24 months stem opt form i983
OPT | USA Visa

Does Consulting Job qualify for 24 Months STEM OPT Extension?

24 Months STEM OPT is a Go! May 10, 2016 is here and it’s time to apply for 24 Months STEM OPT Extension. Students on OPT are finding out that it’s challenging to complete the form I983. There’s more questions at this point then answers.


  • I work at client site through an IT consulting company. Can I apply for OPT Extension?
  • Who should sign the form – My employer or client manager?
  • My DSO is not providing guidance on these topics. Where can I get sample i983?

In this video, I cover the following topics:

  • Form I-983 ( 7 pages long)
  • Consultants and Self-Employment Jobs in STEM OPT
  • DHS comments on Types of employment allowed for STEM OPT Extension.
  • Caution Ahead. Plan accordingly.

Video – STEM OPT Extension and Form I-983

Types of Employment in STEM OPT Extension

Here’s the response from DHS about types of employment  allowed during STEM OPT Extension period

There are several aspects of the STEM OPT extension that do not make it apt for certain types of arrangements, including multiple employer arrangements, sole proprietorships, employment through “temp” agencies, employment through consulting firm arrangements that provide labor for hire, and other relationships that do not constitute a bona fide employer-employee relationship. One concern arises from the difficulty individuals employed through such arrangements would face in complying with, among other things, the training plan requirements of this rule. Another concern is the potential for visa fraud arising from such arrangements. Furthermore, evaluating the merits of such arrangements would be difficult and create additional burdens for DSOs. Accordingly, DHS clarifies that students cannot qualify for STEM OPT extensions unless they will be bona fide employees of the employer signing the Training Plan, and the employer that signs the Training Plan must be the same entity that employs the student and provides the practical training experience. DHS recognizes that this outcome is a departure from SEVP’s April 23, 2010 Policy Guidance (1004-03).

If you are working on OPT or 17 months OPT as a consultant then talk to an attorney (Ask an Immigration Attorney) or your employer to sort things out.

When DSO reviews your training plan, they may not know about client sites, contract jobs, types of employment and approve your I-20 for STEM OPT Extension.

But, you could get RFE when applying for H1B to prove that you were employed by the same employer who signed the Training Plan for STEM OPT Extension. So, be warned and make plans to avoid issues in the future.

I’m merely reporting what I read from response and it better safe then feeling sorry later when it comes to Immigration.

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  1. I am working for a staffing company. The site I am working refused to sign the I-983 form but the staffing company signed it and also my DSO approved it. I saw one similar case that USCIS approve the extension. Are there any other cases?
    Thank you

    1. Hello Preeti, I am in similar situation. I work for an e-verified company but they are not willing to sign the i983. Can you please tell me how did you handle this situation? I do not want to loose my job. Thanks.

  2. Hi Raghu

    I have a question if I work with STEM E-Verfied employer on my STEM extension period and he denies to sign i983 form, can the client sign the form as I will be working on onsite and my formal training takes place only on onsite.

    Your reply will be much appreciated or would you like me to consult a attorney?


    1. As far I know, it has to be signed by your employer who is issuing paychecks. Consult and attorney to know the impact of Client sign.

    2. Hi Preeti,

      Did you get the client’s signature on the I-983, and more importantly, did it get approved?

      I am in a similar situation as you were and it would be helpful to know about what happened to your case.

      Thanks in advance,

  3. Hello Raghu,
    I am on OPT- EAD and wants to apply for 24 months Extension. I don’t have employment right now and my EAD is valid till other 2 months. What should i do now?

  4. Hi
    my I94 has a space constrain on my first name. But i sent the same document to USICS for OPT extension as i don’t have time. Later i requested DHS to update it correctly and they did. now do i get any problem on my approval as they have the old I94 or is it okay? Do USCIS get to know the update made by DHS or Should i expect RFE? Please help. Thanks

  5. I have an APPROVED opt stem 17 month and APPROVED opt stem 7 month extension. Is it possible to change jobs to an employer who is unwilling to be e-verified? Uscis website says we should have e-verified employer if we’re applying for opt stem extension but it is not clear whether we require company to be e-verified after stem is approved. Also, form i983 doesn’t have anything about e-verification. Please help!

    1. STEM OPT Employer Responsibilities:

      If you are an employer who wants to provide a practical training opportunity to a STEM OPT student during his or her extension, you must:

      – Be enrolled in E-Verify and remain in good standing.

  6. Hi raghu, I am currently under 12 months OPT which expires by JAN 27, I am working as a full timer for TCS but my client location is in different state. If i mention my client as my present site location in I983 Form, will i will be in trouble of getting OPT extension

  7. Hi Raghu,

    My OPT is expiring on 1st Feb, 2017 and I have to apply for the STEM Extension. I am working Independent Contractor and I am not a Full time employee of the consulting firm.

    What are my chances to get my Stem Extension approved ? Or if there is any other way out.

    Any suggestions are welcomed

  8. Hello Raghu ,
    My opt will expire in January and I need to apply for extension. Does desi consulting having any issue with opt extension ? They said we get already acceptance for some of our employees but I just want to make sure you have heard any thing from any one who is suffering issue with extension from desi consulting company ?
    Thanks !

    1. DSO’s are issuing I-20 for consulting companies. But, we have to wait and see what happens to them when USCIS adjudicates H1B. Good Luck.

  9. Hello All,

    I am working with express on my opt ead and parallely i have started a LLC now would i have any problem for OPT extention during may 2017

  10. Hi,

    I am currently on 17-month OPT stem extension working in an IT company on a full time basis. I actually did my master’s in Electrical Engineering. I am wondering whether or not to apply for the 7-months stem extension. I have all the documents ready with new i-20 issued by my DSO after I submitted my i-983 document. I have also provided my employee signed training plan since my company is an implementation partner to various software companies.

    If i apply for this 7-month extension, will I get RFE because my job is not directly related to my degree?
    And if I did get RFE will i get my current 17-month OPT be cancelled since i did my master’s in a different field?
    Is it worth it to apply for 7 month extension because my OPT stem extension is until July 2017.

    1. Vasi – This is something specific to you and Risk analysis should be done by an attorney. Maybe others in this page can chime in. You need to consult and Attorney. You are wasting time by asking in forums, when deadline to apply for 7 months OPT Extension is 2 weeks away.

  11. I started a full time job with a company “X” (NOT e-verified) on OPT on August 2015. Company filed for the H1B visa this year but I was not selected on the lottery. In order to get the OPT extension I resigned from company “X” and joined a staffing agency. But my work location/site is still the previous employer “X”.

    The staffing agency filled out the form I-983 and my DSO was totally OK with it. Before the OPT expiry date I was able to submit my application and I also received the receipt from USCIS.

    Just to evaluate the situation I talked to one of the attorneys at Bashyams. Unfortunately the attorneys response to my situation was vague. As they are yet to see cases like this they do not know how the USCIS is interpreting the new rule and what could be the outcome of my case.

    Is there anyone here who was in a similar situation and got his/her STEM OPT extended?

    Raghu, Do you know any of the people like me who got their STEM OPT Extended?

    1. I’m approving your comment and hope someone with similar situation can help you. But, it’s tough to find those contacts. Good Luck.

    2. Hey, Dubious,

      We are in exactly the same situation. Would you want to keep in touch with me to talk more about this?

      1. Just wanted to let people know that my STEM OPT extension got approved by the USCIS. It took around 2 months and 20 days!

        1. Hey ,
          When you file i983, did you keep the client site as where you work or where the consulting company is located?
          Did you mention that you work at a client site

          I am in the same situation and would likento know more

        2. Hi,
          My opt expires on October 2nd.
          I got a full-time job in July and reported opt.
          I got your know my employer is not e-verified . So they have arranged for an e-verified vendor to do my payroll (contract for 12 months) through whom I will work for the same role and company.
          Same as your situation.
          I’m now working on filling out the i983 form.
          In employer site information and direct supervisor information, should I mention vendor details throughout??
          I’m trying to avoid using client company details anywhere as they may wonder why I switched from direct hire to contractor with the same company.
          Kindly help!!!!

  12. I am on opt extension which expires this December. Recently I got full time job offer in CT before that I was on a contract job with desi company. Now that everyone is worried about i983. Should I update my present employer as cts by filling i983(change of employer)?
    Will CTS be filling i983?
    Please advice me on this.
    Thanks in advance!

    1. CTS will not file I-983. They will complete parts of it, but you have to file the form to your DSO.

  13. Is the 17 month stem opt still in place or is it just the 24 month stem opt rule?
    Can there be an instance where a student applies for a 24 month rule but gets qualified for the 17 months and not 24 months?

  14. I did my masters in EE .Now I have full time offer with India’s one of top most MNC company. It’s related to Data Base, even in my master degree i took data base related course. So will it be an issue to get 24 months opt extension?
    some one Please help me this, now I have wonderful offer in my hands but I’m completely dumb. Honestly I don’t know whether I have to accept this offer or not.

    1. Hi Radha,

      My scenario is same as you. Did you speak with attorney or anyone regarding this? Did you get any solution. Please help me out if u have something.


  15. Hi Raghu,

    I’m working through consultancy firm to Client location.

    My DSO is not accepting my i983 because Employer and Site information different. Please let me know what I have to do?
    Is there any one whose DSO approve same like my situation.


    1. If your DSO is not approving then you have to talk to an attorney to see if there is a way. Other options include finding a full time job.

    2. hi gopi I have same problem now.If you don’t mind can i have your contact information plz.I really need your advise,I have only 20 days in my hand to apply.

      1. Hello Ankitha, I would like to discuss about the same, can you please let me know your experience, alternate solution etc.

    3. Hi Raghu, Have you got your Extensions done? I am in the same situation as your’s. Can you please tell me what you did ?

  16. So, I have a question as I am on 17 months extension now.
    I tried going through all posts but I got even more confused on this.
    Do I need to apply for extra 7 months anyway? What if I don’t want to??
    Can I continue with my OPTX as it is now without filing for a 7 month extension?

    1. If you don’t apply, then you will not get 7 months of extra OPT. It depends on the time, month when your 17 months expires.

  17. Hi,
    I work for a company as a contractor. Its a startup so we dont have an office, I work from home. Its not a consultancy. Company is everified, I get paid as much as any US citizen would in my field of work. Would I have a problem in getting 24 months opt stem extension?

  18. Raghu,

    I have started working for one of the top 3 Indian MNCs, from last august in my OPT. I work at a client site. I have applied for my STEM OPT in May, before the new rule was implemented. Now I got an RFE from USCIS, requesting for 24 month I-20 from my University

    How can I proceed in this case? Am I eligible for 24 month STEM extension? My immigration department is also clueless how to fill the I983 form. How to proceed in my case

    1. You have to educate them or they have to talk to their attorneys and come-up with a solution. If you want help, you can talk to attorney Murali. Several people gave been asking him to help lately.

  19. Question 1: what if my current company(where I am legit full time employee),lays me off 10 days before 12month OPT completion date. Can I apply for STEM extension without any employer, i.e if I am unemployed?

    Question 2: The way I understand is that it is very tedious process to get a STEM extension through a consulting company, hence most consultancies wont support me for STEM extension. Let me know if my understanding is correct.

    1. Hi Raghu,
      I have same question as Jaykumar Sheth
      Question 1: what if my current company(where I am legit full time employee),lays me off 10 days before 12month OPT completion date. Can I apply for STEM extension without any employer, i.e if I am unemployed?
      Can you please help us on this.


      1. Sorry Santosh – I don’t know the answer. Your employer is supposed to oversee your training. So, I’m not sure. Good question to ask Attorney Bashyam.

  20. I applied under 17 month extension and my case was received on March 25 which is before May 10. So in this case my application was received for 17 month rule. Now what if I am not able to submit the I-983 form will I get 17 month since it was received before May 10th ?

    1. No, you will not STEM OPT. There no more 17 months STEM OPT. Why can’t you submit i983.

  21. Hi Raghu,

    Am not sure in what situation Am, i need you help now.

    My OPT started on Sep 30 and JULY 1st week is the time i need to apply for STEM extension for sure . I have been employed by a consulting firm for work and they didn’t run my pay roll till april from this month they are running it .

    I just wanted to ask you will this will affect me to not getting STEM extension (not running pay roll till april ) if i run my payroll now and if i work for the consulting firm itself.
    1) will it be a problem ? is there anything to worry about ?
    2)By the time they approved date or by the time they process my request i need to be employed and given wage (like not volunteer work ) ?
    3)If i get a fulltime job now will there be any problem since the pay roll with last employee was just for a month
    3)In the past you can do volunteer work but suddenly the new rule came out is there any exception ?

    Am sorry if am not clear about the questions i asked but final word is i was employed but they didn’t pay me and now after this new rule they are paying me (payroll is running) the situation is too bad for me so please explain the possible ways or steps to follow

    Thank you very much in advance

    1. What is problem with you guys ( those who are getting U.S. education, but unable to follow the rules and maintain status). You need to have a phone consultation with Attorney Murali Bashyam. I’m seeing several questions that goes to Attorney where situation can’t be recoverable. CRAZY. Plus, you should know when to ask in forums and when to pay for consulting.

  22. Hi Raghu,
    I currently did my masters in mechanical.And my BTech is also mechanical background.Now if I get full time software related job,will that be a problem to get opt extension for 24 months

  23. Can I change my job when I have applied for 24 month STEM extension? I currently hold a full time position, can I change to a different company when my application is being processed at USCIS which is through my current company. Thank you.

  24. Hi Raghu,

    I do work with full time employer from January 2016 but there were 2 months where i just took offer letter from consultancy so that i could get more time to look for job. Now when i apply for stem extension next month, my current employer will be filling all information. But what if uscis ask information for those 2 months? Will those 2 months cause problem to me? My opt started on Sep 15, 2015 and 90 period would end on Dec 14, 2015. When i didn’t get a job till mid November i took offer letter from them and still kept on searching. Finally i joined as full time from Jan 11, 2016.

    Can you suggest me what would happen in this case?


    1. Sorry Man. I’m not the person to answer this. Check via Ask an Attorney. I have no idea what will the impact now or later when you apply for H1.

  25. Finally I am glad USCIS is taking some stringent measures against folks using loopholes and I hope they implement it strictly. I hope this whole consulting business is wiped out as students have been abused by paying them lower salary. Capable students will survive by getting full time jobs and every student should strive to find a full time job.

    1. Yes..majority of students will start going back to their home countries and students flow coming to US will go down

      1. I really agree. This Cheating, Whole Fake experience, Proxy Skype Calls, Proxy Interviews. Cheating genuine trusting employers. Every thing would end.

        If some one has capability attend interviews then fine ( what ever they do with resume). But having proxy, cheating is fraud and punishable.

        This new rule would end majority of this ( i dont say every one are like this but unfortunately every one who do this are OPT).

    2. Hi,

      If you are in situation of any student who is facing all these problems, then you will not tell this easily. I am happy that USICS has taken a great decision . But, Do you know how many company’s has full time jobs and how many hire OPT candidates. Many students future is unknown. If i go for a full time job, they will see my OPT card which is expired.Its like no OPT no Full time and no Full time no OPT. We are left with no option. It would really great if USICS publish rule and implement from next year at least we can plan accordingly.

    3. While you have a point regarding consultancies not providing the minimum wage for the job profile, there aren’t enough full time jobs out there to suck up the number of masters students that graduate each year. To these folks consultancy is a means of buying some extra time to stay back in the US and work towards eventually getting into a full time job. Generally I’ve noticed the people who leave comments like these are the ones who were in the same boat sometime back, just while you may have crossed that obstacle, it doesn’t entitle you to pass an opinion that seems very selfish and ungrateful towards our kind. Had this not been an Indian immigration forum, would’ve easily mistook you for a white supremacist trump supporter.

  26. Raghu, I have done my Masters in Computer Science, And i have been recruited in to Infosys as a Full time employee once graduated with out a gap. They have applied my H1B this year 2016 and didn’t picked. I need to apply my OPT extension as my OPT will going to end on December 2016. As a Infosys employee. I’m working in the client Site. And i’m working with my lead and manager who are Infosys employees. So will I-983 form applies for me, Please let me know. Its not Employer Vendor Client. Its directly a Client Service by Bunch of Infosys Employees. Your response is very helpful

    1. I have absolutely no idea on what’s going to happen. In fact several students are asking the same with Attorney Murali Bashyam in last few days. You can talk to Infy attorney or Murali. I’m just the messenger, I don’t have answers in this situation.

    2. Hi Venkata,
      I am in the similar situation as you are. I am also in Infosys. Did u find out a way?

  27. Yes. You are good for 17 months extension. But if you want to extend for remaining 7 months, then you need to follow the new steps.

  28. Hi Raghu, Thanks for your video. I am hired through an american consulting company (not a desi consulting). If according to your video I cannot apply for 24 months stem extension, Can I apply for 17 months? I am not sure. Also, Can you share the link where USCIS has mentioned about consulting firms and not being able to apply for STEM through them.
    Thanks again, Srishti

  29. Hello Raghuram
    Thank you for your guidance all this time we really appreciate it.
    I have applied for OPT extension and it pending now, i work for a consulting company,its not an Indian firm but it can be categorised a Consulting Firm. They are not willing to sign i983.

    My OPT ended on May 12 ,how much time i got to join in a University without any status issues ,i intend to withdraw my OPT extension application?

    Later while i am in university can i apply for OPT Extension (documents from previous Masters degree )if i get a full time job while i am in CPT and employer is STEM Extension eligible,i am asking because i read somewhere that its possible to request STEM extension from previous stem degree.


  30. On USCIS website, you can find the following

    My employee needs our E-Verify company ID number so that he can apply for the STEM OPT extension. My company does not have one because we use an employer agent. What should I do?
    A company that uses an E-Verify employer agent does not have a company ID number, but rather, receives a client company ID number from its employer agent. Provide your E-Verify client company ID number to the F-1 student applying for the STEM OPT extension.

    Last Reviewed/Updated:


    What does this mean ? How to fill the form i983 in this case ?

  31. Hi Raghu,

    One of my friend talked to our DSO, the DSO mentioned like this, we can work client location but in the client location must have to be our employer employee who can supervise the student, that means client location 2 employee must be same employer. If this is the case, I work at client location, one of my other colleague work at same client same location , we both from same employer(consulting firm), so can he able to supervise ? or behind there are something else?

    Please let me know ?

  32. Worst case scenario: My employer may not give i983. And I don’t have enough time to get a full time that qualify. My current contract is long term but if I don’t get i983, I will not get OPT extension. So to stay in USA what should be the method? My initial guess is to try for phd or 2nd master’s. Phd will be very tough for me to get admission, so that leaves 2nd master’s. If I do a 2nd master’s then will I be eligible 24 month again? That time I may get a bona fide fulltime, as of now I just don’t have enough time to get a full time. What do you think about this 2nd master’s plan if OPT denied?

      1. Hi Raghu

        Do i have to have the form i 983 signed by someone at client place.There is no employee from my consultancy monitoring me at the client place and i dont think so i can get it signed by my manager at client place.

  33. Its high time that at-least people should start to know that USCIS & DHS started screwing up things for immigrants and its a fight of Immigrants vs Immigrants.
    The people who can find Full time jobs with employers sponsoring H1’s and GC’s would survive without any problems. There are a series of incidents happening recently.

    1. The lastest STEM OPT incident to stop employment through consulting firm arrangements that provide labor for hire.
    2. The recent Issue of consulting firm in Bay area of H1 visa fraud.
    3. I have recently seen so many cases if I-140’s getting rejected for people applying though consulting firms recently.
    4. Recent Port of entry problems for F1 students.

    I am assuming USCIS will be strict in approving H1b and STEM opt and there will be so many rejections for H1b and STEM opt starting this year.

    Its time for people to awake and be serious and pursue Masters seriously by gaining some knowledge rather than completing in 1 year or 1.5 years.

    1. Thumbs Up for your points..

      Americans are always supports immigrants But we people screwed up things with loopholes and took the OPT/OPTexn/H1-B/GC to this situation.

      Till now Consulting firms played off with System , now System is started playing with people who misusing System/rules.

      Everyone is happy and successful to get their non-immigrant/immigrant benefits if we follow rules properly instead of misusing those.

  34. Hello i have applied for OPT extension,20 days ago with 17 month i20 and my regular OPT ended on May 12 2016. My case is pending at USCIS(Status is Case was received) i work for a consulting company, i am expecting a RFE from USCIS for 24 month i20 i know i have to fill i983 and all the stuff but, what are my options here,how do i get my OPT approved

    Does getting into a full time job helps?? any suggestions would help

    FYI- I have 4 yrs in India and 1yr in US experience,no mockery please,someone’s career is at stake.

    Any suggestions might help…

    1. Yes , getting a full time will definitely help, just go apply for one. Only if getting a full time would be that easy, no body would want to get into consulting jobs.

      1. Then what`s the deadline for getting a new full-time position offer ? Is there time window for finding another full-time position that meets all the new stem requirement when the student`s opt already expired now?

  35. Hi Raghu,

    I am currently on my STEM OPT that will expires on May 17th, 2016. I had applied for my 17 month stem OPT extension. My case was received by USCIS on 25th April and i was given a case number. The 17 month STEM OPT is pending right now and is yet to be approved. Meanwhile, I resigned from my full time job 2 days ago .

    I have 2 questions
    1. As per the new rules, how long do i have before i am out of status if i am looking at direct hire for a full time job?

    2. Can i go for a job from a desi consultant now?

    1. Unemployment period – Under this rule, a student may be unemployed for no more than 90 days during his or her initial period of post-completion OPT, and for no more than a total of 150 days for students whose OPT includes a 24-month STEM OPT extension. This provision is finalized as proposed, with minor changes for clarity.

      Desi Consultancy – I can’t advice on that. This is all new and you need to talk to attorney.

  36. Hi Raghu,

    I know you are not a Layer, but please answer my question..I’m working at client location through Desi Consultancy, My work location at different state , So am I not eligible for OPT extension ? and if eligible then what step I have to follow to get eligible, at this moment direct hire is not possible because I have only 2 month left for OPT expire. Please give me suggestion.


    1. Gopi – I have absolutely zero information about the impact of client/consultant and how it’s going to impact you with new STEM OPT Extension rule. I reported what’s posted in the Rule “as-is”. Not many readers were aware of this provision. Your best bet right now is to check with attorney Murali.

  37. Hi Raghu,

    I am full time hadoop develop in TCS and I work for American express project from TCS? Does it create any problem for my opt 24 months extension?

    1. Sorry Anil. this is new to me and you, DSO and employers. I don’t know the answer. Keep following the blog and the site.

    2. Hi Anil,
      I have the same question. I am a TCS employee working for USAA . If you have any information on how this could affect us when we apply for 24 month stem extension please let me know.

  38. This is similar to H1 memo came in 2010 and i think following rules and maintain E-E relationship with your employer then you will be fine..I don’t think there is anything to panic here..

        1. Contact Attorney Murali Bashyam if you have no patience reading complete NEW STEM OPT Rule.

          Please educate yourself by reading documents published for H1-B memo 2010 and New Opt Stem rule.

          Don’t relate each other. If you read complete new OPT STEM Rule. you would know what it is. But I am sure many people doesn’t have patience to read the complete rule and what DHS/USCIS responded to comments in new rule.

          Go through those comments again and understand yourself.

  39. So, does this mean there will no longer be chance for a student to work as a contractor from desi consultancies? Most employers are not ready to sign the i-983. What is the solution.

    1. So, does this mean there will no longer be chance for a student to work as a contractor from desi consultancies? Most employers are not ready to sign the i-983. What is the solution.

      this is my same question as abiram . Someone please respond .

      1. This is similar to H1 memo came in 2010 and i think following rules and maintain E-E relationship with your employer then you will be fine..I don’t think there is anything to panic here..

        1. @Sharma – In this STEM OPT they specifically say, employer signing the plan should be the place of employment and employer. with H1B Memo they did not have that restriction. We have to wait and see how this pans out. Because, DSO would have ZERO clue about employer-Employee, contracts and consulting. This will be come into picture when H1B is processed.

          1. Even in h1b employer must show that they have E-E relationship which is similar to this..I feel employers who follow proper rules won’t get effected by this but this will impact smaller companies less than 50 employees and who don’t practice rules properly.

          2. I took this issue to my DSO . She has no clue about it at all…She said they have meeting next week with SEVIS Representative .

            So have to wait till next week to get clear picture .

  40. Hello Raghu,

    I’m on 17 months extension right now and I would not like to apply for extra 7 months. Do I still need to go through this process ? Or Im good till my 17 months OPT expires?

      1. Hi Venkat,
        If you are already on 17 months extension and not willing to apply for remaining 7 months you are good with the process. The which came into process now is not applicable for you.

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