Poets&Quants | Trump Proposes $70K OPT Fee – Plus $30K More For STEM Grads

The Trump administration has formally proposed charging U.S. universities $70,000 for every international student they recommend for Optional Practical Training, the work authorization program that has long connected an American MBA to an American job. And for many MBA graduates, that would be only the first payment.

Under a proposed rule released October 7 by the Department of Homeland Security and published in the Federal Register October 8, schools would pay a second fee of $30,000 each time they recommend the same student for more OPT. The most common trigger would be the 24-month STEM OPT extension, which dozens of business schools have rushed to qualify for in recent years. The $30,000 fee would also apply to a student who used OPT during the program and then needs a separate recommendation for OPT after graduating. An international graduate of a STEM-designated MBA who wants all three years of work authorization would cost the school $100,000. That is the same amount the administration attached to new H-1B petitions last year.
The proposal comes about 10 weeks after The Wall Street Journal reported that DHS was considering a $100,000 OPT fee. Public comments are due November 9.

SCHOOLS, NOT STUDENTS, WOULD PAY – AT LEAST ON PAPER

The H-1B fee falls on employers. The OPT fee would fall on the school. Each institution certified by the Student and Exchange Visitor Program would have to pay before its designated school official could enter an OPT recommendation in SEVIS. U.S. Citizenship and Immigration Services would not grant work authorization to any student whose school had not paid. A school could also simply decline to recommend a student rather than pay.

The fee would be charged per student, not per employer. Under the proposal, a school could ask for a refund only if the student never receives an employment authorization document. Once the document is issued, the money is not returned.

DHS openly acknowledges that schools may not absorb the cost themselves.

“DHS acknowledges that the schools may pass the financial obligation of this proposed fee onto F-1 nonimmigrant students, all students, or employers,” the rule reads.

The agency says it set the amount with the H-1B program in mind. “The fee amount is designed to closely align with the H-1B fees to reduce students and employers from using OPT to circumvent the H-1B visa program fees,” the rule says.

One more detail would hit business schools especially hard. The rule also invites comment on an alternative that would charge the full $70,000 again each time a student moves to a higher degree level. That would affect the many international MBAs who earned a U.S. bachelor’s degree first.

WHAT IT COULD COST TOP B-SCHOOLS

DHS estimates the rule would affect about 2,478 schools and transfer between $8.4 billion and $16.5 billion a year from schools to the federal government. According to the rule, the money would go to the U.S. Treasury rather than to ICE.

For leading MBA programs, the bill would be substantial. Poets&Quants estimates the fee would cost 12 top U.S. business schools about $90 million for a single graduating class, or roughly $128 million if every affected student also took the STEM extension. Because a new class arrives every year, those sums would recur annually.

The estimate starts with each school’s international enrollment for its most recent published class. It then assumes about 55% of those students would use OPT, a rate derived from recent employment reports. At Harvard, 65% of the Class of 2025 sought jobs, 92% of those who took jobs stayed in the U.S. and 17% of the class launched startups. At Stanford, 63% sought jobs and 16% pursued their own ventures. At Wharton, 69% sought jobs and 94% of hires were in the U.S. Students who are company-sponsored, return home or take jobs abroad would not trigger the fee.

Columbia faces the largest single bill: an estimated $15.5 million a year, with about 222 likely OPT users. Harvard follows at $13.4 million. Among the M7, the seven schools combined would owe roughly $68 million per class.

ESTIMATED OPT FEE COST, M7 SCHOOLS

School	Class	Int’l students	Est. OPT users	At $70K	At $100K
Harvard	2027	349	192	$13.4M	$19.2M
Stanford	2027	165	91	$6.4M	$9.1M
Wharton	2027	231	127	$8.9M	$12.7M
Chicago Booth	2027	235	129	$9.0M	$12.9M
Columbia*	2027	403	222	$15.5M	$22.2M
Northwestern Kellogg	2027	198	109	$7.6M	$10.9M
MIT Sloan	2027	189	104	$7.3M	$10.4M
MIT Sloan	2028	203	112	$7.8M	$11.2M
M7 total (Class of 2027)		1,770	974	$68.2M	$97.4M

*Includes students who entered in January

ESTIMATED OPT FEE COST, OTHER TOP MBA PROGRAMS

School	Class	Int’l students	Est. OPT users	At $70K	At $100K
Michigan Ross	2027	152	84	$5.9M	$8.4M
UC-Berkeley Haas	2027	120	66	$4.6M	$6.6M
Cornell Johnson	2027	116	64	$4.5M	$6.4M
UCLA Anderson	2027	107	59	$4.1M	$5.9M
UCLA Anderson	2028	103	57	$4.0M	$5.7M
Dartmouth Tuck	2027	67*	37	$2.6M	$3.7M
Total (Class of 2027)		562	310	$21.7M	$31.0M

*Foreign nationals only; excludes dual citizens and permanent residents

Sources: School class profiles and employment reports; Poets&Quants analysis. Estimates assume 55% of international students use OPT; MBA summer internships, which typically run on Curricular Practical Training, are not counted.

WHY DHS SAYS IT NEEDS THE FEE

DHS gives two main reasons: fraud and protecting American workers. The rule cites a Homeland Security Investigations probe, announced by ICE in May, that found more than 10,000 F-1 students on OPT working for what it calls “highly suspect employers” – a count drawn from just the top 25 OPT employers. The rule says investigators found residential addresses listed as worksites, shell companies, and “phantom employees” who never showed up for work.

The agency also points to the program’s growth. According to the rule, 194,554 students on pre- or post-completion OPT reported working for an employer in 2024, up from 160,627 in 2023. Another 165,524 were on STEM OPT. When DHS expanded STEM OPT in 2016, it projected about 92,000 eligible participants by 2026.

The rule suggests the program itself could be shut down.

“DHS notes that without the fees proposed in this rule, it cannot operate OPT consistent with its focus on preventing fraud and may shut down the program entirely,” the rule reads.

It also says plainly, “The F-1 visa was never intended to provide a pathway to employment in the United States.”

‘A COLLAPSE IN ACCESS TO OPT’

Before the rule was released, economist Michael Clemens predicted in a series of Bluesky posts that the charge would land on universities rather than students. The proposed rule bears him out. Clemens, a professor at Johns Hopkins University’s School of Government & Policy and a non-resident senior fellow at the Peterson Institute for International Economics, also predicted what would happen next.

“Few universities – obviously – will pay,” Clemens writes. “That will mean a collapse in access to OPT.”

That collapse, he argues, would undercut U.S. enrollment itself. Clemens says OPT is “a crucial bridge to remaining by any channel,” and points to research showing that the work bridge is a major reason international students choose the U.S. in the first place.

He also sees the OPT fee as one part of a broader squeeze. For about half of the international students who want to stay, he notes, the H-1B is the next step after OPT, and that path faces its own proposed six-figure fee.

“The combined effect will be to make it practically impossible for most int’l students to stay,” Clemens writes.

A FAMILIAR TARGET FOR B-SCHOOLS

OPT has been in the administration’s sights since Trump’s first term. Poets&Quants has reported for years that the program was in Trump’s crosshairs, even as top business schools added or expanded STEM programs to attract international students.

The STEM push started in earnest in 2018. That year, Rochester Simon became the first business school to win STEM designation for its entire full-time MBA, regardless of specialization. Others followed, including Yale SOM, beginning with its Class of 2026.

In January, P&Q founder John A. Byrne argued in a commentary that OPT is no marginal benefit for international MBAs. He estimated that losing it could cut the lifetime return on an MBA by 40% to 60%.

The H-1B fee was the first big blow. When the administration announced its $100,000 H-1B charge in September 2025, it later clarified that F-1 students changing status from OPT were exempt. That exemption made OPT the main path to an H-1B for international MBAs. A federal court in Massachusetts vacated the H-1B fee in June, and in August DHS proposed a separate rule that would add a $103,265 fee to all initial cap-subject H-1B petitions. The new OPT proposal would put a price on the OPT path too.

A PIPELINE ALREADY UNDER STRAIN

The proposal reaches business schools after a difficult admissions cycle. In February, P&Q reported that several full-time MBA programs saw applications fall 20% to 30% year over year, with international applicants leading the decline.

Data from the Graduate Management Admission Council show the same trend. The share of non-U.S. candidates who said they preferred to study in the United States fell from 57% in January 2025 to 42% by December. New international enrollment across U.S. higher education fell 19% in August 2025, and 45% among students from India, the largest source of students for many MBA programs.

EARLY CLASS OF 2028 NUMBERS: STEADIER SHARES, SMALLER CLASSES

The first Class of 2028 profiles show how that demand slump played out this fall. MIT Sloan’s applications plunge 25% to 4,228. UCLA Anderson receives 2,422 applications and enrolls 287 students, down from 307 a year earlier. Duke Fuqua’s Daytime MBA class shrinks to 359 from 426, its smallest since the pandemic, and Georgetown McDonough enrolls 197 from 1,269 applications, down from 248 students a year earlier.

The international share of those classes tells a more complicated story. Of the four top-25 programs that have released Class of 2028 profiles so far, none reports a lower international share than a year ago. MIT Sloan’s rises to 45% from 42%, Duke’s to 38% from 35% and UCLA’s to 36% from 35%, while Georgetown holds at 44%.

But because three of the four enrolled smaller classes, they also enrolled fewer international students in absolute terms. Only MIT, which held its class at 450, added international students. The two-year view is also less encouraging. Compared with the Class of 2026, three of the four – all but MIT – remain below where they stood two years ago, when Duke and UCLA each drew 41% of their classes from abroad and Georgetown drew 49%.

The OPT fee would add to other recent changes. These include the Cato Institute’s finding that Trump-era policies have cut legal immigration far more than illegal crossings. They also include DHS’s final rule this July that replaced open-ended “duration of status” with fixed admission periods for F-1 students, effective September 15.

INTERNATIONAL STUDENTS AS A SHARE OF THE INCOMING MBA CLASS

School	Class of 2026	Class of 2027	Class of 2028
MIT Sloan*	40%	42%	45%
Duke Fuqua**	41%	35%	38%
UCLA Anderson	41%	35%	36%
Georgetown McDonough	49%	44%	44%

*Includes Leaders for Global Operations dual-degree students
**Excludes dual citizens

Sources: School class profiles; Poets&Quants

WHAT COMES NEXT

NAFSA: Association of International Educators has been briefing its members on the proposed OPT fee rule since it cleared White House review in September.

A legal challenge is likely. Clemens argues the charge is a tax, not a fee, and that DHS has no legal authority to impose it. He lays out the case in a recent RFBerlin paper.

“No law does; it is an illegal action,” he writes, answering his own question of what law would let the government levy such a tax. “That is why the forthcoming proposed rule calls it a ‘fee’, which it certainly is not.”

The Massachusetts court that vacated the H-1B fee used the same reasoning, holding that it functioned as an unauthorized tax. On July 24, the First Circuit declined to let the government resume collecting it while the appeal proceeds. Similar arguments could be raised against the OPT fee.

As proposed, the rule would take effect 60 days after the final version is published. It would apply only going forward. Students already on OPT, already approved, or holding a school recommendation dated before the effective date would not be charged. Any later OPT request filed after that date, including a STEM extension, would trigger the fee.

DON’T MISS TRUMP EFFECT: 40% OF INTERNATIONAL CANDIDATES NOW LESS LIKELY TO STUDY IN THE UNITED STATES

© Copyright 2026 Poets & Quants. All rights reserved. This article may not be republished, rewritten or otherwise distributed without written permission. To reprint or license this article or any content from Poets & Quants, please submit your request HERE.