New F-1 Restrictions on Changing Degree Programs and Educational Levels
Important Changes Under DHS's New Fixed-Period Admission Rule
In addition to replacing “Duration of Status” (D/S) with fixed periods of admission, the Department of Homeland Security's new rule makes significant changes to the circumstances in which an F-1 student may change educational objectives or move between degree levels while remaining in F-1 status.
These provisions are particularly important for international students who plan to transfer schools, change majors, or continue from one degree program to another after completing a degree.
Students Generally May Not Change Programs During the First Academic Year
Under the new rule, an F-1 student below the graduate level generally may not change programs or educational objectives during the student's first academic year in a program of study. “Educational objectives” includes changes to the student's program, major, or educational level.
There is an exception when the Student and Exchange Visitor Program (SEVP) authorizes a change because of extenuating circumstances. Examples identified by DHS include circumstances such as a school closure or a school's prolonged inability to provide in-person instruction because of a natural disaster.
This means that an F-1 student generally cannot enter the United States for one bachelor's degree program and then simply switch to a different bachelor's program or educational objective shortly after arrival.
Additional Restrictions for Graduate Students
The rule imposes an even more significant restriction on students pursuing graduate education.
An F-1 student at the graduate level will generally be prohibited from changing programs during the course of the graduate program.
For example, a student who enters F-1 status to pursue a master's degree in Computer Science generally could not use the F-1 change-of-educational-objective provisions to switch to a different graduate program while remaining in F-1 status.
This is a substantial departure from the flexibility that has historically existed for F-1 students to change educational objectives through their DSO and SEVIS record.
Students Generally Can Only Move Up to a Higher Educational Level
The rule also establishes an important restriction on moving between degree levels.
Once an F-1 student has completed a program at one educational level, the student may generally begin another program only at a higher educational level while remaining in F-1 status. The new rule prohibits a student from changing to a program at the same or a lower educational level while remaining in F-1 status.
For example:
Completed ProgramNew Program in F-1 StatusBachelor's degreeMaster's degree — permittedMaster's degreeDoctoral degree — permittedBachelor's degreeAnother bachelor's degree — not permittedMaster's degreeAnother master's degree — not permittedMaster's degreeBachelor's degree — not permitted
The practical effect is that F-1 students will generally need to follow a progression toward a higher educational level, rather than using F-1 status to pursue an additional degree at the same or lower level.
What Does This Mean for Common Student Situations?
The new restrictions could affect several situations that have historically been relatively common.
Changing majors: A student who begins a bachelor's program may not be able to change to a different educational objective during the first academic year, absent an applicable exception.
Changing bachelor's programs: A student who completes one bachelor's degree generally cannot begin a second bachelor's degree while remaining in F-1 status.
Changing master's programs: A student in a graduate-level program generally cannot change programs during the course of that graduate program under the new rule.
Returning for another master's degree: A student who has completed a master's degree generally cannot remain in F-1 status to pursue another master's degree at the same educational level.
Moving from master's to bachelor's: A student who has completed a master's degree generally cannot use F-1 status to pursue a bachelor's degree because the new program would be at a lower educational level.
Moving from bachelor's to master's or master's to doctorate: These traditional upward educational progressions remain permissible, subject to the other requirements for maintaining F-1 status.
School Transfers Are Also Affected
The rule separately addresses school transfers and changes in educational objectives.
An F-1 student seeking to change educational objectives or transfer to another SEVP-certified school must be maintaining F-1 status and satisfy the applicable eligibility requirements. The new rule also generally requires a student changing educational objectives or transferring to complete the first academic year at the school that initially issued the student's Form I-20, unless SEVP authorizes an exception.
This means students should not assume that they can enter the United States, attend a school for only a short period, and then transfer to another institution or change their academic program without additional immigration consequences.
What If a Student Wants to Pursue a Different Program?
Students who want to change their educational plans should speak with their Designated School Official (DSO) before making the change.
Depending on the circumstances, the student may need to:
Complete the required period of study before changing programs;
Remain eligible to maintain F-1 status;
Obtain a new Form I-20;
Update the student's SEVIS record;
Obtain authorization from SEVP if an exception applies; or
Leave the United States and obtain a new F-1 visa and admission for the new educational program.
Students should not assume that a DSO can simply change the student's SEVIS record when the new regulations prohibit the proposed educational change.
Why This Matters
The new restrictions make advance planning particularly important for international students.
Under the traditional D/S framework, an F-1 student's immigration status was closely tied to maintaining a valid SEVIS record and complying with the requirements of the student's program. The new rule adds additional restrictions governing what educational changes an F-1 student may make while remaining in the United States in F-1 status.
At the same time, the new fixed-period admission system means that students will need to pay close attention to the expiration date on their Form I-94 and may need to seek an extension of stay from USCIS in circumstances where they previously could have continued in F-1 status under D/S.
Takeaway for F-1 Students
International students should carefully consider their long-term educational plans before entering the United States or changing programs.
In particular, students should consult with their DSO and immigration counsel before:
Changing majors;
Changing degree programs;
Transferring schools;
Beginning a second degree at the same educational level;
Moving to a lower educational level; or
Changing a graduate-level program.
These changes may no longer be possible simply through a SEVIS transfer or updated Form I-20.
The new rules make it more important than ever for F-1 students to understand both their academic options and the immigration consequences of changing educational objectives.
This alert is provided for general informational purposes only and does not constitute legal advice. The implementation of the new rule may be affected by litigation, agency guidance, or subsequent regulatory changes.
