On February 27, 2008 the Student and Exchange Visitor Program (SEVP) notified schools that it was preparing to begin an OPT (Optional Practical Training) data validation exercise, which requires schools to update the SEVIS records of all students on OPT with the current name and address of the student, the name and address of the student's employerand dates of employment.

The new rule states that during post-completion OPT, F-1 status is dependent upon employment. During any initial 12-month period of post-completion OPT, no student (including STEM students) may be unemployed for an aggregate of more than 90 days. If a STEM student receives a 17-month extension, the limit on unemployment is raised to an aggregate of no more than 120 days, applied to the entire 29-month period on which the student is on post-completion OPT.