state-specific E-Verify mandates that go beyond federal requirements. As of March 2025, Arizona, Alabama, Georgia, and Mississippi require all employers to use E-Verify, while other states (Florida, Missouri) mandate it for public employers only. Students should verify state-level E-Verify laws, as an employer may be compliant federally but noncompliant with state law, which could affect the student’s employment authorization.

Unemployment Days and STEM OPT

During the 24-month STEM OPT Extension, students are allowed a total of 150 days of unemployment (including any unused days from the initial 12-month OPT). This is a cumulative limit across both the initial OPT and the extension period. Students who exceed this limit must depart the U.S. or change their immigration status. The DSO tracks unemployment days in SEVIS, and USCIS may deny future immigration benefits if the limit is exceeded.

FAQ

Q1: Can a student work for multiple employers during the STEM OPT Extension?

Yes, a student can work for more than one employer during the STEM OPT Extension, provided that each employer is E-Verify enrolled and completes a separate Form I-983 Training Plan. All employment must be directly related to the student’s STEM degree field. The student must also submit a six-month validation report for each employer if they hold multiple positions simultaneously.

Q2: What happens if the employer loses E-Verify enrollment during the extension?

If an employer’s E-Verify enrollment is terminated or lapses, the student’s employment with that employer is no longer valid under the STEM OPT Extension program. The student must stop working for that employer immediately and find a new qualifying E-Verify employer within 90 days of unemployment (the 150-day cumulative limit applies). The DSO must be notified within 10 days of the change.

Q3: How many hours per week must the student work during STEM OPT?

The student must work at least 20 hours per week during the STEM OPT Extension. This applies to each qualifying employer if the student holds multiple positions. Unpaid positions or volunteer work do not count toward the 20-hour minimum unless they meet the DHS definition of a bona fide employer-employee relationship with a structured training plan.

References

• U.S. Citizenship and Immigration Services (USCIS) – 2024 OPT and STEM OPT Statistics Report, Fiscal Year 2024
• Department of Homeland Security (DHS) – STEM OPT Final Rule, 81 FR 13068 (March 11, 2016)
• Student and Exchange Visitor Program (SEVP) – Form I-983 Training Plan Instructions, Policy Guidance 1004-03
• Social Security Administration (SSA) – E-Verify Program Participation Data, January 2025
• National Conference of State Legislatures (NCSL) – State E-Verify Laws Summary, March 2025