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What the Proposed End of "Duration of Status" (D/S) Really Means for International Students

  • 2 days ago
  • 5 min read

Updated: 22 hours ago

There has been a lot of confusion—and frankly, misinformation—circulating about the proposed U.S. rule to end “Duration of Status” (D/S), especially when it comes to CPT and integral CPT, commonly referred to as “Day 1 CPT” programs.


Let’s break this down in a simple, factual way so you can understand what’s actually changing and what is not.


First: What Is “Duration of Status” (D/S)?

Right now, most F-1 students are admitted to the U.S. under something called Duration of Status (D/S).


This means:

  • You can stay in the U.S. as long as you are maintaining your student status

  • Your stay is tied to your program progress, not a fixed end date


What Is the Proposed Change?

The DHS proposal would replace D/S with a fixed period of stay.


What that means:

  • You would receive a specific end date on your I-94

  • This would typically be:

    • Your program end date

    • Up to a maximum of 4 years

    • Plus a 30-day grace period (reduced from 60 days)


If you need more time, you would have to:

  • Apply for an extension through USCIS (Form I-539)

  • Pay additional fees

  • Potentially provide biometrics or attend an interview


Bottom line: Your stay becomes more structured and less flexible.



Important: This Rule Is Still NOT Final


While the final rule has not yet been published, universities and international offices across the United States are actively reviewing the anticipated changes and preparing for possible

operational impacts.

  • Publication of the final rule is anticipated in the near future, though the exact date has not yet been announced.

  • The rule is expected to become effective 60 days after publication in the Federal Register.


So for now, nothing has changed.



Let’s Address the Biggest Misconception: “Day 1 CPT Is Ending”

This is where a lot of misinformation is spreading.


Here is the truth:

The proposed rule does NOT change CPT regulations.


What this means:

  • Programs that legitimately require practical training from the start can still offer CPT

  • “Day 1 CPT” (when academically justified) still exists under current rules


The proposal does NOT eliminate CPT


So, Why Are People Saying CPT Will Be Affected?

Because while CPT itself is not changing, the student strategy will be affected.

The biggest shift is this:


You may NOT be able to do a second degree at the same level

Under the proposal:

  • Students would be prohibited from enrolling in another program at the same educational level

  • Example:

    • Master’s → another Master’s ❌ (not allowed)

    • Master’s → Doctoral ✅ (allowed)

This is a major change.


Why This Matters for CPT Students

Many students currently use a strategy like this:

  1. Complete a degree

  2. Enroll in another program (often same level)

  3. Continue gaining work experience through CPT


Under the proposed rule:

  • That pathway could be restricted or eliminated

  • Not because of CPT itself—but because of limits on academic progression


So the impact is on strategy, not the CPT regulation


Key Changes with the Proposed End of Duration Status (D/S)

  1. Replacing D/S with a Fixed Admission Period

At a glance

Instead of staying in the U.S. as long as you maintain your student status, you would receive a fixed end date, typically:

  • Your program end date

  • Up to a maximum of 4 years

  • Plus a 30-day grace period

Any additional time would require a formal application with USCIS.


What this means for you

  • Your stay becomes less flexible

  • You must track deadlines carefully

  • Extensions are no longer automatic through your school

  1. Extension of Stay (Form I-539 Requirement)

At a glance

Students who need more time must:


This replaces the current system, where schools can handle many extensions internally.


What this means for you

  • More costs and processing time

  • More government involvement in your academic timeline

  • Greater importance of planning ahead

  1. Shorter Grace Period

At a glance

The grace period after completing your program would be reduced from:

  • 60 days → 30 days 


What this means for you

  • Less time to:

    • Apply for OPT

    • Transfer schools

    • Change status

  1. Restrictions on Program Changes and Transfers

At a glance

The rule proposes:

  • Limits on changing majors or programs

  • Restrictions on transferring schools, especially early in your program

  • Graduate students may not be allowed to change programs at all 


What this means for you

  • You must be more certain about your academic path upfront

  • Changing direction may become difficult or restricted

  1. No Second Degree at the Same Level

At a glance

Students would be prohibited from pursuing another degree at the same or lower level after completing one.


What this means for you

  • Example:

    • Master’s → another Master’s ❌

    • Master’s → Doctoral ✅

  • This directly impacts long-term planning strategies

  1. ESL (English Language Programs) Limits

At a glance

English language study may be limited to:

  • 24 months total, plus a 30-day grace period


What this means for you

  • Less flexibility for extended English study

  • More pressure to progress into degree programs

  1. Increased Risk if Extensions Are Denied

At a glance

If your extension is denied:

  • Your status may end immediately

  • There may be no grace period


What this means for you

  • Higher risk if applications are delayed or denied

  • Greater importance of submitting accurate and timely applications


What Should International Students Do Now?

If you’re planning your education and career in the U.S., this is a moment to be strategic—not reactive.


For now, students should:

• continue their academic plans as scheduled

• remain attentive to official communications from HMS and their university

• avoid relying on speculation or unofficial social media information

• reach out with questions if they have concerns about their individual situation


We recognize that uncertainty around immigration policy can be stressful. HMS remains

committed to providing timely updates, clear communication, and practical guidance as

more information becomes available.


Check back regularly as we will continue sharing updates as soon as official guidance is released.


FAQ: What International Students Need to Know


1. Is this rule already in effect?

No. This is a proposed rule and has not been finalized. If implemented, it would take effect after a final rule is published.

2. Will this affect my current status immediately?

Not right now. If finalized, the rule would apply based on the implementation details—typically impacting future admissions, extensions, and status changes.

3. Is CPT or “Day 1 CPT” being eliminated?

No. CPT regulations are not being changed.


Programs that require practical training as part of the curriculum can still authorize CPT, including from the first day if academically justified.

4. Why are people saying “Day 1 CPT” is going away?

Because the strategy students use may change.


The proposal restricts pursuing a second degree at the same level, which many students currently use to continue CPT.

5. Can I still do another degree after I graduate?

Students would be able to pursue another degree as long as it is an academic progression.

  • Same level (e.g., Master’s → Master’s): ❌ Not allowed

  • Higher level (e.g., Master’s → Doctoral): ✅ Allowed

6. What happens if I need more time to finish my program?

You would need to:

This replaces the simpler school-based extension process.

7. How long can I stay in the U.S. under the new rule?

You would receive a fixed end date, typically:

  • Your program length (up to 4 years max)

  • Plus a 30-day grace period

8. Why is the grace period being reduced?

The proposal reduces it from 60 days to 30 days, meaning less time to:

  • Apply for OPT

  • Transfer schools

  • Change status

9. Will it be harder to transfer schools or change programs?

Yes, potentially. The proposal includes:

  • Restrictions on transfers (especially early in your program)

  • Limits or restrictions on program changes

10. What happens if my extension is denied?

Your status could end immediately, and there may be no grace period. This makes timely and accurate applications critical.

11. Are English language (ESL) students affected?

Yes. ESL study may be limited to:

  • 24 months total, plus a 30-day grace period


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