Duration of Status Changes

For many years, F-1 and J-1 students were admitted to the United States for Duration of Status (D/S). Rather than receiving a fixed departure date, they could remain in the country as long as they continued to meet the requirements of their immigration status, such as maintaining full-time enrollment, making normal academic progress, and complying with all applicable regulations. 

Under the final rule, that admission framework changes. Most students will instead receive a specific expiration date on their Form I-94. On or before that date is reached, students generally must either: 

• Apply for an approved extension of stay from U.S. Citizenship and Immigration Services (USCIS), 

• depart the United States, or 

• qualify for another authorized immigration status. 

The change shifts much of the responsibility for maintaining lawful presence from ongoing compliance with immigration regulations – to ensuring that authorized stay is extended before the I-94 expires. 

The elimination of Duration of Status changes how students maintain lawful presence in the United States. 

Previously, many academic changes—such as extending an I-20 because research took longer than expected—could often be handled through SEVIS and the Designated School Official (DSO). 

Under the new framework, many students will need to submit applications directly to USCIS to extend their authorized stay. This introduces additional filing requirements, government processing times, filing fees, and the possibility that an extension request may be denied. 

Students should begin discussing their immigration timeline with ISSS at least 6 months before their I-94 expiration date. 

The rule generally applies to: 

• F-1 academic students 

• F-2 dependents 

• J-1 exchange visitors 

• J-2 dependents 

Although many of the examples in this FAQ focus on F-1 students, exchange visitors and dependents should also become familiar with the new requirements because their ability to remain in the United States may also depend on the expiration date listed on their own Form I-94. 

Students and scholars should expect several important changes, including: 

• A fixed expiration date on the Form I-94 instead of “D/S.” 

• Greater reliance on USCIS approval to extend authorized stay. 

• More advance planning for degree completion. 

• Increased importance of monitoring immigration documents. 

• Potential limitations on certain academic changes and transfers, depending on the applicable regulations. 

• Increased consequences for allowing an I-94 to expire without obtaining appropriate authorization. 

Because processing by USCIS may take several months, students and scholars should begin planning well in advance of any expiration date. 

The Form I-94 is your official record of admission to the United States. 

It identifies: 

• your immigration classification, 

• the date you entered the United States, 

• and the date your authorized stay expires. 

Under the previous D/S system, the I-94 generally showed “D/S.” Under the new rule, students and scholars should expect to see a specific expiration date. 

Your I-20 or DS-2019 remains an important immigration document, but it no longer serves as the document that controls how long you may remain in the United States. Students and scholars should download and review their I-94 after every international trip and notify ISSS immediately if any information appears incorrect. 

Possibly. 

Not every student or scholar will need an extension, but many students and scholars whose academic programs extend beyond the expiration date on their I-94 may need to apply to USCIS before their authorized stay expires. 

Examples include students who: 

• require an additional semester to graduate, 

• are completing a dissertation, 

• experience unexpected research delays, 

• receive an approved reduced course load that lengthens their program, 

• or remain in the United States for authorized practical training. 

Students and scholars should meet with ISSS approximately six months before their I-94 expires to discuss available options. 

The DSO/ARO continues to play a critical role in advising students and scholars, maintaining SEVIS records, and issuing Forms I-20 or DS-2019 when appropriate. 

However, under the new rule, extending your academic program in SEVIS does not extend your period of authorized stay. Depending on the circumstances, USCIS approval may also be required. 

Students and scholars should never assume that an updated I-20/DS-2019 automatically authorizes them to remain in the United States beyond the expiration date on their I-94. 

Allowing your authorized stay to expire may have serious immigration consequences. 

Depending on your circumstances, you may begin accruing unlawful presence, become subject to removal proceedings, lose eligibility for future immigration benefits, or encounter difficulties obtaining future visas. 

If you believe your I-94 may expire soon, contact ISSS immediately. Acting before the expiration date generally provides more options than waiting until after it has passed. 

In many cases, students and scholars who submit a timely and properly filed extension application before their authorized stay expires may remain in the United States while USCIS reviews the request. 

However, students and scholars should not assume that they may freely travel internationally during this period. Departing the United States while an application is pending may affect the application. Always discuss travel plans with ISSS before leaving the country. 

Academic plans frequently change. You may need more time to finish your degree, decide to pursue another degree level, change advisors, participate in practical training, or transfer to another institution. 

Under the new rule, immigration consequences may arise much earlier than students expect. Contact ISSS before making academic decisions so that any required immigration filings can be discussed before deadlines are reached. 

Students should consult ISSS before requesting any change of major. 

Depending on the regulations that apply to your situation, changing your field of study may require additional immigration review and may affect your eligibility to remain in the United States. Graduate students face additional limitations under the final rule. 

Changing majors without first discussing the immigration implications could delay graduation or require additional immigration processing. 

Transfers will be more limited than they were under the previous Duration of Status system. 

Students and scholars should not assume that admission to another institution automatically allows a SEVIS transfer. Depending on the regulations and individual circumstances, additional approvals or immigration filings may be required before transferring. 

Always consult ISSS before accepting admission elsewhere or requesting that your SEVIS record be transferred. 

This is one of the most common situations students encounter. 

If your academic program will extend beyond your I-94 expiration date, meet with ISSS as early as possible—ideally six months before your authorized stay expires. Waiting until the last few weeks before expiration may not allow enough time to complete any required immigration processes. 

Withdrawing from classes or taking a leave of absence may affect both your academic standing and your immigration status. 

Students should never withdraw from classes, stop attending, or take a leave of absence without first speaking with ISSS. Depending on the circumstances, a withdrawal may require departure from the United States or other immigration action. 

Students participating in Curricular Practical Training (CPT) or Optional Practical Training (OPT) or Academic Training (under the J1 Student Category) must continue to satisfy all existing eligibility and reporting requirements. 

Under the new framework, students should also ensure that their period of authorized stay extends through the entire period of approved employment. If an I-94 expires before employment authorization ends, additional immigration action will be necessary. 

Graduate assistants must maintain lawful immigration status to remain eligible for employment. 

If your immigration status changes because an extension is denied or your authorized stay expires, your employment eligibility will also be affected. Notify ISSS immediately if you receive any correspondence from USCIS regarding your status. 

It depends on the type of employment you have and whether you meet the requirements for continued employment authorization. 

Under the new regulations, an F-1 student who timely files an extension of stay application may generally remain in a period of authorized stay while USCIS reviews the application. Certain F-1 employment authorizations may also continue during the pending extension period, but the automatic continuation is limited and does not apply to every type of employment.  

For eligible F-1 employment categories, including certain: 

• On-campus employment  

• Curricular Practical Training (CPT)  

• Severe economic hardship employment authorization  

employment authorization may continue while the extension application is pending, but the automatic extension generally cannot exceed 240 days from the expiration date of the student’s period of admission listed on the Form I-94.  

Students should not assume that they may continue working simply because an extension application has been filed. The ability to continue employment depends on: 

• The type of employment authorization;  

• Whether the extension application was filed properly and on time;  

• Whether the student maintained F-1 status;  

• Whether the student remains eligible for the specific employment benefit.  

Optional Practical Training (OPT) and STEM OPT 

OPT and STEM OPT students should pay particular attention to the expiration dates of their employment authorization documents (EADs). The continuation of employment during a pending application may follow separate rules depending on the type of application filed. For example, certain STEM OPT extension filings may allow continued employment for a limited period while USCIS processes the application.  

Students should consult ISSS before assuming they may continue employment after the expiration of any employment authorization document. 

Example Scenario 1 – Graduate Student Completing Dissertation 

Situation:
Jin is a Ph.D. student whose I-94 expires on September 30. He files an extension of stay application with USCIS before the expiration date. Jin has an on-campus graduate research assistantship. 

Can Jin continue working? 

Possibly. Because Jin timely filed his extension application and his employment is an eligible F-1 employment category, his authorized employment may continue while USCIS processes the application, subject to the applicable limits and requirements. Jin should work with ISSS and his employer to ensure documentation is available to verify continued employment authorization.  

Example Scenario 2 – Student With Expired OPT EAD 

Situation:
Maria’s post-completion OPT EAD expires on October 1. She filed an extension-related application, but her new employment authorization has not yet been approved. 

Can Maria continue working? 

Maria should not assume she can continue working. F-1 employment authorization is tied to specific regulatory requirements, and a pending immigration filing does not automatically authorize employment in every situation. She should consult ISSS before continuing employment after the expiration date on her current employment authorization document. 

Important Reminder for Students 

A pending extension of stay application does not automatically provide general employment authorization. 

Before continuing employment after an I-94 expiration date or employment authorization expiration date, students should confirm with ISSS that: 

1. Their extension application was timely/properly filed;  

1. They remain eligible for employment;  

1. Their specific employment category allows continued work while the application is pending;  

1. Their employer has appropriate documentation for employment verification.  

Working without authorization is a serious immigration violation that may negatively affect a student’s current status and future immigration benefits. 

Students should continue to obtain valid travel signatures and carry all required immigration documents. 

However, travel while an immigration application is pending may have additional consequences. Always consult ISSS before making international travel plans if you have recently filed or plan to file an immigration application. Furthermore, any current student admitted on D/S who travels and re-enters during the transition period will immediately be subject to the new rules upon re-entry. 

Download your new I-94 and verify: 

• your admission category, 

• your date of admission, 

• your expiration date. 

If any information is incorrect, contact ISSS immediately so that corrective action can be discussed. 

Contact ISSS before: 

• extending your academic program, 

• changing majors, 

• changing degree levels, 

• transferring schools, 

• withdrawing from classes, 

• accepting employment, 

• traveling internationally, 

• applying for immigration benefits, 

• or whenever you are unsure whether an academic decision may affect your immigration status. 

Early advising often prevents problems that become much more difficult to resolve later. 

No. 

This FAQ is intended to provide general educational information for students and scholars. Immigration laws are complex and individual circumstances vary. If you need legal advice or representation, ISSS recommends consulting with a qualified immigration attorney. 

Not necessarily. 

Students who are already in the United States and whose current Form I-94 is marked “D/S” (Duration of Status) should carefully review the transition provisions contained in the final rule and any subsequent guidance issued by the Department of Homeland Security (DHS) or U.S. Citizenship and Immigration Services (USCIS). 

The final rule establishes a transition from the longstanding Duration of Status admission system to a fixed period of admission. How that transition applies to an individual student depends on the provisions of the rule, the student’s immigration history, and any future actions the student takes, such as international travel or filing an immigration application. 

During this transition period, students should continue to comply with all F-1 or J-1 requirements, including: 

• Maintaining full-time enrollment (unless otherwise authorized) 

• Making normal academic progress 

• Keeping immigration documents valid 

• Reporting address changes 

• Following all employment authorization requirements 

Students should not make assumptions about how the transition applies to them. ISSS will provide individualized guidance as additional information becomes available. 

The answer depends on the transition provisions contained in the final rule. 

Some students who were admitted under the previous Duration of Status system may continue to be governed by those admission terms for a period of time, while others may transition to the new system because of a future immigration event, such as international travel, filing an application with USCIS, or another action specified in the regulations. 

Because transition rules can be complex and depend on individual circumstances, students should avoid relying on information from unofficial sources or social media. 

If you were admitted before the effective date of the rule, ISSS recommends scheduling an advising appointment if you have questions about how the transition provisions apply to your specific situation. 

Yes. 

Your Form I-20 or DS-2019 remains an important immigration document and continues to document your academic program and eligibility for F-1 or J-1 status. 

However, under the new regulatory framework, your I-20 or DS-2019 alone may no longer determine how long you are authorized to remain in the United States. Depending on how the transition provisions apply to you, your authorized stay may instead be governed by the expiration date shown on your Form I-94 or by another period established under the regulations. 

After September 15th, 2026, current students and scholars will have a maximum of 4 years or until their current program end date listed on the I-20/DS-2019 (which ever is shorter) to complete their degree/program.  If a student has not completed their program by the end of their current program end date on the I-20/DS-2019 or within a maximum of 4 years, the student or scholar will need to apply for an extension of stay 

Students  and scholars should not assume that having a program end date several years in the future automatically authorizes them to remain in the United States for that entire period without additional immigration action. 

If your expected graduation date/program end date changes or you anticipate needing additional time to complete your program, contact ISSS as early as possible to discuss your options. 

No. 

Students who are already in the United States generally should not expect to receive a new Form I-94 automatically simply because the final rule becomes effective. 

A new Form I-94 is typically issued when you are admitted to the United States after international travel. Other immigration actions involving USCIS may also affect your period of authorized stay. 

Students should continue to keep copies of their current immigration documents and periodically review their Form I-94 to ensure the information is accurate. 

If DHS announces additional transition procedures, ISSS will communicate those updates to affected students. 

International travel will change how the new regulations apply to a student previously admitted as D/S. 

Students and scholars who currently have a Form I-94 marked “D/S” may receive a different admission record when they re-enter the United States after the rule becomes effective. Instead of receiving an I-94 marked “D/S,” you may receive a Form I-94 containing a specific expiration date that establishes your authorized period of stay. 

Before making international travel plans, students should: 

• Verify that their passport and visa are valid. 

• Obtain a valid travel signature from ISSS. 

• Discuss how reentry under the new regulations may affect their immigration timeline. 

• Understand whether additional immigration filings may be necessary in the future. 

After travel and re-entry to the US, current students will also find that their 60 day grace period has now been shortened to 30 days.  It may be beneficial to remain in the US if you are going to complete your program within the next 4 years so that you are eligible for a 60 day grace period rather than a 30 day grace period. 

After every international trip, download your new Form I-94 and carefully verify the information. If the admission class or expiration date appears incorrect, contact ISSS immediately. 

The implementation of a major regulatory change may involve additional guidance from DHS, USCIS, the Department of State, or the Student and Exchange Visitor Program (SEVP). 

ISSS will communicate important updates through official university communication channels, which may include: 

• University email announcements 

• The ISSS website 

• Student newsletters 

• Information sessions and webinars 

• Individual advising appointments 

• Workshops for international students 

Students are strongly encouraged to read all communications from ISSS promptly and to ensure their university email account remains active and regularly monitored. 

Because implementation guidance may change over time, students should rely on official university communications rather than social media, unofficial websites, or anecdotal information from other students. 

The best way to prepare is to remain proactive. 

ISSS recommends that all international students and scholars: 

• Keep copies of all immigration documents, including passports, visas, Forms I-20 or DS-2019, Employment Authorization Documents (if applicable), and Forms I-94. 

• Download and review their Form I-94 after every entry into the United States. 

• Begin discussing graduation timelines with ISSS at least six months before their expected completion date. 

• Notify ISSS immediately of any changes to their academic program, enrollment, address, or immigration status. 

• Consult ISSS before changing majors, transferring schools, withdrawing from classes, or traveling internationally. 

• Attend ISSS workshops and information sessions regarding implementation of the new regulations. 

The answer depends on your individual circumstances and whether you remain covered under the transition provisions of the final rule. 

Students who were admitted in F-1 status before the effective date and are physically present in the United States with a Form I-94 showing “D/S” may be eligible for certain transition provisions. However, being admitted under D/S does not mean that all previous academic flexibility continues indefinitely. The final rule introduces new restrictions on certain academic changes, including graduate-level changes of study and transfers, and students should carefully evaluate their options before making changes to their academic program.  

Changing a Graduate Major 

Graduate students who are currently enrolled should not assume they may freely change their major or field of study after September 15, 2026. 

Before requesting a change of major, students should consult ISSS because: 

• The final rule does restrict graduate students from changing their academic objective after beginning their program.  

• A change in field of study may require additional immigration review or approval.  

• A change that appears academically minor may have significant immigration consequences.  

• Students who change programs without proper immigration guidance may risk losing eligibility to continue in F-1 status.  

Example:
A student enters the United States in Fall 2026 as a Ph.D. student in Mechanical Engineering. In Spring 2027, the student decides to change to a Ph.D. program in Computer Science. Even though the student originally entered before the change, the student should not assume the transfer between graduate fields will be permitted. The student should meet with ISSS before making any academic change because the new rule may limit this type of change. 

Transferring to Another University 

Current graduate students admitted under D/S should also consult ISSS before transferring to another institution. 

Under the final rule, graduate-level transfers are subject to additional restrictions and review. A student who was admitted under D/S does not automatically retain the same transfer flexibility that existed before the rule took effect.  

Before accepting admission at another university, students should: 

• Meet with ISSS at their current institution.  

• Discuss whether the transfer is permitted under the new regulations.  

• Determine whether USCIS approval may be required.  

• Understand whether travel outside the United States could affect their immigration status.  

• Avoid requesting a SEVIS transfer until immigration implications are reviewed.  

Example:
A master’s student admitted in 2025 under D/S applies to another university in 2027 and is accepted into a different master’s program. Although the student still has an active I-20 and maintained status, the transfer requires additional review under the new regulations. The student should not assume that the SEVIS transfer process alone is sufficient. 

After September 15th, 2026 – current graduate students who are considering any of the following should contact ISSS before taking action: 

• Changing majors  

• Changing departments  

• Changing degree objectives  

• Transferring universities  

• Beginning a second graduate program  

• Leaving one graduate program and starting another  

Students should also remember that maintaining valid F-1 status requires more than simply having a valid I-20/DS-2019. Immigration compliance now requires careful coordination between academic decisions, SEVIS requirements, and any required USCIS processes. 

Scenario – Graduate Student Wants to Change Research Area 

Situation:
Wei is a second-year Ph.D. student in Chemistry. After completing coursework, Wei decides that their research interests have shifted and wants to move into a Ph.D. program in Biomedical Engineering at the same university. 

What should Wei do?
Wei should meet with ISSS before requesting the academic change. Although Wei was admitted before the elimination of D/S, the new regulations will restrict graduate students from changing their academic objective after beginning their program. ISSS must review whether the proposed change is permitted and whether additional immigration action is required. 

If you were physically present in the United States in valid F-1 status before September 15, 2026, you generally do not need to file an Extension of Stay (Form I-539) when you apply for post-completion Optional Practical Training (OPT) as long as you as you submit your I-765 within six months of the effective rule date. DHS included this temporary exemption to ease the transition from the previous Duration of Status (D/S) system to the new fixed-period admission system.  

To qualify for this transition benefit: 

• You must have been physically present in the United States in valid F-1 status before September 15, 2026 (and not traveled outside of the US after this date.)  

• You must file your Form I-765, Application for Employment Authorization, within the normal OPT filing window and within six months of the date the rule goes into effect (September 15, 2026.)  

• You must continue to meet all other eligibility requirements for post-completion OPT, including maintaining valid F-1 status and receiving an OPT recommendation from your Designated School Official (DSO).  

If you meet these requirements, USCIS will process your OPT application without requiring a separate Extension of Stay application as part of your initial post-completion OPT request under the transition policy.  

Important: This transition relief is limited to six months after the rule goes into effect on September 15, 2026.  After March 15, 2027 – students applying for post completion optional practical training will be required to file an Extension of Stay in addition to an employment authorization application.