PROGRAM OPERATIONS MANUAL SYSTEMPart RM – Records MaintenanceChapter 102 – The Social Security Number, Policy and General ProceduresSubchapter 11 – Alien Evidence for an SSNTransmittal No. 84, 08/12/2025
Audience
Originating Component
OISP
Effective Date
Upon Receipt
Background
This transmittal adds additional acceptable signature methods for Form I-20.
Summary of Changes
RM 10211.255 Evidence of Curricular Practical Training (CPT) for an F-1 (Foreign Student) for an SSN Card
Inserted Citation for the corresponding Code of Federal Regulations.
Subsection A
Updated section to list the various acceptable signature methods.
Subsection B
Modified subsection by restructuring sentences.
Made minor grammatical changes.
Citations: 20 C.F.R. §§ 422.105, 422.107; 8 C.F.R. 214.3(k)
F-1 students participating in CPT must submit Form I-20 (Certificate of Eligibility for Nonimmigrant Student Status) which includes the evidence of nonimmigrant status, per RM 10211.135, and evidence of employment status.
Accept the Designated School Official’s (DSO) annotations on page 2 (employment page) of the Form I-20 as evidence of employment status.
Page 1 of the Form I-20 must have the DSO's signature and date. DHS has deemed acceptable the following methods that the DSO can choose for signing and sending Form I-20 to F-1 students (students must print emailed Form I-20s prior to visiting their field office or social security card center):
Email Form I-20 that contains a digitally reproduced copy of a physical signature (e.g., a scanned image of a physical (original) signature); or
Email a digitally signed Form I-20 with an electronic signature produced with software programs or applications (e.g., Adobe); or
Provide a physically signed Form I-20.
Page 2 of the Form I-20 must show all of the following employment information:
whether CPT is full-time or part-time;
employer name and location; and
employment start and end dates (employment start date can be 30 days before the start of classes).
Sometimes the DSO completes page 2 of the Form I-20 to show approval for Optional Practical Training (OPT). Please ensure the annotation specifies CPT.
NOTE:
An F-3 (Border Commuter Student) may not have authorization to accept any employment in connection with their foreign student status, except for CPT. Please follow the same policy and procedure for an F-3 student as you would for a F-1 student participating in CPT.
CPT is an alternative work/study, internship, cooperative education, or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school. CPT must be an integral part of an established curriculum and may occur on or off campus.
For example, participation in cooperative education and working for university-approved off-campus employers is a degree requirement for many students at Drexel University in Philadelphia.
The Social Security Administration (SSA) does not require an Employment Authorization Document (EAD, I-766) from the Department of Homeland Security (DHS), and instead requires the school’s DSO's documentation of CPT on page 2 of the student’s Form I-20. The DSO’s completion of page 2 of the Form I-20 with employment information is evidence that the F-1 student meets academic requirements and authorized for CPT. When establishing CPT work authorization, F-1 students do not need to provide a DSO letter, pay stub, or other evidence of employment status as described in RM 10211.270.
Do not accept page 2 as evidence of CPT for English-language program students because English-language-program students are ineligible for CPT.
RM 10211.275 Reviewing the Student and Exchange Visitor Information System (SEVIS) and Form I-20 (Certificate of Eligibility for Nonimmigrant Student Status)