The Optional Practical Training Extension for STEM Students (STEM OPT) allows certain international college students on F-1 visas to extend their optional practical training for 24 months after graduation. The program applies to a wide range of STEM majors, but medical students cannot currently take advantage of this opportunity. In the following letter, Cecilia Esterline of the Niskanen Center advocates for the inclusion of MD (Doctor of Medicine) and DO (Doctor of Osteopathic Medicine) programs in the STEM OPT designation.
Sharon Snyder
Head of Department, Policy and Response Center
Student and exchange visitor program
U.S. Immigration and Customs Enforcement
500 12th Street SW, stop 5600
Washington, DC 20536-5600
July 31, 2024
Subject: Attention: STEM CIP Code Nomination
Dear Unit Chief Snyder,
I am writing on behalf of the Niskanen Center to submit nominations for the Department of Homeland Security (DHS) list of STEM degree programs pursuant to Federal Register Notice 89 FR 59748.1 The Niskanen Center is a nonprofit public policy organization that advocates for a government that provides social security and essential public goods, encourages market competition and innovation, invests in government capacity, and does not impede productive enterprise. We are committed to a liberal democracy and an open society that encourages engagement, collaboration, discussion, and learning. As the Niskanen Center continues to support bipartisan legislation that can modernize the entire American immigration system, we are grateful for the opportunity to offer suggestions on this issue.
Since its inception, the STEM OPT program has played a critical role in training and retaining qualified foreign graduates from U.S. universities. The program names reflect a wide range of science, technology, engineering, and mathematics courses, but the current names unnecessarily prevent medical graduates from participating. Therefore, we propose Classification of Instructional Programs (CIP) codes 51.1201 and 51.1901, Medicine (MD) and Osteopathic Medicine/Osteopathy (DO), respectively, for inclusion in the list of STEM Designated Degree Programs.
The pool of students likely to benefit from this change would be small: fewer than 400 noncitizen, nonresident students would begin an MD or DO program in 2022.2 However, these students are among the best medical students in the country and should be a priority when pursuing postgraduate training. Fewer than 50 U.S. medical schools accept applications from international students; those that do are among the highest-ranked schools nationwide, including Harvard, John Hopkins, and the Icahn School of Medicine at Mount Sinai.3
Not only do these universities have their own rigorous admissions processes, but nationally, data suggests that international students who successfully enroll in medical school in the United States have higher grade point averages (GPA) and better Medical College Admission Test (MCAT) scores than the average enrollee.4 As the United States faces a physician shortage of 86,000 by 2036,5 We must ensure that we do not lose highly qualified, U.S.-trained physicians due to outdated and stagnant policy hurdles.
Although we acknowledge that DHS has previously chosen not to recognize medical degrees as STEM fields due to the importance of patient care training, a large portion of the medical school curriculum is STEM-oriented. At Harvard Medical School, for example, STEM courses make up about 70 percent of the first two years for students in the research stream or about 55 percent for students in the clinical stream.6 At other schools, such as Washington University School of Medicine in St. Louis, up to 80 percent of the first two years can be spent on STEM subjects.7 Medical students usually take their first admission exam at the end of their second year of study. This exam covers almost exclusively subjects that are included in the STEM designation list, such as pathology, physiology and pharmacology. 8
Although medical school also includes the clinical application of STEM knowledge, DHS already has a track record of approving mixed-discipline programs. Business administration, for example, is not a STEM major.9 However, many universities have developed specializations or degree programs within Master of Business Administration (MBA) programs that meet STEM designation requirements, even if the core courses would not normally qualify. The Wharton School’s MBA program, for example, offers 21 different majors, nine of which qualify for the STEM designation, although all Wharton MBA students take the same core business courses.10 Although business alone is not an option, these specializations are appropriate because they provide significant insight into mathematics, analytics, and other qualifying disciplines. Likewise, medical degrees should be eligible for inclusion due to the large portion of the curriculum devoted to STEM subjects.
In addition, many of our closest colleagues and competitors in higher education, such as the United Kingdom, have already designated medicine as a STEM subject.11 To remain competitive internationally and continue to attract the brightest and most promising minds, the United States must fundamentally revise the restrictive categorical definitions established over a decade ago.12
All students must compete for admission to highly competitive medical schools and residency positions. Therefore, this change would not give foreign students an advantage over American students. Instead, this change would correct a systematic failure of medicine’s inherent science focus. Although the limited pool of beneficiaries would likely still require funding after the STEM OPT period is complete, allocating MD and DO programs to STEM OPT would greatly improve our ability to retain the most qualified foreign students in our country.
Thank you for your attention and the opportunity to comment on this matter. If you have any questions or need further information, please feel free to contact me at [email protected].
Sincerely,
Cecilia Esterline
Immigration Research Analyst
Niskanen Center
