Frequently Asked Questions: “Fixed Period of Admission” Rule”

Students, faculty, postdocs, scholars and staff can seek further assistance with these or other questions as follows:

• Submit questions via email to iss@pnw.edu if you are:
  • A current Purdue student
  • An incoming degree-seeking student
  • A Purdue alumni pursuing post-completion benefits such as OPT
  • Faculty, staff or others concerned about Purdue students or graduate alumni
• Email studyaway@pnw.edu if your DS-2019 shows the following categories:
  • Student Non-Degree
  • Short-Term Scholar
  • Specialist
  • “Student Intern” (J-1 Visiting Undergraduate Student)
  • Professor
  • Research Scholar
• Email studyaway@pnw.edu if you are concerned or have questions about:
  • Your J-1 postdoc or staff
  • J-1 Visiting Faculty
  • Your J-1 visiting scholar or visiting undergraduate student

The first time you return to the U.S. and clear a Port of Entry after the new rule takes effect (Sept. 15), U.S. Customs and Border Protection (CBP) will issue you a new electronic Form I-94 displaying a date-specific expiration.

This date will match your current Form I-20, or DS-2019 expected program end date, or four years from this port of entry date (whichever is shorter).

It will also include a 30-day post-completion grace period.

You must check the official CBP I-94/I-95 portal within 24 hours of every entry to retrieve and review your electronic Form I-94.

If the “Admit Until Date” (AUD) does not align with your I-20 or DS-2019 timeline (plus the 30-day grace period), contact ISS immediately to request a CBP Deferred Inspection correction.

Leaving an incorrect AUD uncorrected on your I-94 could cause you to automatically accrue severe unlawful presence penalties.

No. Because mid-program changes and transfers are strictly banned for graduate students under this rule, you cannot utilize travel to “reset” or alter your major field of study.

Any formal change to your numeric CIP code or degree objective is prohibited from within the U.S. or upon reentry unless you receive DHS approval.

Under the new rule, if you enter the U.S. on or after September 15, 2026, the U.S. Customs and Border Protection (CBP) will assign you a strict, hard calendar date known as a Fixed Period of Admission.

Your authorized period of stay in the U.S. will be capped at either your academic program length (as listed on your Form I-20 or DS-2019) or a maximum of four (4) years, whichever is shorter.

If your program is likely to exceed the four-year cap, you will be required to execute a multi-step extension process.

• First, you must request an updated I-20 or DS-2019 from ISS recommending an extension.
• Second, you must file a formal Form I-539 Application to Extend Nonimmigrant Status (EOS) directly with USCIS and pay the required government filing fee. Your Fixed Period of Admission is not legally extended until USCIS formally approves this application. However, you are permitted to remain in the U.S. so long as your Form I-539 application is pending with USCIS.

The new rule imposes absolute limits based on your educational objectives to ensure you adhere to the specific “educational objective” for which your visa was issued:

• Undergraduate students (Bachelor’s level): You face a first-year curricular lock. You are prohibited from changing your major field of study, altering your core educational objectives, or transferring your SEVIS record to another U.S. institution during your first full academic year (initial two full semesters; summer semesters do not count). Exceptions are extremely rare and require formal review by DHS.
• Graduate and professional students (master’s, professional, PhD): You are legally locked into your specific objectives for the entire duration of your program. You are strictly prohibited from changing majors, changing specific academic programs, or transferring to another U.S. institution mid-program at any point during your studies unless you receive DHS approval.

There is a six-month transition period. If your current I-94 document indicates “D/S”, you must apply the Manual Calculation Rule. This means the federal government considers you to have a Fixed Period of Stay: your legal status will expire exactly 30 days after the program end date listed on your current Form I-20 or DS-2019 or four years from the effective date of the rule (plus 30 days), whichever is less, regardless of what text is printed on your I-94 record.

Your I-20 or DS-2019 is the definitive clock regulating your authorized period of stay.

Maintaining your status is your personal responsibility; you should monitor your program’s end date every semester. If you have a compelling academic or documented medical reason for a delay, your next step is to navigate the 180/30 Day Processing Pipeline:

• As early as 180 Days and Not Less Than 30 Days before your program end date: submit your completed Program Extension Form signed by your academic advisor to the ISS office, including updated evidence of financial support.
• 30 Days before your fixed period of admission expires: This is the absolute final cutoff deadline. ISS requires sufficient time for review and processing. Requests submitted less than 30 days before your program end date risk being denied, causing your SEVIS record to lock.
• Note: Requests submitted to ISS for a program extension cannot happen on or after your program end date, nor can requests be authorized during your post-completion grace period.

No. The new regulation introduces a strict ban on lateral and downward academic movements. F-1 and J-1 students are prohibited from pursuing a subsequent academic program at the same or a lower educational level than one they have already completed in the U.S. (e.g., you cannot earn a second master’s degree, nor is it permitted to change from a PhD track to “master out” without severe status implications).

However, upward, vertical progression (e.g., bachelor’s to master’s, or master’s to PhD) remains supported, provided you secure a new level-appropriate I-20/DS-2019 and file a timely Form I-539 EOS with USCIS or exit the U.S. and re-enter.

For F-1 students, the post-completion grace period is shortened from 60 days to 30 days, matching the J-1 timeline.

Critical compliance information:

1. Grace period restrictions: The 30-day grace period is strictly a departure preparation window. During this period, taking degree-seeking classes, working on campus, or engaging in any off-campus CPT, OPT, or AT is not permitted.
2. Employment authorizations: All on-campus employment and CPT authorizations naturally terminate on your program end date. CPT, OPT, or AT work can only begin when you possess the physical authorization document (I-20, EAD card, or updated DS-2019 letter with the accompanying AT letter) and the approved start date has arrived. Any work occurring outside the permitted dates is considered unauthorized employment and can lead to immediate SEVIS termination and the loss of all legal grace periods and other benefits.
3. USCIS denial risks: If you timely file a Form I-539 EOS with USCIS and it is subsequently denied after your fixed period of admission has passed, there is no grace period. You instantly begin accruing unlawful presence penalties and should depart the U.S. immediately. Accruing more than 180 days of unlawful presence carries an automatic 3-year bar from reentering the United States; 365 days or more of unlawful presence triggers an automatic 10-year bar.
4. Unlawful presence is a statutory lifetime accumulation under INA § 212(a)(9)(B). The accrual of unlawful presence days is aggregate across an individual’s entire immigration history. Subsequent lawful entries, changes of status, or departures from the United States do not reset or nullify previously accrued days. Rather, any new incidence of unlawful presence will append to the existing historical balance, moving the individual closer to the non-discretionary inadmissibility bars.

Under the new rule, your authorized stay is no longer an open-ended “D/S” status but rather will transition to a fixed period of admission.

Be aware that when you apply for a 12-month Post-Completion OPT, your Form I-765 application only requests employment authorization; it does not automatically extend your lawful stay if your I-94 authorized period of admission has expired or is expiring.

• Transition Period: If your last entry to the U.S. was prior to September 15, 2026, and your most current I-94 record reflects duration of status (D/S) as the “Admit Until Date” (AUD), you are part of the transition group DHS identified in the new rule.  If you submit a complete and timely I-765 application for OPT to USCIS on or before March 18, 2027 (the established 6-month transition period), you do NOT need to file a separate Form I-539. Your timely filed I-765 application acts as a joint request. During this transition period, once approved, your fixed period of admission is automatically extended through your EAD end date plus your grace period when your EAD is approved under employment category C03B if the I-765 is properly and timely filed before March 18, 2027.

If at the time you apply for OPT, your current I-94 record already reflects a fixed period of admission expiration date because it was issued after the new rule took effect, you must file both the complete I-765 application for OPT and an I-539 EOS application to extend your stay in the U.S.

Yes, in almost all cases. Because your previous fixed period of admission was legally tied to the expiration date of your initial 12-month OPT EAD card, that hard calendar deadline is a strict ceiling. To secure the 24-month STEM extension, you must successfully navigate the STEM OPT application process:

1. Obtain a STEM OPT recommendation I-20 from ISS.
2. File your Form I-765 STEM OPT application with USCIS before the end of your 12-month post-completion OPT period.

Simultaneously file a new Form I-539 EOS application to request USCIS to extend your fixed period of admission to your new 24-month STEM OPT Extension dates.

The regulations provide a critical safety buffer, but you must monitor it closely:

• Work Authorization: If you timely file your STEM OPT Form I-765 before your initial OPT EAD expires, your work authorization is automatically extended for up to 180 days while USCIS processes the application.

Legal Stay: If you also timely filed your accompanying Form I-539 EOS, you are permitted to remain physically present in the U.S. during this pending period. However, if USCIS ultimately denies your Form I-539 EOS after your initial EAD date has passed, you receive no grace period. You must cease all employment and depart the U.S. immediately to avoid severe unlawful presence penalties.

Under certain circumstances, you may be eligible to travel and reenter the U.S. while your OPT, STEM OPT and I-539 EOS applications are pending with USCIS.

We advise that you carefully review your situation with an ISS counselor (and in some cases an experienced immigration attorney) prior to confirming any plans to travel outside the U.S. while you have applications pending with USCIS to avoid unnecessary complications or abandoning your USCIS applications.

Traveling always involves some inherent risk of experiencing immigration complications.

Once you successfully complete your authorized period of 12-month Post-Completion OPT or 24-month STEM OPT, you enter your final departure window. Under the new rule, the post-practical training grace period for F-1 students is 30 days from the expiration date listed on your EAD card.

• Note: Just like the standard academic grace period, this window is exclusively for packing and preparing to depart the U.S., transferring your SEVIS record to a higher degree level, or filing a change of status. You are strictly prohibited from performing any work or earning income during these 30 days.

• [ ] Check the clock: Review your current electronic Form I-94 AUD against your expected graduation/EAD end date.
• [ ] Dual filing check: Confirm if you are eligible to submit only the Form I-765 (only legacy D/S I-94 holders who file later than March 18, 2027) or if you must dually file both the I-765 OPT and I-539 EOS applications.
• [ ] Meet the 180/30-day submission deadlines: Submit your OPT/STEM OPT I-20 request to ISS up to 90 days before and not less than 30 days before your program end date or current EAD expiration date. Additionally, submit your complete I-765 OPT and I-539 EOS applications to USCIS by the end of your 30-day grace period.
• [ ] Revisit international travel plans: Consider all international travel plans carefully and discuss with ISS and potentially outside legal counsel while your I-765 OPT and/or I-539 EOS applications are pending with USCIS to prevent automatic abandonment.

No. Under the new rule, graduate and professional students (master’s, professional and PhD) are strictly prohibited from changing their major field of study or specific academic programs once their program has begun.

They are legally locked into the exact educational objective tracked by the original numeric code associated with their program of study.  This code aligns with the National Center for Educational Statistics Classification of Instructional Program (CIP) codes.

While they may take an elective course or two in another department, students cannot use outside coursework to transition into a new degree path or major.

Undergraduate students face a strict, first-year curricular lock. They are generally prohibited from changing their major field of study, altering their core educational objective, or transferring their SEVIS record to another U.S. higher education institution during their first full academic year (initial two full semesters; summer terms do not count toward meeting this requirement).

Please advise them that they must remain registered under their original major code until they complete their first full year and to consult ISS with any questions.

Exceptions are extremely rare and require explicit DHS approval.

Advise with extreme caution. Moving downward from a higher educational tier to a lower tier (such as PhD to master’s) is heavily restricted under the new rule and likely carries severe status implications.

Students seeking to “master out” risk becoming entirely ineligible to apply for post-completion OPT employment benefits. Always direct the student to an ISS advisor before any formal modifications are made to their degree path.

No. The new regulation completely bans lateral or downward academic movements. Once a student completes an educational level in the U.S., they cannot pursue a subsequent or secondary program at that same or a lower level (e.g., earning a second master’s degree after completing an initial masters).

They are only permitted to progress vertically to a higher tier (e.g., master’s to PhD).

If a student’s graduation timeline shifts for any reason, such as a compelling academic or documented medical reason, the student must submit a Program Extension Form signed by their academic advisor to ISS. The form confirms that the student is making normal progress, details the reason for delay and must explicitly define their new expected program end date.

30-Day hard cutoff: ISS requires the completed extension request and your advisor recommendation at least 30 days before the student’s current I-20 or DS-2019 expires. If the window is missed, the student’s SEVIS record will lock, making an extension impossible and placing them out of status. The student may submit their Program Extension Request to ISS as many as 180 days before their current program end date.

Regulations allow extensions only for compelling academic or documented medical reasons. Standard valid reasons include:

• Graduate research bottlenecks: Lab equipment failures, data collection challenges, change in research topic
• Original length of time was insufficient: Recommendations for additional time based on an inadequate original timeframe must be strongly supported by evidence-based data. Submissions must include documentation and objective facts demonstrating why the original duration was insufficient to fulfill the academic requirements of the student’s educational objective.
• Documented medical circumstances: A medical condition interrupting full-time study, which must be backed by official documentation from a licensed medical professional.
• Extenuating circumstances: Some examples include when a school closes or is unable to hold in-person classes for an extended period due to natural disasters or other causes.

Note: Wanting to delay graduation to wait for a better job market, continuing to work an on-campus or off-campus job, or delays due to continuing work on publications that are not required for the completion of the thesis or dissertation are not permissible reasons for an extension.

No. Under federal immigration guidelines, “employment” is defined as any activity performed in exchange for compensation of any kind — including housing, transit passes, or promises of future equity.

Furthermore, onboarding, orientation and technology setup constitute labor. A student may never perform a single day of work or training until they have the physical authorization document in hand and the active start date has arrived. Doing so can result in immediate status termination.

True volunteering is strictly reserved for altruistic, humanitarian, or charitable purposes with recognized non-profit organizations where no commercial employee is displaced.

University policy contains careful language and descriptions of appropriate volunteer opportunities at Purdue and scenarios that are not appropriate for individuals to contribute in a volunteer role.

• [ ] Refer early: Direct students to ISS the moment they are in danger of failing to make normal academic progress or mention changing their major, research focus, or graduation term.
• [ ] Respect the application timeline: Complete the Program Extension form promptly to give ISS sufficient processing time.
• [ ] Check before enrolling: Do not authorize an official academic major or program change with the Office of the Registrar until the student has received formal written clearance from ISS.
• [ ] Enforce the work rule: Ensure no international student begins assisting your department, lab, or project until their active work authorization dates are completely approved. Don’t invite or allow students to volunteer until/unless the opportunity has been properly vetted by ISS, HR and the Policy office.