The Proposed $100,000 OPT Fee
File comments by Monday, November 9, 2026.
On October 8, 2026, the Department of Homeland Security (DHS) published a proposed rule that would impose a $70,000 fee on initial Optional Practical Training (OPT) applications, and an additional $30,000 fee for any subsequent OPT applications, such as the OPT STEM-Extension. This rule, if implemented, would devastate the OPT program—a critical talent pipeline for the U.S. economy securing America’s innovation, economic growth and national security.
International students contribute nearly $43 billion annually to the U.S. economy and support more than 355,000 jobs. International education technically qualifies as an export and ranks roughly 7th among such U.S. export products. Their tuition dollars help subsidize lowering tuition for domestic students and their scholarship boosts innovation and academic excellence, helping to make U.S. colleges and universities the top in the world.
International students comprise more than 50 percent of the graduate students in key STEM academic disciplines, such as electrical engineering and computer science. The vast majority of these students desire to work in the U.S. economy after graduation and the OPT program is the primary first step. Roughly one-third of OPT participants transition into H-1B or other longer-term visas and over half of all H-1B visa holders come from the OPT program. 30 percent of U.S. STEM workers are foreign-born and 63 percent of this population first came as international students. Nearly half of the STEM PhDs working in the U.S. are foreign-born and 71 percent of them first arrived as international students typically using the OPT as a bridge.
The proposed OPT fee will price the program out of reach for employers and students. It will devastate the use of OPT by as much as 80 percent, depriving the American economy of tens of thousands of the world’s most highly-skilled and educated workers. Economic research estimates that the U.S. economic loss resulting from this loss of talent could be as high as $240 to $481 billion of U.S. GDP annually as the cumulative effects come to bear.
The OPT Fee Notice of Proposed Rulemaking (NPRM) was posted for public inspection on October 8, 2026, and the public is encouraged to submit their opinions on this rule by Monday, November 9, 2026.
Understanding the Rule
The proposed rule is 35 pages. You can find a detailed analysis of the proposed rule and its economic impacts prepared by the Institute for Progress at:
A good media piece that analyzed the proposed rule and discusses the context in which it was introduced (i.e., how it relates to efforts to create similar $100,000 fees for H-1B visa applicants), as well as the economic impacts, was written by Stuart Anderson from the National Foundation for American Policy and was published in Forbes.
The Importance of OPT
to America
The U.S. for Success Coalition has assembled some strong talking points documenting the importance of international students and OPT to the American economy, to universities, and to American workers.
NAFSA has a shorter version of the U.S. for Success document on the importance of OPT:
The Economic Innovation Group has done a very detailed analysis of the importance of international students to America’s colleges and universities and supply of high-skilled STEM graduates, as well as the importance of OPT to the American economy.
Detailed Talking Points on the OPT Fee Issue
Brief overview
With more than 1.1 million international students who spend $43.8 billion annually in the U.S., as well as over 400,000 Optional Practical Training international student workers in the U.S. economy, this rule would have devastating economic consequences. It will decrease an immediate supply of critical STEM talent, reduce the number of high-tech startups launched by international students, slow patent production from America’s research universities and deprive colleges and universities of much-needed tuition revenue, triggering either tuition increases on domestic students or decrease in educational offerings. Historically, federal regulations governing international education have only attracted attention from leaders in higher education. The proposed $100,000 OPT Fee rule, however, is one of several attacks on international students who have played an increasingly critical role in the American economy. It is important for business, industry and economic development leaders to weigh in on these issues in order to protect the supply of critical talent needed for the U.S. economy, especially in STEM fields.
Impacts to U.S. Employers
The proposed rule seems particularly harmful to U.S. employers who employ more than 400,000 international students on the Optional Practical Training (OPT) portion of their student visa. The rule proposes a four-year cap before international students will need to apply for extension of say, requiring filing fees, biometric data, interviews, lawyers, delays and red tape. These sorts of delays will make hiring international students on OPT an uncertain and risky venture, exactly the opposite of what employers need in developing strategies to fill critical talent gaps. The rule will greatly deter utilization of the STEM extension of the OPT that has fueled growth in OPT employment and will make pursuing PhDs more difficulty. The rule will decrease international student enrollment, the majority of whom major in STEM fields and who make up significant majorities of the graduate students in computer science, engineering, artificial intelligence, mathematics, as well as physical and life sciences—all fields critical to America’s economic future.
Impacts on the U.S. Economy
International students spent $43.8 billion annually in the U.S., making it the seventh largest service export product. Those expenditures don’t just hurt higher education, but they impact retail business, landlords, tourism, hospitality and other business sectors in the university towns and communities across the nation. Longer-term economic impacts will be felt through the loss of innovation (patents being generated by colleges and universities), decrease in future startups, loss of high-skilled STEM workers available for higher and loss of future exports and investments from global partners who have built ties to the U.S. while studying as international students here. Economic research estimates that the U.S. economic loss resulting from the proposed OPT Fee rule from the loss of high-skilled STEM talent in the U.S. workforce could be as high as $240 to $481 billion of U.S. GDP annually as the cumulative effects come to bear ten years down the road.
Hampering U.S. Innovation
International students have played a critical role in U.S. innovation. Over 50 percent of international students major in a STEM discipline, and international students comprise over 55 percent of all the graduate students in America in electrical engineering, computer science, industrial and manufacturing engineering, statistics, economics, civil engineering, mechanical engineering, agricultural economics, and mathematics and applied math. The students are a critical component of the future STEM workforce to advance innovation within American companies and industry. International students and faculty are critical to the innovation that occurs with America’s research universities. It is estimated that 75 percent of the patents awarded to the nation’s top ten patent-producing research universities had an international student, faculty or researcher among the team filing the patent. International student graduates go on to launch some of the most important and valuable startup companies in the U.S., having founded or co-founded 24 percent (186 of the 775) U.S. “unicorns,” startup companies backed by venture capital with market valuations in excess of $1 billion. They also contribute to a disproportionate number of U.S.-won Nobel Prizes in science.
The Rule Will Accomplish Little in Terms of Reducing Fraud
First, DHS does little to truly document the prevalence of fraud in the OPT program. Second, the fee seems designed simply to reduce the number of OPTs without any true effort to target fraud within the system. To this end, the proposed $100,000 OPT Fee rule seems to exemplify the proverbial “throwing the baby out with the bathwater” phrase. In other words, if fraudulent use of OPT is the dirt in the bathwater one has after washing a baby, imposing an exorbitant fee is the equivalent of flushing the baby with the bathwater down the drain.
The Importance of Spreading the Word and Engaging Business, Industry and Economic Development Sectors
Historically, federal regulations governing international education have only attracted attention from leaders in higher education. The proposed $100,000 OPT Fee rule, however, is one of several attacks on international students who have played an increasingly critical role in the American economy. It is important for business, industry and economic development leaders to weigh in on these issues in order to protect the supply of critical talent needed for the U.S. economy, especially in STEM fields. Most Americans, business and economic development leaders and policymakers are unaware of the enormous economic contributions of international education and the talent proposition that graduating international students pose to help fill critical talent gaps. More than half of all international students major in STEM fields and international students account for more than 70 percent of the graduate students in critical disciplines such as electrical engineering and computer science. The proposed $100,000 OPT Fee rule flies in the face of comments made by President Trump on the campaign trail, as well as in the 2025 State of the Union address in which he promised to expand opportunities to work in the U.S. for graduating international students. It is important to make employers, chambers of commerce, industry groups, economic development organizations and other allies beyond the higher education sector aware of the proposed rule and to assist them in filing comments to the rule.
The Proposed Rule Is Part of a Larger Attack on International Students and International Education
Despite President Trump’s repeated promises on the campaign trail and during his State of the Union address to increase opportunities for international students to work in the U.S. after graduation, the federal government is in the midst of attempting to implement a series of policies that will have the exact opposite effect and will make the U.S. far less attractive to potential international students of the future. These policies began in late March when as many as 6,000 international students found their status had been summarily revoked, including some arrests on the streets of international students by masked ICE agents. Eventually, many of these students had their status reinstated and the Secretary of State clarified that these actions were motivated by concerns over political expression and speech these students made in relation to U.S. foreign policy and/or issues relating to Israel and Palestine that the federal government viewed as anti-Semitic. In May and June, the U.S. Secretary of State suspended all new visa appointments for incoming international students. Once the suspensions were lifted, consulars were instructed to implement new social media vetting protocols, creating significant processing delays. Earlier this fall, DHS announced a final rule changing its Duration of Status policies that would change decades of policy that grants international students on F-1 visas lawful presence in the U.S. so long as they are enrolled in their degree program on a full-time basis to put a four-year limit on the duration of their status, forcing nearly half of all international students to pursue and expensive and burdensome Extension of Stay application to complete their degree or pursue OPT employment. A temporary injunction has been ordered against this new rule and in the coming months the federal courts will review its legality. Now comes the $100,000 OPT Fee, which would fundamentally change the economics behind OPT, essentially pulling up the welcome mat, locking the door and barring the windows on the pathway that international students would travel to enter the U.S. workforce and contribute to our prosperity. This is completely opposite of what President Trump campaigned on in regards to opening the door on assisting talented international students educated at American colleges and universities to more easily access jobs in critical areas of the economy. Given these series of attacks, it is important for business, industry and economic development leaders to weigh in on these issues in order to protect the supply of critical talent needed for the U.S. economy, especially in STEM fields.
Prepare and File Comments
The proposed $100,000 OPT Fee rule offers a 30-day comment period ending on November 9, 2026. Comments must be filed by then. Comments can (1) be filed here through the online portal; or (2) by emailing dhsdeskofficer@omb.eop.gov and including the docket number (Docket No. ICEB-2026-0100) and “Attention: Desk Officer for U.S. Immigration and Customs Enforcement, DHS” in the subject line of the email). There also are instructions in the rule to mail in comments if for some reason that is preferable.
Click below for draft comments that you can customize into comments from you and your organization. Ideally, your comments will reflect you and your organization’s experience with international students and the OPT program.
How to Get Involved
File Comments
The most effective way to oppose the proposed $100,000 OPT Fee rule or to minimize its negative impacts is to file comments with DHS by November 9, 2026. The section on this microsite gives you more details on how to file comments and what those comments might contain. But at this moment, filing comments is the most effective way to oppose these changes.
Get Others to File Comments
The purpose of this microsite is to engage important voices that have not traditionally spoken up about this topic and the importance of international education, international students and their entry in the U.S. workforce via OPT. Specifically, we hope you will work to get employers, business groups, chambers of commerce, economic development organizations, state and local government and other voices to file comments opposing this proposed rule.
Spread the Word
One way to bring awareness to this issue and to raise the profile of the importance that international education, international students and their entry in the U.S. workforce via OPT represent to America, our local economies and higher education is to write an opinion piece in local papers, business journals, newsletters, blogs, LinkedIn posts, and other social media. This microsite contains sample social media posts. If you would like assistance in crafting an opinion piece or otherwise spreading the word, or if you have an opinion piece you want to share, please contact us at info@globaldetroitmi.org.
Host a Webinar
Most Americans, business and economic development leaders and policymakers are unaware of the enormous economic contributions of international education and the talent proposition that graduating international students pose to help fill critical talent gaps. Hosting a webinar to provide data on those contributions, as well as to explain the proposed $100,000 OPT Fee rule can help educate these partners. Global Detroit’s E Pluribus program would love to work with you to help host a webinar to spread information on this proposed rule and/or the importance of international education and international students to our economy. Please contact us if you need assistance.
Join the E Pluribus International Student Retention Peer Learning Cohort
Global Detroit’s E Pluribus program supports an International Student Retention National Peer Learning Cohort of nearly three dozen local international student retention programs. These programs are immigrant economic inclusion initiatives, economic development organizations, chambers of commerce, state and municipal offices of New Americans, as well as state and local programs who are focused on connecting international student talent to unmet private sector talent needs. The cohort meets online monthly, conducts webinar, and shares research and best practices, as well as tools to advance local international student retention initiatives. To find out more information and/or join the group email us at e.pluribus@globaldetroitmi.org.
Volunteer
Global Detroit is always looking for volunteers who can help us with our programs. Whether it’s crafting social media posts, doing research, analyzing data, conducting outreach to partner organizations, designing websites and reports or just helping out, we welcome volunteers. Email us at info@globaldetroitmi.org to find out more.
Get in Touch
Global Detroit and the E Pluribus program would love to hear from you. If you have questions, ideas, requests or just want to talk about these issues, drop us a line at info@globaldetroitmi.org.
Make a Donation
Global Detroit is a tax-exempt charitable organization. Our E Pluribus national work currently operates without any dedicated funding. If you want to support this program please contact us or consider a donation at https://globaldetroitmi.org/donate/.
Join the U.S. for Success Coalition and/or Other Advocacy Groups
There are other national policies that would negatively impact international education and international students that are being considered right now and working in coalition is one way you can stay informed and help further the cause of supporting international education and international students. The U.S. for Success Coalition is one multi-sector effort that aims to foster international student success in the United States through a coordinated national effort working in partnership with the U.S. government, higher education institutions, the business sector, and other key partners to foster supportive federal policies and practices. You can join the U.S. for Success Coalition at https://www.usforsuccess.org/join-us.