Before posting shifts for OPT students, check the applicable authorization documents, extension dates, decision status, and Supplement B record.
Key takeaways
- Review the expired EAD and endorsed Form I-20 together for the applicable extension case.
- Record the pending STEM application's filing date and track its decision status.
- Keep the pending STEM deadline separate from the cap-gap entry.
- Review acceptable authorization evidence before completing Supplement B.
- Keep the scheduling review and reverification record together.
Why OPT dates matter when you post shifts
A posted shift is only as current as the work authorization behind it. An F-1 student on OPT can have an expired card, a pending extension, or a cap-gap situation while the schedule is being built, so the dates need to sit beside the roster rather than in a folder nobody opens. Start with the OPT EAD and the Form I-20 for the document checks below.
Timing drives most of these rules. The cap-gap wording covers a student whose F-1 status and employment authorization have been automatically extended after a timely filed H-1B change of status petition, according to U.S. Citizenship and Immigration Services, so ask the student for the filing and expiry dates before the schedule goes out.
Your role is to check and record documents, not to decide any one student's status. The job is to read the rules, collect the papers, and write down what you reviewed. When a student's situation is unclear, send the question to the person who handles that student's immigration paperwork instead of guessing from a card.
Put the EAD expiry date, any cap-gap or pending STEM filing date, plus the applicable pending STEM deadline in one line for each student. A single record keeps the schedule and the paperwork in step, and it gives the next person the same facts you used. Keep the line short enough to read in a few seconds.
Review that line before any schedule change that adds hours or moves the student into a new posting week. That is the moment when an expired card or a pending decision matters most, so treat the review as a gate rather than a reminder. For the wider roster review, see schedule change approval checks.
Before you schedule: which documents count
Start by sorting the documents in the student's file. Keep the OPT EAD, Form I-20 and Form I-94 distinct rather than treating any stack of documents as proof. Read each card and endorsement on its own terms before you enter the student on a shift.
Form I-94 needs particular care. When an H-1B employee requires reverification, that employee may choose to present Form I-94, since only a List A or List C document is required for reverification, according to U.S. Citizenship and Immigration Services. That rule is about H-1B employees, so the F-1 OPT rule is separate and is covered in the checks below.
The table below identifies the guidance used for the document and form checks.
| Publisher | Source page | Review topic |
|---|---|---|
| U.S. Citizenship and Immigration Services | Questions and Answers page | Authorization evidence for F-1 students seeking OPT, STEM OPT extension, or off-campus employment based on severe economic hardship |
| E-Verify | Employee Rights and Responsibilities page | Recording reverification on Supplement B |
| U.S. Department of Justice | Civil Rights Division IER FAQs page | Protection against unfair documentary practices |
Keep copies of the documents you reviewed and write down the date you reviewed them. A log of this kind is an editorial recommendation, separate from the quoted rules. A dated copy lets you answer a later question from the file instead of from memory.
Do not confuse a document check with a Form I-9 entry, and ask only for the documents the rules allow rather than extra papers the situation does not call for. Each check below names the document it relies on, so review the applicable document combination.
Check 1: cap-gap and the expired EAD
The first check covers a student whose OPT EAD has expired while cap-gap applies. An expired OPT EAD together with an endorsed Form I-20 is considered an acceptable List A document for a student participating in OPT whose F-1 status and employment authorization have been automatically extended as a result of a timely filed H-1B change of status petition, according to U.S. Citizenship and Immigration Services, so the endorsement is the detail to confirm.
Your first action is to confirm that the Form I-20 carries an endorsement and that the expired card is the EAD the student holds. Do not rely on the expired card alone, because the acceptance depends on the endorsed Form I-20 in this case.
Note the date you reviewed the EAD and the Form I-20 beside the cap-gap entry. The case rests on a timely filed H-1B change of status petition, so ask the student which petition that refers to rather than guessing from the card.
Keep the cap-gap check separate from the STEM check below, even when one student has both situations in the file. Record each situation separately. Writing the reason for each acceptance beside its date keeps the file easy to audit.
Recheck the cap-gap entry whenever the student's dates change or before you add hours. That is an editorial recommendation, separate from the quoted wording, and it keeps the note matched to the current card.
Check 2: a pending STEM extension
If a student files the STEM OPT extension application on time and the OPT period expires while the application is pending, employment authorization is automatically extended for 180 days, according to U.S. Citizenship and Immigration Services, so that automatic extension is separate from the cap-gap case above.
An expired OPT EAD with an endorsed Form I-20 is also an acceptable List A document for the F-1 OPT student with a pending STEM extension application, according to U.S. Citizenship and Immigration Services. Use that line when the file shows a pending application.
Confirm that the filing was made on time before you rely on that line. Record the filing date and ask the student for proof of filing, stored with the EAD and Form I-20 copies.
The automatic extension ceases once USCIS adjudicates the STEM OPT extension application, according to U.S. Citizenship and Immigration Services, so the authorization you rely on can end at a decision. Ask the student to tell you promptly when a decision arrives, and update the file the same day.
Check 3: the pending STEM extension's 180-day limit
For the pending STEM extension, work is authorized until USCIS makes a decision, but not more than 180 days from the initial OPT EAD expiration date, according to U.S. Citizenship and Immigration Services, which sets the outer limit in this wording.
Plan the schedule against the date the wording gives, and do not assume the 180 days restart after a decision.
Compare the applicable authorization deadline with any decision event that ends the pending STEM extension when planning shifts. That is an editorial recommendation, not a rule from the sources.
Review the limit each time you add shifts that run past the current end date, and note which document set that end date. A short note like that lets the next manager see the source without reopening the whole file.
Illustrative example: reviewing the remaining time
Suppose an on-time STEM application is still pending 120 days after the initial EAD expires. Compare the proposed shifts with the 180-day outer limit, then check whether a decision has arrived. The filing date helps document the application, but it is not the date from which you count this limit. Write the review date beside the pending STEM entry and identify the documents reviewed. If the student reports a decision, update that entry before posting more shifts. Keep any cap-gap entry separate so another manager can follow the reason for the scheduling review.
Check 4: Supplement B and what to keep on file
When reverification is required, your employer must complete Supplement B, Reverification and Rehire, of Form I-9, according to E-Verify, so read the form's instructions before you start. The USCIS handbook refers readers to its section on completing Supplement B for more information on reverification, according to U.S. Citizenship and Immigration Services, so read that section too.
For F-1 students seeking OPT, a STEM OPT extension, or off-campus employment based on severe economic hardship, Form I-94 together with Form I-20 does not establish employment authorization for reverification, according to U.S. Citizenship and Immigration Services, so keep that limit in view.
Store the completed Supplement B with the EAD copy, the endorsed Form I-20 copy, and the dates from the earlier checks. Keeping them together means the reverification record and the shift approval tell the same story.
These steps are editorial recommendations and sit apart from the quoted rules above. Recheck the form against the EAD dates whenever the student's authorization changes, and keep the record active while the student remains on staff.
Make sure the person who completes the form and the person who schedules the student can both find it. A shared location with matching dates keeps the paperwork and the schedule in step. For another document review before roster entry, see teen shift eligibility checks.
Next step: check your OPT staff's EAD dates
Check your OPT staff's EAD dates and set a reminder 30 days before each one expires. Take that action before the next schedule goes out, and start with students who have an expired card or a pending STEM filing.
For each student, record the EAD expiry date, whether cap-gap or a STEM filing applies, plus the pending STEM deadline where applicable. Use the same format for every student so the file stays easy to read.
A reminder tells you when to review the file, but it does not decide status, so the review still belongs with the student and the right advisor.
After each review, update the schedule only for students whose dates and documents are current, and hold the others out of posted shifts until their files are complete.
Related guides: Teen closing shifts: 8 checks before posting tonight · Florida training shifts: 3 limits before screening clears · Comp time in Michigan: 6 rules to check before you offer it.
Questions and answers
Does an expired OPT EAD still count?
Yes, when it accompanies the endorsed Form I-20 in either extension case described above. Check the endorsement before you rely on the card, and keep a copy of the endorsed Form I-20 in the file.
How long does the automatic extension last?
The pending STEM extension lasts until a decision or the deadline in check 3, whichever comes first. Plan around the dates in the file rather than assuming a full 180 days.
Can I use Form I-94 and I-20 for OPT reverification?
No, that combination is insufficient for the F-1 situations covered in check 4. Review acceptable authorization evidence and record it on Supplement B; the form does not replace that evidence.
Which form records reverification?
Supplement B records reverification, as described in check 4. Keep the completed form with the student's other records.
What does the Justice Department law protect?
The law protects work-authorized individuals from employment discrimination in hiring, firing, and recruitment or referral for a fee based upon citizenship, immigration status, and national origin, according to U.S. Department of Justice, and it also covers unfair documentary practices when verifying employees' employment eligibility (Form I-9 and E-Verify) and retaliation. Use that protection as a reason to ask only for the documents the rules allow. Read the wording closely before you request any document from a student.
Does the 180-day limit restart after a decision?
No, the pending STEM deadline stays tied to the initial OPT EAD expiration date. Keep the calendar entry tied to the expiration date on the card.