Bachelor's OPT, Then a Master's: Could the Proposed OPT Fee Be Charged $70,000 Twice?

The $140,000 OPT fee headline comes from an alternative DHS only asked about. Here is what the proposed text would charge when you move up a degree level, and what is still unsettled.

Part of our guide to the proposed OPT fee.

Short answer, as of November 1, 2026: as written, the proposed OPT fee for a master's after bachelor's OPT would not charge $70,000 twice. Your school, as the legal payer, would pay $70,000 before your first OPT recommendation and $30,000 before each later one, so master's OPT after fee-paid bachelor's OPT would be a $30,000 "subsequent" recommendation. The $140,000 figure comes from an alternative DHS says it considered: charging the $70,000 again each time you move up a degree level. And if your bachelor's OPT came before any fee existed, as all OPT so far has, the proposal does not say whether master's OPT would cost $70,000 or $30,000. All of it is proposed only: nothing is collected today, and public comments close on 2026-11-09.

Status line (as of 2026-11-01):

• In effect: no OPT fee of any kind. Twelve months of OPT remain available at each higher education level, and I-765 costs are those on USCIS's fee schedule (G-1055, edition 10/26/26).
• Proposed: the DHS/ICE "Optional Practical Training Fees" NPRM, 91 FR 64566 (docket ICEB-2026-0100, RIN 1653-AB01), published 2026-10-08: $70,000 before the initial OPT recommendation and $30,000 before each later one.
• Alternative, not in the proposed text: re-charging the $70,000 for the first OPT at each higher degree level.
• Unresolved (our reading): which amount applies when your first OPT was fee-free.
• Upcoming: comments close 2026-11-09 at 11:59 p.m. ET (more than 4,700 comments as of 2026-11-01; check the Federal Register after that date). Any fee would start only 60 days after a final rule, and none exists.

How the OPT fee for a master's after bachelor's OPT would work

Under the proposal published 2026-10-08, a master's OPT recommendation that follows fee-paid bachelor's OPT would cost your school $30,000, not another $70,000. Proposed 8 CFR 214.13(i) charges $70,000 once, the first time a student is recommended for OPT, and $30,000 before every later recommendation. A second $70,000 exists only as an alternative DHS invited comment on.

The question exists because OPT resets when you move up a level. ICE's practical training page says: "You can apply for 12 months of OPT at each education level." Because the proposed fee is charged per DSO recommendation, not per year or per degree, the real question is how DHS prices that new OPT year.

What the proposed text says about later OPT (as of 2026-11)

All quotations are from the NPRM text on govinfo.

Who pays. The SEVP-certified school is the legal payer and would pay before the DSO enters your recommendation in SEVIS, though DHS says schools "may pass the financial obligation of this proposed fee onto F-1 nonimmigrant students, all students, or employers." See our explainer on who pays the proposed $70,000 OPT fee and our roundup of what universities have said about paying it.

What is the $140,000 OPT scenario?

$140,000 is two initial fees of $70,000, one at the bachelor's level and one at the master's level (the total is our arithmetic). It comes from an alternative described in the NPRM, not from the proposed regulatory text. The passage, verbatim (91 FR 64577):

"DHS has also considered, as an alternative to the approach described above, having the one-time initial fee of $70,000 apply again to any initial period of OPT following the F-1 student's change to a higher educational level (e.g., to a post-bachelor's degree OPT and again to the student's master's degree OPT). DHS welcomes public comments on the rule in its entirety but especially encourages input from the public on this potential alternative."

Is the re-charge alternative part of the proposed rule?

No. The proposed regulatory text, 8 CFR 214.13(i)(1)-(3), charges $70,000 once and $30,000 for each later recommendation. The re-charge appears only in the preamble and the regulatory flexibility analysis, as an option DHS considered and singled out for comment. A final rule could keep the $70,000 / $30,000 structure, adopt the alternative, change the amounts, or never be published.

Three cases side by side: proposed, alternative, unresolved

The table shows what the school would pay under each version. What reaches you depends on your school's policy if a rule is finalized.

What the school would pay (as of 2026-11; amounts from the NPRM, totals are our arithmetic)

Add STEM OPT at the master's level in case 1 and the totals become $130,000 under the proposed text and $170,000 under the alternative; with STEM OPT at both levels, $160,000 and $200,000. Each is school-paid arithmetic on a proposal, not a bill. Our six single-degree STEM OPT fee scenarios cover the paths that stay at one level.

Case 1: Bachelor's OPT, then a master's

Starting a master's ends bachelor's OPT. USCIS says on its OPT page that if you "begin studies at another educational level (for example, you completed a bachelor's degree and are starting a master's program), your authorization to engage in OPT employment will automatically terminate."

Under the proposal, cutting OPT short would not bring the money back: the initial fee "will not be refunded under any circumstances once the F-1 student has been granted the employment authorization document for OPT." The master's recommendation would still be the $30,000 kind under the proposed text, or another $70,000 under the alternative.

Two practical points. First, the $30,000 condition in (i)(2) turns on your history, not on the same school having paid (our reading); the NPRM does not say how a new school would confirm a fee an earlier school paid. Second, a second master's is different. SEVP's SEVIS Help Hub OPT guidance lets a student split the 12 months between two programs at the same level when the split is noted in SEVIS, and adds: "If you initially request 12 months of OPT based on one degree program, the student will be unable to later request OPT based on a different degree program at the same education level." No new OPT time means no new recommendation and no new fee; a planned split would create a second, later recommendation, which reads as $30,000 under the proposed text (our reading). For the lottery and cost side of that choice, see our guide to deciding on a second master's degree for sponsorship, and confirm OPT eligibility for any same-level degree with your DSO first.

Case 2: Master's OPT, then a PhD

A doctorate is a higher level, so OPT is available again. The SEVIS Help Hub says "Twelve months of Regular OPT is available for each higher level of study." Under the proposed text, doctoral OPT after fee-paid master's OPT would be a later recommendation at $30,000. Under the alternative, it would be a fresh $70,000.

Three PhD-specific wrinkles:

• CPT can remove doctoral OPT entirely. ICE says 12 months or more of full-time CPT makes you ineligible for OPT, and the Help Hub adds that "CPT at another program level does not affect OPT." No doctoral OPT recommendation means no fee.
• A second STEM OPT extension is possible. USCIS's STEM OPT page says a student who earns "another qualifying STEM degree at a higher educational level" may be eligible for "one additional 24-month STEM OPT extension," which would be another $30,000 recommendation under the proposed text.
• Your program end date sets the timing. Our guide to starting a PhD or another degree while on OPT covers what ends and what carries over.

Case 3: Your first OPT came before any fee

This is where today's master's students sit: bachelor's OPT already used, with no fee because no rule existed. The NPRM confirms the later request is covered: "if the F-1 nonimmigrant student submits a subsequent request for OPT on or after the effective date of the final rule, the fee provisions as outlined in this proposed rule will apply" (91 FR 64579). It does not say which fee.

• Reading A, $30,000: it is a later recommendation for someone who has "previously participated in OPT," and (i)(1) reserves the $70,000 for "the first time."
• Reading B, $70,000: (i)(2) gives the $30,000 rate only to a student who "paid the initial OPT fee of $70,000," and the (i)(3) transition charges $70,000 for each student whose recommendation is dated on or after the effective date.

Both readings are ours; DHS has not answered the question. Here is how the dates line up for one example student whose master's program ends in May 2028:

The 2028 window follows from USCIS's post-completion filing rules: file up to 90 days before you complete your degree, no later than 60 days after, and within 30 days of the DSO recommendation. As proposed, a recommendation dated before an effective date carries no fee, so the recommendation date, not your graduation date, is the one to track. A final rule could set different transition terms.

Does the $30,000 fee apply to OPT after a second degree?

Under the proposed text, yes, when the second degree is at a higher level and the $70,000 was already paid for you. A same-level second degree usually adds no new OPT time, so there is nothing new to price; case 3, a fee-free first OPT, is the open question.

Watch for conflicting summaries. SEVP's Broadcast Message 2610-02 (2026-10-08) calls the $30,000 a charge "for the second year of practical training," and a Study in the States summary (2026-10-07) added "no additional fees in subsequent years." The Federal Register text controls: $30,000 before each later recommendation.

What you can do before November 9

1. Find your OPT history on your earlier Forms I-20 (the employment section shows each DSO recommendation and its dates) and on your EAD cards, and note the education level of each.
2. Ask your DSO how SEVIS lists each of your program levels, and whether your school has said how it would handle the fee if a rule is finalized.
3. Read the alternatives passage (91 FR 64577) on the Federal Register page for the NPRM, then submit a comment, if you choose to, through that page's comment link (docket ICEB-2026-0100) by 11:59 p.m. ET on 2026-11-09; regulations.gov shows the same deadline in UTC as November 10. If the re-charge alternative or the fee-free-first-OPT question affects you, describe your own facts. Our November 2026 comment-deadline guide covers the mechanics.
4. Watch the Federal Register for a final rule. As proposed, no fee applies to any recommendation until a final rule is published and 60 days pass.
5. Talk to your DSO about OPT eligibility and SEVIS, and to a licensed immigration attorney before changing degree or status plans because of a proposal.

Common mistakes

• Reporting $140,000 as the rule. It is arithmetic on an alternative; the proposed text prices master's OPT after fee-paid bachelor's OPT at $30,000.
• Saying students pay $70,000. The school is the legal payer and may pass the cost on; no school policy is final because no rule is.
• Assuming a second master's brings a new OPT year. Once 12 months were requested on one program, SEVP's guidance rules out OPT on a different program at the same level; only a split noted in SEVIS shares the year.
• Assuming fee-free bachelor's OPT settles the master's fee. The NPRM covers that later request but does not say whether it costs $70,000 or $30,000.
• Trusting "second year" summaries. BCM 2610-02 conflicts with the Federal Register text, which charges $30,000 for each later recommendation.
• Treating a cut-short OPT as refundable. Under the proposal, once the EAD is issued the fee is not refunded "under any circumstances."

Frequently asked questions

Would the $70,000 OPT fee be charged again for a master's degree?

Not under the proposed text published on 2026-10-08, which has the school pay $70,000 before a student's first OPT recommendation and $30,000 before each later one, so master's OPT after fee-paid bachelor's OPT would cost the school $30,000. A second $70,000 appears only in an alternative DHS asked for comments on. If your bachelor's OPT came before any fee, the NPRM does not say whether $70,000 or $30,000 would apply. Nothing is charged today.

What is the $140,000 OPT scenario?

It is two initial fees of $70,000, one for bachelor's OPT and one for master's OPT, under an alternative in the NPRM that would charge the one-time fee again at each higher degree level (the total is our arithmetic). It is not in the proposed regulatory text, and the school, not the student, is the legal payer.

Does the $30,000 fee apply to OPT after a second degree?

Under the proposed text, yes, if the second degree is at a higher level and the $70,000 was already paid for you; the $30,000 covers any later OPT, STEM OPT included. A second degree at the same level usually adds no new OPT time under SEVP guidance, so there is usually nothing new to price.

Is the re-charge alternative part of the proposed rule?

No. It appears in the NPRM's preamble (91 FR 64577) and regulatory flexibility analysis as an alternative DHS considered and especially wants input on, while the proposed regulatory text charges $70,000 once and $30,000 for each later recommendation. Comments close on 2026-11-09, and a final rule could keep that structure, adopt the alternative or change course.

Does this affect PhD students who had master's OPT?

Potentially. Doctoral OPT after fee-paid master's OPT would cost the school $30,000 under the proposed text, or a second $70,000 under the alternative. If the master's OPT was fee-free because it predates any rule, the NPRM does not settle which amount would apply; ask your DSO how your SEVIS record shows each level.

Sources

• Federal Register, Optional Practical Training Fees (proposed rule, 2026-10-08)
• GovInfo, full NPRM text, 91 FR 64566
• ICE, Practical Training
• Study in the States, SEVIS Help Hub, F-1 Optional Practical Training
• USCIS, Optional Practical Training (OPT) for F-1 Students
• USCIS, STEM OPT extension
• SEVP, Broadcast Message 2610-02

How we checked this: on 2026-11-01 we read the proposed regulatory text and preamble of 91 FR 64566 on GovInfo, SEVP Broadcast Message 2610-02, and the ICE, USCIS and SEVIS Help Hub OPT pages. The comment count comes from the Federal Register's record for the NPRM on the same date.

This is general information, not legal or tax advice; your own I-20, EAD and SEVIS record, read with your DSO or a licensed immigration attorney, govern over anything published here.

If you are planning a degree path around OPT and an eventual H-1B, F1Jobs helps international candidates focus their search on employers that sponsor.