The American Council on Education (ACE) and 36 other higher education associations on Monday urged the Department of Homeland Security (DHS) to withdraw its proposed fee on Optional Practical Training (OPT) “in its entirety.” Their comment letter, filed on the final day of the public comment period, warns that the fee would deepen declines in international enrollment and could make fraud worse, not better.
Under the proposal, published Oct. 8, a college would pay $70,000 before recommending an international student for initial OPT and $30,000 for each later recommendation. The money would go to the Treasury Department, not to DHS, and would not be used for processing, fraud investigations or enforcement, according to ACE. Students now pay $520 to apply for work authorization. DHS says the fees are meant to curb fraud and protect workers.
Fraud Concerns
The groups argue the fee amounts to a “pay-to-play” system that “does not help distinguish between a responsible institution and a qualified student and appears to punish institutions that follow the rules.” Because colleges would likely pass the cost on to students or employers, or stop recommending OPT, the letter warns the fee could encourage unregulated employment arrangements and predatory third-party financing.
It also questions the logic of using a price as a safeguard. “Relying on a fee as a proxy for integrity mistakenly assumes that bad actors cannot afford high fees,” the groups wrote, noting that fraudulent shell companies “are often the most willing to finance exorbitant costs.” They say DHS already has tools, including institutional certification, designated school official training, job description reviews and employer verification.
As alternatives, they propose risk-based audits, employer-side verification and site visits for all OPT, data analytics to flag employers hosting implausible numbers of students, and a fee “clearly calibrated to the actual cost of the increased oversight.”
Enrollment and Economic Effects
The letter cites a 17% decline in new international enrollment in 2025-26, according to the Institute of International Education, and says some institutions project drops of 40% to 60%. It says international students typically pay full tuition, so losing them could lead to deficits that reduce support for domestic students, raise their costs or cut smaller academic programs.
It cites a NAFSA estimate that international students have an economic impact of more than $40 billion annually and support more than 368,000 domestic jobs. It also cites a 2018 Business Roundtable analysis concluding that a 60% reduction in OPT participation would cost 443,000 jobs over a decade, “including 255,000 jobs held by native-born workers.”
Compounding Policy Changes
The groups say the fee would stack on top of a separate DHS effort to end “duration of status,” which is blocked by a court order the administration is appealing. If that rule takes effect, they say, OPT students would need separate extension filings, and the combined burden would “effectively dismantle” post-graduation practical training.
If DHS proceeds, the groups ask for “a realistic economic impact assessment” accounting for visa declines and lost student contributions, and for explicit transparency on how fee revenue would be used.
They note the higher education community has supported fee increases when the money improves processing, fraud enforcement and the program itself.
If a final rule is issued, the fees would take effect 60 days after publication.
