The Optional Practical Training Extension for STEM Students (STEM OPT) allows certain international college students on F-1 visas to extend their post-completion optional practical training by 24 months. The program applies to a wide range of STEM degrees, but medical students are currently unable to benefit from this opportunity. In the following letter, Niskanen Center’s Cecilia Esterline advocates for the inclusion of MD (Doctor of Medicine) and DO (Doctor of Osteopathic Medicine) programs under the STEM OPT designation.

Sharon Snyder
Unit Chief, Policy and Response Center Unit
Student and Exchange Visitor Program
U.S. Immigration and Customs Enforcement
500 12th Street SW, Stop 5600
Washington, DC 20536-5600

July 31, 2024

RE: Attention: STEM CIP Code Nomination

Dear Unit Chief Snyder:

I write on behalf of the Niskanen Center with nominations for the Department of Homeland Security (DHS) STEM Designated Degree Program list per Federal Register Notice 89 FR 59748.1 The Niskanen Center is a nonprofit public policy organization that advocates for a government that provides social insurance and essential public goods, fosters market competition and innovation, invests in state capacity, and does not impede productive enterprise. We are committed to liberal democracy and an open society that encourages engagement, cooperation, discussion, and learning. While the Niskanen Center continues to encourage bipartisan legislation that can modernize the entirety of the American immigration system, we are grateful for the opportunity to offer suggestions on this topic. 

Since its inception, the STEM OPT program has played a critical role in training and retaining qualified foreign graduates of U.S. universities. The program’s designations reflect a wide breadth of science, technology, engineering, and mathematics courses, yet the current designations unnecessarily block medical graduates from participation. Therefore, we nominate CIP (Classification of Instructional Programs) codes 51.1201 and 51.1901, Medicine (MD) and Osteopathic Medicine/Osteopathy (DO), respectively, for inclusion on the STEM Designated Degree Program list. 

The pool of students likely to benefit from this change would be small: less than 400 non-citizen, non-resident students began MD and DO programs in 2022.2 However, these students represent some of the top medical students in the country and should be priorities for post-graduate retention. 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 on a national level, data also suggests that the international students who successfully enroll in medical school in the U.S. enter with higher undergraduate grade point averages (GPAs) and higher Medical College Admission Test (MCAT) scores than the average matriculant.4 With the U.S. facing an impending physician shortage of 86,000 by 2036,5 we must ensure we do not lose highly qualified, U.S.-trained doctors due to outdated, stagnant policy barriers. 

While we acknowledge that DHS has previously elected not to recognize medical degrees as STEM fields due to the importance of patient care education, a large portion of the medical school curriculum is STEM-focused. At Harvard Medical School, for instance, STEM courses make up around 70 percent of the first two years for research-track students or around 55 percent for clinical-track students.6 At other schools, such as the Washington University School of Medicine in St. Louis, up to 80 percent of the first two years can be spent in STEM courses.7 Medical students typically take their first licensing exam at the end of their second year, and that test almost exclusively covers disciplines that appear on 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 record of permitting programs with blended disciplines to qualify for designation. For example, business administration is not a STEM-designated field of study.9 However, many universities have designed specializations or tracks within Master of Business Administration (MBA) programs to comply with STEM designation requirements, even if the core courses would not typically qualify. For example, the Wharton School MBA program has 21 different majors, nine of which qualify for STEM designation, even though all Wharton MBA students take the same foundational business courses.10 Although business alone does not qualify, those specializations qualify because they offer significant exposure to mathematics, analytics, and other qualifying subject areas. Similarly, medical degrees should qualify for inclusion due to the large proportion of the curriculum dedicated to STEM disciplines. 

Furthermore, many of our closest peers and competitors in higher education, like the United Kingdom, have already designated medical education as a STEM field of study.11 To remain competitive on an international level and to continue attracting the brightest and most promising minds, the U.S. must conduct a meaningful revision of the limiting categorical definitions set over a decade ago.12 

All students must compete to enter highly competitive medical schools and residency slots. Therefore, this change would not give international students any advantage over American students. Instead, this change would rectify a systemic oversight of medicine’s inherent science focus. Though the limited pool of beneficiaries would likely still need sponsorship after completing the STEM OPT period, designating MD and DO programs for STEM OPT would significantly improve our ability to retain the most qualified international students in our country.

Thank you for your consideration and the opportunity to provide input on this matter. If you have any questions or need additional information, please do not hesitate to contact me at cesterline@niskanencenter.org. 

Sincerely, 
Cecilia Esterline 
Immigration Research Analyst 
Niskanen Center

  1.  “​​Update to the Department of Homeland Security STEM Designated Degree Program List”, Federal Register, July 23, 2024. ↩︎
  2. “2022 Entering Class AACOMAS Profile: Applicant and Matriculant Report”, American Association of Colleges of Osteopathic Medicine, 2022.; “Table A-14.3: Race/Ethnicity Responses (Alone and In Combination) of Matriculants to U.S. MD-Granting Medical Schools, 2018-2019 through 2022-2023”, Association of American Medical Colleges, 2022.
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  3. “Applying to Medical School as an International Applicant”, Association of American Medical Colleges; “Medical Schools That Accept International Students (2024)”, International Medical Aid. ↩︎
  4.  See “MCAT Scores and GPAs for Applicants and Matriculants to U.S. MD-Granting Medical Schools by Race/Ethnicity”, Association of American Medical Colleges, 2022 and “AACOMAS Profile: Applicant and Matriculant Report”, American Association of Colleges of Osteopathic Medicine, 2022. ↩︎
  5. “New AAMC Report Shows Continuing Projected Physician Shortage”, Association of American Medical Colleges, March 21, 2024.  ↩︎
  6. “Overview of the MD Curriculum – Pathways & HST”, Harvard Medical School.  ↩︎
  7. “MD Program, Curriculum Phases”, Washington University School of Medicine in St. Louis. ↩︎
  8.  “Step 1 Content Outline and Specifications”, U.S. Medical Licensing Examination (USMLE).; “DHS STEM Designated Degree Program List”, U.S. Department of Homeland Security, July 22, 2024.  ↩︎
  9. “DHS STEM Designated Degree Program List”, U.S. Department of Homeland Security, July 22, 2024. ↩︎
  10. “Majors & Academic Departments”, The Wharton School, University of Pennsylvania. ↩︎
  11. “​​Higher Education in Science, Technology, Engineering and Mathematics (STEM) subjects – Science and Technology Committee”, Parliament. ↩︎
  12. “SOC Policy Committee recommendation to OMB”, U.S. Department of Labor, Bureau of Labor Statistics, August 2012. ↩︎