International students at Luther College are facing tighter limits on off-campus internships after a federal memo directed colleges to restrict internship authorization unless the experience is directly required for graduation. The change could affect more than 200 students from more than 70 countries who use internships and other experiential learning opportunities to prepare for graduate school and employment.

The memo, dated Aug. 24, says the Student and Exchange Visitor Program, part of Immigration and Customs Enforcement, has “observed a rise in Curricular Practical Training (CPT) ⁠authorizations that appear ⁠to violate regulatory requirements which permit CPT only where the training is an integral part ​of an established curriculum.”

Under the guidance, an international student generally cannot complete an off-campus internship unless it is a direct graduation requirement for the student’s major. The memo also warns that “failure to comply with SEVP regulations may result in an institution losing certification to enroll foreign students.”

The guidance does not halt all degree-related activity. The source report says degree requirements will continue to be processed normally, including dissertations and master’s thesis research conducted under CPT.

Students worry about experience and future opportunities

For students seeking internships, the change reaches beyond whether they are paid. Joaquin Ocaña, a Luther student in the class of 2028, was looking for an internship when he learned about the new guidance.

“Absolutely, that was more important for me than the money itself. With no experience I can’t get into good grad school programs or any real competent work.”

Ocaña said many international students had counted on internships both to meet graduation-related experiential learning expectations and to build résumés for graduate school and future employment.

“Experience is everything in today’s market. They took that opportunity away with the sole purpose of preventing international students from coming to the country,” Ocaña said.

Gerardo Ramirez Mainou, also a member of the class of 2028, said international students already face barriers that domestic students may not encounter.

“I don’t think I have the same opportunities as domestic students,” Ramirez Mainou said.

He said finding an engineering internship was already difficult because many companies work in the defense sector, where citizenship is required. He added:

“Reaching graduate school with no experience could really set me behind my peers, making other countries seem like better options.”

What Luther says students can still do

Luther’s Center for Global Learning is working with affected students and explaining how the new rules apply. Assistant Director of International Education Alejandra Cruz said the guidance limits CPT to experiences built into the curriculum, required for degree completion and supported by a formal employer agreement.

“That is, receiving academic credit for an internship does not qualify for CPT unless the experience is a graduation requirement that cannot be fulfilled in any other way.”

Cruz said paid and unpaid internships or practicums remain possible when they are specific graduation requirements for every student in the major. She cited elementary education as an example because student teaching is required to earn a bachelor’s degree in elementary education.

Other options identified by the Center for Global Learning include completing an internship while physically living outside the United States. Students may also meet Luther’s EXPL, or Experiential Learning, requirement through EXPL-designated courses, on-campus research and study abroad.

“The Provost’s Office is planning a meeting to communicate with students impacted by the change. The Center for Global Learning is working closely with our international students to help them understand the new guidance and remain in compliance with federal regulations,” Cruz said.

The Provost’s Office and the Center for Global Learning are scheduled to hold a meeting for affected students on Tuesday, Oct. 13, from 9:30 to 11 a.m. in Valders 206. Additional meetings are planned with faculty department heads and Luther College staff.

The report notes that the article was revised after an earlier version published Oct. 1. The revision was made for clarity and length and to correct an inaccurate characterization of how Luther is applying the new federal internship guidelines.