The Degree Nobody Finishes

Curricular Practical Training is the rule that lets a foreign student on an F-1 visa work off campus. The default version is unremarkable. A student enrolls, studies full time for one academic year, and only then becomes eligible to work in a job connected to the coursework.

Then comes the exception, at 8 CFR 214.2(f)(10)(i):

Congress never voted on that sentence. It is regulatory text, and it was written for programs where the placement is the instruction, like a co-op engineering degree or a clinical residency.

The load-bearing word is require. Not offer. Not recommend. Require. A school that writes a mandatory practicum into every semester of a graduate program has manufactured Day 1 work eligibility for every student it admits. The curriculum requires employment, so the employment is curricular. This is what the industry calls Day 1 CPT.

You do not have to take our word for how it works. The University of the Cumberlands publishes it on its own website:

That is the regulation's language mapped onto a product. The work is declared integral, so it is curricular, so it starts on day one.

Trine University goes further and cites the regulation by number. From its own page describing what it calls the Experiential Learning Track:

The school named the statutory subsection this article is about, in its own admissions material, as a selling point. It also documents a route in from another visa: students already on an H-1B cannot access the CPT application "until your Change of Visa Status request has been processed."

Nobody in the federal government approves it

Here is the part that gets missed. A CPT authorization is not adjudicated by U.S. Citizenship and Immigration Services. It is entered into the SEVIS database by a Designated School Official, an employee of the school, and printed on page two of the student's I-20.

There is no I-765 application. No Employment Authorization Document. No filing fee. No prevailing wage. No annual cap. No lottery. For comparison, an H-1B hire requires a Labor Condition Application filed at prevailing wage, a registration in a lottery capped at 85,000 slots a year, an I-129 petition, filing fees, months of federal adjudication, and a cap of 85,000 slots.

One path runs through a federal agency. The other runs through a school employee down the hall from the admissions office. The institution that grants the work permit is the same institution selling the degree that pays for it.

One agency has acknowledged the exception in writing, and it is worth knowing exactly where. The USCIS Policy Manual carries it in a footnote: "Students enrolled in master's degree or doctorate programs that require immediate participation in CPT are exempt from the one-academic-year eligibility rule." The chapter's own bulleted eligibility list states the one-year requirement with no qualification at all. The exemption lives only in the footnote, and USCIS has never said what "require immediate participation" means.

Acknowledging that a regulation contains an exception is not the same as approving a program. No school is certified, no curriculum is reviewed, and no federal officer ever reads the justification.

We went looking for graduate completion rates across every school named in Bloomberg's October 2024 investigation of Day 1 CPT. They are not published, and not because the schools are hiding them.

The federal government does not collect graduate program completion rates at all. The Department of Education's IPEDS system has two components that measure whether students finish, the Graduation Rate component and Outcome Measures. Both track first-time, full-time undergraduate cohorts only. There is no federal equivalent for a master's or doctoral program anywhere in the system. A university can enroll 9,000 graduate students and graduate almost none of them without ever filing a number that would show it.

A handful of states close that gap. California requires private postsecondary institutions under its Bureau for Private Postsecondary Education to file an annual report disclosing, for every individual program, how many students began, how many graduated on time, the completion rate, the placement rate, and the total price. Wisconsin publishes per-program completion through the doctoral level. Tennessee publishes completion and in-field placement, and calculates the rates itself from student-level records instead of accepting school aggregates.

Of the six schools Bloomberg named, exactly one sits in a state that publishes this. Westcliff is in Irvine.

There is a wrinkle that matters. California exempts WSCUC-accredited institutions from BPPE oversight under Education Code 94874(i), and Westcliff is WSCUC-accredited. It files anyway, voluntarily, because state approval is what lets it participate in Cal Grant and sit on California's eligible training provider list. Two other California schools marketed for Day 1 CPT, Humphreys University and Golden Gate University, took the exemption instead. Neither has filed a single per-program completion rate in any year, and no law will ever make them.

So the only reason any of this is visible is that one school traded disclosure for access to state grant money.

Westcliff is a private for-profit in Irvine, founded in 1993 by John Lee Yuhnaut. His son, Anthony M. Lee, took over as president in 2012, when the school was unaccredited and enrolled fewer than 100 students. It is now accredited by WSCUC, the same regional accreditor as Stanford, Berkeley, UCLA, and Caltech. Its own state filings show total enrollment rising from 1,414 in 2017 to 8,076 in 2024.

The split that repeats every year

Westcliff runs most graduate programs in two versions, residential and online. This matters more than it sounds. Federal rules cap how much online coursework counts toward the full course of study an F-1 visa holder must maintain, which means a student on a visa is required to take the residential track. The online track carries no such requirement.

So the two versions of the same degree, at the same school, taught by the same faculty, form a natural experiment. Here is the enrollment-weighted completion rate for Westcliff's graduate programs, residential against online, in every year the state published both. We computed these from the raw filings.

Seven years. Seven times the residential track finished lower. The gap ran as wide as 46 percentage points in 2019.

Now look at where the students went. The residential graduate cohort grew from 181 students in 2018 to 1,507 in 2024, an increase of more than eight times. Across that same stretch its completion rate fell from 7.7% to 5.5%. The school kept selling the version that finished worst, and it sold far more of it every year.

In 2024, 1,507 people started a graduate degree in the track visa students are required to take. Eighty-three finished on schedule.

What that number does and does not mean

Being precise here matters, because the figure California collects is an on-time rate. Under Education Code 94928(c) an on-time graduate is one who completes "within 100 percent of the published program length." A student who takes an extra term is in the denominator and not the numerator. Plenty of students finish late.

So here is the fuller picture. Westcliff awarded 313 residential MBA degrees in 2024 against 644 students who began. On the generous measure, counting every degree the program handed out, the residential MBA completes at roughly 49%, and the online MBA at roughly 79%. Those are real numbers and we are putting them in front of you rather than behind a footnote.

Two things survive that correction, and they are the ones that matter.

The distribution says the same thing. Among California master's programs with a cohort of at least ten students, the median on-time completion rate is 40%. Roughly 12% of programs report below 10%. Westcliff's residential graduate programs sit in that bottom tenth, and they are the largest programs the school runs.

For scale, other institutions filing the same form in the same year: Hult International Business School reports 100% on-time completion for its MBA. Stanbridge University reports 96.9% for a master's in occupational therapy. The Wharton School reports 80.0% for its MBA. Same metric, same regulator, same paperwork.

One program deserves its own section.

Westcliff's Doctor of Business Administration, residential version, in the 2024 reporting year. The school filed these figures with the State of California itself. We pulled them from the raw filing rather than a summary.

Six consecutive years. The cohort grew from 27 students to 375. The completion rate never once reached five percent, and in three of those six years it was exactly zero.

A skeptic should ask whether students simply finish late. For the MBA that objection has real force, which is why we gave you both numbers above. For this program it does not. The 2024 filing reports 375 students beginning and 6 degrees awarded. Counting every doctorate the program handed out that year, the rate is 1.6%. Across all six years it has awarded 46 doctoral degrees in total. There is no late-completion story that rescues this.

Against the California statewide doctoral benchmark of 41.39% on-time, this program reports zero. It costs $56,400.

The California filing includes a field most people never see: total charges for the program. Not annual tuition, the full price of the degree.

We pulled it for every graduate program Westcliff ran in 2024, in both versions. The residential track, the one a student on a visa is required to take, costs more than the online track in every single program. It also completes at a lower rate in every single program.

This is not a quirk of one year. We matched every program Westcliff offered in both versions across all eight filings and found 101 paired prices. Residential cost more in 94 of them. The premium widened over time, from $45 on a 2024 certificate to $30,600 on the 2024 bachelor's in education. Of the 45 pairs where both versions actually enrolled students, 30 show the complete pattern: residential costs more and finishes worse.

Westcliff's residential doctorate carries a $9,600 premium over the identical online degree. The online version graduated 16.2% of its students on time. The residential version graduated none.

One caution, because we checked whether this generalizes and it does not. We pulled the same filings for Sofia University, the Palo Alto for-profit with five undergraduates and 1,140 graduate students. Sofia does not charge a residential premium. In 2018 its residential master's in transpersonal psychology was $7,200 cheaper than the online version. Of Sofia's 13 matched pairs, none shows the Westcliff pattern. The pricing inversion is Westcliff's, and we are not going to pretend it is the whole sector's.

There are smaller charges layered on top. Westcliff's published price sheet for international students carries a $200 I-20 processing fee, a charge for producing the immigration document itself. The same sheet prices an intensive English pathway at $5,200 per course across up to five stackable levels, with entry accepted below a 4.0 IELTS score. A student can be billed five terms of English, up to $26,000, before starting the degree the visa is attached to.

Sofia's filings raise a different question. Every program it labels residential has reported zero students in 2022, 2023, and 2024. In 2023 the sole residential program was filed at a price of $0.00. A school with 1,140 graduate students in federal data, whose students cannot count online coursework toward full-time enrollment, is telling California that nobody is enrolled on the ground. Sofia's own 2024 filing reports 178 total students against the 1,140 in its federal report. The undergraduate counts in the two filings nearly match, at 4 and 5.

Westcliff is the school that has to file. The others do not, so we went at them through federal enrollment data instead. That is where we found something worth its own headline.

Look up Trine University in the Department of Education's College Navigator and you get a small private nonprofit in Angola, Indiana: 4,646 students, 4,373 of them undergraduates, and 273 graduate students. An ordinary regional college.

There is a second Trine. It is registered with the Department of Education as a separate institution, under its own federal ID and its own OPEID, called Trine University-Regional/Non-Traditional Campuses. We verified it directly on NCES. Fall 2024 enrollment:

In Fall 2023 that entity reported 7,786 graduate students, and 7,657 of them were nonresident aliens. Ninety-eight point three percent. Its graduate enrollment went from 130 students in Fall 2014 to 9,123 in Fall 2024, growth of roughly 6,900%.

The pricing tells the rest. A graduate year at Trine University proper costs $47,850. A graduate year at Trine-Regional costs $10,350. Same university name, same accreditation, roughly one quarter the price, thirty-three times the graduate enrollment.

Anyone checking on Trine University sees 273 graduate students. The operation with 9,123 sits behind a different door in the same federal database.

One day a term, or your visa

What does a student at one of these education centers actually attend? Trine answers that in its own December 2020 announcement of the Phoenix center:

That single day is not optional. A separate Trine page on seated-class attendance warns that arriving late, leaving early, or failing to fully participate means being dropped from the course, and that "depending on your situation, this may result in you being considered out of status, and you may be instructed to transfer to another institution or face SEVIS termination." The school permits "only one documented extreme circumstance for the entire academic career," and lists what counts. Traffic does not. A minor cold does not.

So the academic obligation is one weekend day per term, enforced by the threat of losing immigration status.

The recruiter on both sides of the table

Trine publishes its own list of approved international recruitment agencies. For India it names one: Gurukul Overseas Inc., with a named contact, Vishnu Undyala.

Trine's tax filings report paying Gurukul Overseas for "recruitment": $1,172,023 in fiscal 2022, $7,064,198 in fiscal 2023, and $7,957,223 in fiscal 2025. Roughly $16 million to a single agency.

Now read Trine's own press release from the Detroit center's grand opening on September 10, 2024. The photo caption identifies the officials present, and among them is "Vishnu Undyala, director of international graduate student recruitment."

Gurukul Overseas operates from Hyderabad and Warangal. Those are the same two cities where University HUB, the agency Campbellsville paid $35.7 million, lists offices. Its US address in archived captures of its own site is a residential street in Rochester Hills, Michigan, matching the location on Trine's tax return. It recruits for sixteen universities, one of which is Sofia University.

Two numbers Trine puts in its own marketing

Trine advertises a 99.2% placement rate for the class of 2025. Its own footnote gives the denominator: 361 of 452 graduates responding. The university enrolled 13,661 students that year. The placement figure describes the Angola undergraduate class, not the graduate operation that accounts for most of the institution.

The second number is the federal aid. Trine's Title IV volume rose about 16% from fiscal 2021 to fiscal 2024. Its enrollment roughly tripled over the same span, from 5,467 to nearly 15,000. Growth that large against flat federal aid means the new students were, overwhelmingly, people who cannot borrow from the US government.

Fall 2025 brought the first decline, to 13,661. Trine's fiscal 2026 audit records revenue falling about $10 million.

How lopsided these schools get

Once you know to look for the ratio, the shape of the sector is obvious. Federal Fall 2023 data, graduate students as a share of the student body, plus the share of graduate students who are nonresident aliens:

Sofia University, a for-profit in Palo Alto, enrolls five undergraduates and 1,140 graduate students. We confirmed that on the Department of Education's own site. Harrisburg University's graduate division is 97.1% foreign. At Trine-Regional it is 98.3%.

Note also what the control column says. Five of the six schools Bloomberg named are tax-exempt nonprofits. Only Westcliff is a for-profit. The structure doing the work here is not the for-profit sector. It is the graduate division, wherever it happens to sit.

Federal finance data for fiscal 2023 shows what these operations are worth and what they spend it on.

Westcliff's instruction line comes first. It spends 17% of core expenses on instruction and 49% on institutional support, which is administration. Its instructional spending works out to roughly $1,540 per full-time-equivalent student. Harrisburg University spends about $13,550. Westcliff's total revenue grew from $5.5 million in fiscal 2018 to $47.5 million in fiscal 2023, and tuition was between 88% and 97% of it in every single year.

The nonprofit with a 42% margin

The University of the Cumberlands is a tax-exempt institution in Williamsburg, Kentucky, founded by Baptist ministers in 1888. We pulled ten years of its audited financial statements from the Federal Audit Clearinghouse, which is where single audits are filed and where almost nobody looks.

Its net assets went from $151.2 million in fiscal 2016 to $693.3 million in fiscal 2025. That is a $542 million increase at a charity. In fiscal 2021 it booked $196.3 million of revenue against $113.7 million of expenses, an operating margin above 40%. Federal Direct Loan volume flowing through it went up 4.2 times over the decade and Pell 8.4 times.

In fiscal 2025 it spent $55.2 million on instruction and $53.5 million on institutional support. Nearly a dollar of administration for every dollar of teaching. Academic support was $3.3 million, about 6% of the administrative line.

Its president's pay tracked the graduate division rather than the college. Total compensation went from $161,290 in fiscal 2014 to $1,974,823 in fiscal 2025, a twelvefold increase while revenue grew 3.6 times. In fiscal 2014 the president was paid less than the university's own vice president of academic affairs. The single largest jump, from $237,705 to $649,138, landed in fiscal 2018, the same year net tuition revenue rose 64%.

What the graduate money actually buys

The audited statements disclose no marketing agreement, no recruiting agreement, no student-recruiting agent, and no online program manager in any of the ten years. Marketing is not a broken-out expense line. It sits inside institutional support.

The tax returns tell a different story. Cumberlands' largest reported contractors are recruiting and enrollment-marketing firms, and the spending escalates year over year:

EducationDynamics describes itself as an enrollment-marketing firm handling performance marketing, inquiry qualification, enrollment coaching, student retention, and financial aid advising. It claims more than 115,000 enrollments a year across its clients.

Vesta Technology Solutions is the one worth asking about. It billed a Kentucky nonprofit $11.1 million for recruitment in a single fiscal year, and $25,645,527 across six years. It is a Wyoming LLC formed on March 14, 2013 at a Cheyenne registered-agent address, registered in Kentucky a month later as a foreign company, and revoked in October 2020 for failing to file an annual report. Kentucky's filings name its manager: Dr. Eric S. Harter, and after February 2018, Stacey Harter.

The addresses it billed from are the story. Three of the six years list 4017 Fox Meadow Way, Prospect, Kentucky, which is a four-bedroom house. The $11.1 million year lists a suite in Louisville that is sold as a virtual office for $105 a month. The last two years list a suite number in Cheyenne that is a mailbox inside a registered-agent building. None of the three is an office.

$35.7 million to an Indian recruiting agency, filed as "marketing"

Campbellsville University's largest contractor is not a construction firm or a food service company. We pulled its Form 990 contractor tables straight from the IRS bulk filing archive.

From fiscal 2021 through fiscal 2025 it paid $35,759,678 to University HUB Inc. In fiscal 2024 that single vendor took $9,235,523, more than any other contractor of any kind. The reported purpose on the tax return is one word: "Marketing."

University HUB describes itself on its own website as a study-abroad company. Its services include university shortlisting, application assistance, IELTS coaching, visa support, job placement, and a financing arm offering up to 100% tuition assistance. Its listed offices are in Bangalore, Warangal, Hyderabad, and Ameerpet. It names Campbellsville among its partner institutions.

That is a student-recruiting agency paid tens of millions of dollars, disclosed to the IRS as marketing, and absent from the university's audited financial statements.

Two details worth holding next to each other, without drawing a line between them. Ameerpet is the Hyderabad neighborhood where SACSCOC lists an approved University of the Cumberlands instructional site, at Imperial Towers. And in August 2019 Campbellsville conferred an honorary doctorate on a businessman from Hyderabad who, per the university's own announcement, pledged classrooms and offices in the city for Campbellsville programs launching in India in January 2020. Two Kentucky universities, the same neighborhood of the same Indian city.

The trustees on the receiving end

Campbellsville also files Schedule L every year, which discloses business transactions with interested persons. The vendors are owned by its own trustees, and the university names them:

Four of those five owners still sit on Campbellsville's published board of trustees. The same filings list family members of university officers on the payroll, twelve of them in fiscal 2020 and fiscal 2021. In fiscal 2020, five people sharing the surname of the sitting president drew a combined $451,263.

None of this is illegal. Schedule L exists precisely so that it gets disclosed, and Campbellsville disclosed it. It is what the graduate tuition pays for.

There is a broker, and it sells the same product to seven universities

Harrisburg University's audited financial statements describe a "marketing and recruiting agreement with a management company to assist in marketing and recruiting international graduate students." The statements do not name the company in that note. They name it in the debt note, as "Notes Payable – HMS."

HMS is Howell Management Services, of Smithfield, Utah. The disclosed terms:

A university paid one Utah company roughly $75 million over a decade to bring it foreign graduate students, on a contract that paid a percentage of tuition per returning student, and after settling, pays per head per semester.

Now look at what HMS sells. We loaded its website. The page title reads, in full:

That is the supply chain. Not seven schools independently discovering the same regulatory exception, but one vendor selling the same product to seven campuses, with a partnerships page recruiting further agents beneath it. An archived 2016 version of the site described the business as influencing academic partners to create programs that serve international students and generate new revenue streams. National Louis University publicly confirmed its HMS partnership in a December 2024 press release.

Humphreys University is on that list. It is the California school that took the WSCUC exemption and therefore files no per-program completion rate with anyone.

An accreditor flagged this exact structure in 2015

Harrisburg was on accreditation probation from 2014 to 2016. In a November 19, 2015 action, Middle States required the university to document controls ensuring that "independent contractors or agents used by the institution for recruiting purposes are governed by the same principles as institutional admissions officers," that recruiters' "credentials, purposes, and position or affiliation with the institution are clearly specified," and that "inducements or other offerings to agencies or individual persons in exchange for international student enrollment are prohibited."

The same action demanded documentation on "the implementation of the Graduate Curricular Practical Training (CPT) program, including the nature of the program, enrollments, and assessment of the student services and faculty resources necessary to sustain it."

An accreditor named commission-based international recruiting and the graduate CPT program, together, in 2015. It lifted the probation in March 2016. The program then grew for another eight years.

Harrisburg borrowed $150 million after its enrollment peaked

Harrisburg University's fiscal 2023 single audit "identified substantial doubt about this organization's ability to meet its financial obligations and continue operating for the foreseeable future." That is going-concern language, in a federal audit filing.

The balance sheet explains it. Harrisburg's tax-exempt bond debt went from $53.2 million in fiscal 2020 to $150.4 million in fiscal 2021, nearly tripling in one year. Total liabilities now stand at $179.4 million against $202.5 million of assets, a ratio of 89%. Net assets have fallen 52% from their 2021 peak, and the university has lost $20.7 million cumulatively across fiscal 2022 through 2025.

Its graduate enrollment peaked in 2018 at 3,818 students, three years before it took on that debt. The graduate division that was 97% foreign and paying the bills had already started shrinking when the borrowing happened.

The audited statements are blunter than any outside analysis could be. Harrisburg's own concentrations note reports that international students, all of them on F-1 visas, made up between 82.8% and 84.3% of total enrollment in every one of the five academic years from 2020-21 through 2024-25. Undesignated net assets sit at a deficit of negative $11,566,778, and total expendable net assets went from $10.4 million in fiscal 2023 to negative $2.5 million in fiscal 2025.

The Department of Education scores institutions on financial responsibility from negative 1.0 to 3.0, and anything below 1.5 fails. Harrisburg scored 1.3 in fiscal 2023, 0.1 in fiscal 2024, and 0.7 in fiscal 2025. Three consecutive failures, requiring letters of credit posted to the department.

It also breached its bond covenants at June 30 of both 2023 and 2024, putting it in technical default. Its fiscal 2023 audit records that no waiver had been received and that bondholders could demand repayment in full. In January 2025 it signed a forbearance agreement good for twenty-nine days and drew a new $6.5 million credit line, guaranteed by certain members of its own board.

Eric Darr, president for eleven years, resigned on November 1, 2024. That was four weeks after the Bloomberg investigation published. The university gave no reason. The interim president who followed cut the Panama and Dubai campuses, telling a local broadcaster they "weren't real opportunities for us."

When Corinthian Colleges and ITT Tech collapsed, the weapon was federal student aid. Cut off Title IV eligibility and a predatory college dies within a semester, because federal loan money is the revenue.

That weapon does not reach here. Foreign students cannot borrow federal student loans. They pay cash, in advance, out of pocket.

The federal loan numbers make the point. Westcliff had 172 borrowers entering repayment against 6,532 enrolled students. Harrisburg had 192 against 3,558. In Westcliff's own state filings the share of students taking federal loans has sat between 2% and 7% every year since 2017. Inside the graduate programs specifically, the 2024 filing puts it at 1% to 4%.

Pull the federal aid lever on a school like this and the overwhelming majority of the revenue does not notice.

We looked for the enforcement record against these schools. Here is what exists.

No Day 1 CPT school has ever been criminally charged. Not one indictment, not one named federal enforcement target, across the entire sector. We searched DOJ records, ICE announcements, SEVP school alerts, and accreditor actions.

Schools have been shut down for student visa fraud, and the cases are instructive because of what they were. Tri-Valley University's president got 198 months in federal prison in 2014 for fabricating transcripts and inventing faculty. Herguan University's CEO was indicted in 2012. The University of Northern New Jersey and the University of Farmington were not schools at all, they were storefronts ICE built itself to catch brokers.

Those were fake schools. The schools in this investigation are accredited and legal. That is precisely why nothing happens to them.

The government said out loud that it does not check

In March 2018 Senator Chuck Grassley wrote to the Department of Homeland Security about exactly this. His letter is blunt about the mechanism:

He asked DHS a direct question: what is the earliest date after arrival that a student can begin working for pay? DHS answered in June 2018, and the answer is the whole story:

The federal government confirmed in writing that it does not evaluate whether a program genuinely requires the work it claims to require. It calls that an academic question and leaves it to the school selling the degree.

DHS did say what the exception is supposed to mean. Twelve pages into the same response, it wrote that the graduate carve-out covers students "whose practical, work-based training is integral to the program of study, i.e., the student cannot progress in the program until this practical training is completed."

That is a demanding standard. A program where the work is genuinely a prerequisite to academic progress meets it. A program where enrollment exists to produce the work permit does not. DHS wrote the test down once, in a letter to a senator, and has never applied it to a single school.

One more detail from that exchange. Grassley asked for school-by-school CPT and OPT counts for several institutions he had flagged. Pages 4 through 9 of the published DHS response are redacted to solid black. Those are the pages containing the answers.

The audit that has never happened

The DHS Office of Inspector General has published roughly 2,500 audits, inspections, and evaluations since 2004. Not one of them examines the Student and Exchange Visitor Program. There is a single project listed as ongoing and unpublished, titled "ICE's Management of Student and Exchange Visitor Program School Certification." If it is ever released it will be the first.

The Government Accountability Office has looked at practical training exactly once, in 2014, and that report covered OPT. Its finding then was that ICE "has not identified or assessed fraud or noncompliance risks posed by schools that recommend and foreign students approved for optional practical training." A 2019 GAO report found a backlog of 3,281 school recertification petitions, handled by extending expiration dates 180 days at a time, which GAO said "may allow fraudulent schools to operate longer without detection." Two of its recommendations remain open.

What regulators did find

The findings that do exist are small, and they are about paperwork.

California's Bureau for Private Postsecondary Education inspected Westcliff unannounced on December 3, 2019 and issued Citation No. 2021028 on July 22, 2020. The violation was enrollment agreements missing the school's own countersignature. Bureau staff recorded that "Institution staff stated that the students sign the documents online, but they are uncertain as to why the documents are not signed by Institution staff." The fine was $1,000.

Harrisburg University has been under Middle States financial-stability monitoring since February 27, 2025, when the Commission rejected a supplemental report as inadequate and ordered a follow-up visit. Its Philadelphia location closed on September 1, 2025. Its accreditation is intact. So is everyone else's. None of the six schools is under accreditor sanction.

The school that lost its accreditation and kept advertising

International Technological University in Santa Clara is marketed as a Day 1 CPT provider. Its accreditation history is a matter of public record with WSCUC: reaffirmed for six years in June 2018, placed under an Order to Show Cause by February 2020, and then Withdrawal of Accreditation in June 2024, and again in June 2025. We read the June 2025 Commission action ourselves. It names the school.

The school is still operating. We loaded its website on July 29, 2026. It returns normally, the full catalog is up including a doctorate in business administration and two PhD programs, and the HTML page title reads, in full:

The site also promotes a spinoff at a subdomain branded as an artificial intelligence university, whose landing page advertises "32 Years of Accredited Graduate Education" and lists "Accredited via ITU" as a feature, for $100 a month.

We are not asserting those claims are false, because we have not established what accreditation, if any, the school currently holds. We are reporting the WSCUC record and the live marketing side by side. Confirming the school's current accreditation and SEVP certification is the obvious next step, and it is the single loose thread we would most like closed.

The tell hiding in ICE's own data

ICE publishes an annual count of CPT authorizations and a list of the top employers of CPT students. In 2024 there were 130,586 CPT authorizations. And in the top-25 employer table, ranked third, sitting between Tesla at 1,118 students and Google at 880, is a college: Lindsey Wilson College, with 1,028.

A school appearing in the federal government's own list of the largest employers of student workers, above Google, is the entire business model showing up in a spreadsheet. ICE published it and drew no conclusion.

Who actually gets punished

The staffing companies at the center of OPT fraud enforcement, the ones whose names recur in every practitioner account, have produced almost no prosecutions of their operators. The students who worked for them carry findings under INA 212(a)(6)(C)(i), which is permanent inadmissibility for willful misrepresentation, with no waiting period.

One operator did go to prison. Weiyun Huang ran two shell companies, Findream and Sinocontech, that sold offer letters, employment verification letters, I-983 training plans, and fake payroll to students. Her plea agreement puts the count at roughly 2,025 students for one company and 660 for the other. Customers paid $200 for a false offer letter. She was sentenced to 37 months in June 2020. Her companies had appeared on SEVP's own published list of top OPT employers in 2017.

The pattern across the whole enforcement record is consistent. Students absorb permanent immigration consequences. The institutions collecting the tuition absorb a $1,000 citation for unsigned forms.

On July 17, 2026, the Department of Homeland Security published a final rule at 91 FR 44976, effective September 15, 2026. It is the largest change to student visa mechanics in decades.

Commenters asked DHS to close it. Here is the answer, verbatim.

During the comment period, people wrote in asking DHS to eliminate Day 1 CPT. DHS summarized what they said, and the summary is worth reading twice:

DHS considered it and declined:

Elsewhere in the same document DHS writes that "F-1 students should not be relying on future or prospective income from Day-1 CPT as their primary means to financially support themselves in the United States." The agency understands exactly what the product is. It said so in a binding rule, and changed nothing about it.

We read all eight mentions of Day 1 CPT in the 155-page rule. DHS names no school.

What survives

The rule does not amend 8 CFR 214.2(f)(10)(i). The sentence is still there, word for word. A graduate program can still declare that it requires immediate participation in curricular practical training, a school employee can still authorize employment on a student's first day, and USCIS still never reviews it.

And a doctorate is a higher educational level than a master's. The same-or-lower-level ban does not reach it.

So the ladder gets shorter and a federal checkpoint appears at the top of it. The demand does not disappear. It gets pushed up one rung, into doctoral programs. Westcliff already has 375 students in a residential doctorate that graduated nobody on time, and 1,542 doctoral students overall as of its 2024 filing, up from 120 in 2017.

The rule written to close this is about to route the remaining customers directly into the programs with the worst completion records in the sector.

These are answerable. Accreditors, the Department of Education, SEVP, and the schools themselves hold the answers.

It would be easy to read this as a story about foreign workers gaming a system, and that reading is wrong on the arithmetic.

In 2024, 1,507 people paid to start a graduate degree in Westcliff's residential track. Eighty-three of them finished on time. They paid between $30,780 and $56,400 for the privilege, which is more than the online version of the same degree costs, and they were required by federal rule to buy the more expensive one. The 375 people in the residential doctorate paid $56,400 each into a program that produced zero on-time graduates and six degrees total.

Those students got the work permit. That much is real, and for most of them it is the entire reason they enrolled. What they did not get, in overwhelming numbers, is the degree they paid for. The school collected either way.

Every gate that was supposed to catch this is pointed somewhere else. Accreditors examine learning outcomes and financial stability. SEVP examines recordkeeping and facilities. The Department of Education tracks whether undergraduates graduate and does not ask about anyone else. The one enforcement tool with teeth, federal student aid, cannot touch a school whose students are barred from borrowing.

So the numbers sat in public filings for eight years, in a state database, waiting for anyone to add them up.