USCIS has effectively clarified their policy regarding STEM OPT student eligibility at off-site third party placement work locations. The most recent updates from the agency confirm the following policy:
On August 9, 2018 U.S. Citizenship and Immigration Services (USCIS) published a revised final policy memorandum (PDF, 129 KB) related to unlawful presence for F, M, J status holders after considering feedback received during a 30-day public comment period that ended June 11, 2018.
USCIS Current Guidance on STEM OPT Training and Client Sites
USCIS provides on their website that the employer that signs the Form I-983 must be the same entity that provides the practical training experience to the student.
Moreover, the employer that signs the Form I-983 must be the same entity that provides the practical training experience to the student, utilizing its own personnel.
USCIS states that the training experience must take place on-site at the employer’s place of business or worksite(s) to which U.S. Immigration and Customs Enforcement (ICE) has authority to conduct employer site visits to ensure that the employer is meeting program requirements.
Per USCIS: “ICE must always have access to a student’s worksite; if the student is sent to different worksite locations as part of the training opportunity, ICE must be able to access such worksite locations.”