Camille Faivre is a distinguished authority in higher education management, recognized for her extensive work in helping institutions adapt to the complex, post-pandemic regulatory environment. As schools transition into this new era of 2026, her expertise in the intersection of international student policy and institutional development has become a vital resource for university leaders. With the Department of Homeland Security recently upending decades of established protocol regarding Curricular Practical Training, Faivre provides a nuanced perspective on the legal and practical implications of these shifts. Our discussion explores the current legal battle led by major educational associations, the immediate threats facing university administrators, and the potential erosion of the experiential learning model that has long defined the American college experience for global talent.
Federal guidance now limits Curricular Practical Training to mandatory degree requirements rather than elective credit—how does this shift fundamentally change the landscape for international students seeking professional experience?
This sudden, unexplained reversal by the Department of Homeland Security strikes at the very heart of why international students choose to study in the United States. For decades, the Curricular Practical Training program, or CPT, operated under a stable, two-pathway system: students could engage in internships if the experience was required for their degree, or if they simply received elective academic credit for it. By effectively collapsing these two paths into one, the government has slammed the door on a vast array of vital professional opportunities. Imagine a law student who has the chance to intern for a judge or an art history major who is offered a training program at a prominent museum; under this new interpretation, those students are often left stranded because those specific roles aren’t “mandatory” for every single person in their major. The sensory impact of this change is profound, as the vibrant energy of students returning from off-campus internships is replaced by a clinical, restricted focus on the bare minimum requirements for graduation. We are moving away from a holistic education toward a rigid, check-the-box mentality that ignores the direct relationship between elective training and career readiness.
The Association of American Universities and other groups are alleging that this move was a violation of the Administrative Procedure Act—what makes the lack of a notice-and-comment period so legally and operationally damaging?
The Administrative Procedure Act is designed to prevent exactly this kind of regulatory whiplash, where a longstanding, settled agency interpretation is discarded overnight without any reasoned explanation. By bypassing the notice-and-comment period, the government denied universities, students, and legal experts the opportunity to voice how these changes would disrupt thousands of academic paths and institutional workflows. This isn’t just a procedural technicality; it’s a matter of basic fairness and stability for institutions that have built their entire international recruitment strategies around these established rules. When policy is rewritten behind closed doors and issued as immediate guidance, it leaves no room for the necessary adjustments that colleges must make to their curricula or their advising structures. The lawsuit correctly points out that for decades, the regulatory history has been clear that elective training programs receiving academic credit qualify for CPT, and to change that without public discourse feels like a betrayal of the trust between federal agencies and the higher education sector.
With institutions like Columbia University, Michigan State University, and Tufts University already narrowing their CPT authorizations, how are campus officials balancing their commitment to student success against the threat of federal sanctions?
The atmosphere in international student offices right now is one of high-stakes caution, bordering on fear, because the penalties for non-compliance are existential. We are seeing a strategic retreat from prestigious schools like Columbia and Michigan State not because they agree with the policy, but because they have no choice when faced with the “death penalty” of losing their ability to enroll international students altogether. It is a heartbreaking reality for an administrator to have to tell a bright, ambitious student that they cannot accept a dream internship because the school cannot risk its federal standing. Furthermore, there is a chilling personal element here, as college officials who oversee these programs now face the specter of personal criminal liability if they are found to be out of compliance with this new, narrower interpretation. This pressure creates a defensive posture where schools must prioritize legal self-preservation over the innovative, hands-on learning experiences that have historically made American higher education the gold standard for the world.
What is your forecast for the future of the CPT program and the broader impact on American higher education’s ability to attract global talent?
I believe the legal challenge brought by the Association of American Universities and the Presidents’ Alliance on Higher Education and Immigration will eventually force a return to a more flexible interpretation, but the damage to our reputation may take longer to heal. My forecast is that if this restrictive guidance remains in place, we will see a measurable shift in international enrollment as students look toward countries that offer more seamless pathways between the classroom and the professional world. The viability of the CPT program is linked directly to our competitiveness; if we tell the world’s best and brightest that they can study here but cannot practice their craft in a museum, a courtroom, or a lab unless it is a mandatory chore, they will take their talents elsewhere. For the reader, the takeaway is clear: the strength of our universities has always been the integration of theory and practice, and any policy that severs that connection threatens the long-term vibrancy of our entire academic ecosystem.
