Applying for OPT While an Adjustment of Status Is Pending

Attorney Answer

File the OPT application — it does not put your adjustment application at risk, and its deadline will not wait for your interview to be rescheduled. And on your second question: yes, the restrictions affecting Mali are almost certainly connected to what happened to your interview. There is a specific, named USCIS policy that did exactly that, and a federal court struck it down on June 5, 2026. You are not imagining a connection, and the answer to your question is not that it would be speculative to draw one. Below is the policy, what it did to cases like yours, and where it stands today.

Two separate things happened, and separating them matters. The first is Presidential Proclamation 10998, signed December 16, 2025, which provides that "the entry into the United States of nationals of Mali as immigrants and as nonimmigrants is hereby fully suspended," effective January 1, 2026. By its own scope provision, though, that suspension reaches only nationals who "are outside the United States on the applicable effective date" and who "do not have a valid visa on the applicable effective date." If you were in the United States on January 1, 2026, the proclamation did not suspend your status, your studies, or your right to file anything.

The second is what actually reached your case. On January 1, 2026, USCIS issued Policy Memorandum PM-602-0194, "Hold and Review of USCIS Benefit Applications Filed by Aliens from Additional High-Risk Countries," directing officers to "place a hold on all pending benefit applications" for people covered by Proclamation 10998, expressly "regardless of entry date," and applying to anyone who lists a covered country as country of birth or country of citizenship. Mali is on that list. The memorandum also directed a comprehensive re-review of benefit requests that had already been approved on or after January 20, 2021. An interview descheduled in that window is not a mystery, and it is not something you did. It is what that memorandum instructed.

Now the development that matters most to you. On June 5, 2026, the U.S. District Court for the District of Rhode Island vacated that memorandum in Dorcas International Institute of Rhode Island v. USCIS, No. 1:26-cv-00132-JJM-PAS (D.R.I.), entering final judgment on June 11, 2026. USCIS posted a notice on June 12, 2026 stating that the vacatur "applies agency-wide" and that the memoranda "should be treated as if they are not in effect." The district court denied the government's motion to stay that ruling pending appeal on July 15, 2026. The government's appeal is pending in the First Circuit as No. 26-1703, where its stay motion finished briefing on August 10, 2026 and, as of August 13, 2026, had not been granted. In practical terms: the hold that stalled your case is not in force right now, and USCIS has resumed adjudicating these cases. Because the appeal is live, confirm the posture before you rely on it.

The OPT deadline, with the actual numbers. Under 8 CFR 214.2(f)(11)(i)(B)(2), you may file Form I-765 up to 90 days prior to your program end date and no later than 60 days after your program end date, and you must also file within 30 days of the date your designated school official enters the OPT recommendation into your SEVIS record. All three limits apply at once. That last one is the trap: ask your DSO for the updated Form I-20 with the OPT recommendation only when you are ready to file, because the 30-day clock starts when the recommendation is entered in SEVIS, not when the I-20 reaches you.

On whether OPT can hurt the adjustment case. It does not. They are separate benefit requests, and a pending Form I-485 does not disqualify you from OPT so long as you keep maintaining F-1 status. You do have a second route to work authorization — 8 CFR 274a.12(c)(9) covers "an alien who has filed an application for adjustment of status to lawful permanent resident" — but do not treat it as a safety net that makes the OPT deadline optional. While PM-602-0194 was in force, the only Form I-765 categories excepted from the hold were (c)(8) and limited (c)(11) and (c)(14); the (c)(9) category and the (c)(3)(B) OPT category were both held. That fallback was suspended by the same policy that stalled your interview, which is precisely why the OPT window — which never reopens — should not be missed while waiting on it.

The single most important compliance step: do not leave the United States. Two independent rules make departure the one move that could undo everything. Under 8 CFR 245.2(a)(4)(ii)(A), your departure is deemed an abandonment of your adjustment application unless you were granted advance parole before leaving. And separately, Proclamation 10998 suspends the entry of Mali nationals — the moment you are outside the country you fall within its scope, and advance parole is not a visa and does not exempt you from it. Do not travel abroad, even briefly, without speaking to an immigration attorney first.

What you can do:

1. Ask your designated school official for the updated Form I-20 with the OPT recommendation, and file Form I-765 within 30 days of the SEVIS entry and inside the 90-day/60-day window around your program end date.

2. Keep a full course of study through your program end date. Falling below a full course load without DSO authorization is the ordinary way students lose status, and it is entirely within your control.

3. Check your case status and ask USCIS to reschedule the interview, noting that the hold policy has been vacated. Processing of these cases has resumed.

4. Do not travel outside the United States.

5. Have an immigration attorney confirm the current posture of the First Circuit appeal before relying on the (c)(9) route, and confirm your exact filing dates against your I-20.

⏱ Time limits apply. The post-completion OPT window under 8 CFR 214.2(f)(11)(i)(B)(2) closes 60 days after your program end date and does not reopen, and the 30-day clock from your DSO's SEVIS recommendation runs independently of it. Neither is paused by the litigation or by the descheduling of your interview. Separately, once you complete your course of study and any authorized practical training, 8 CFR 214.2(f)(5)(iv) allows a 60-day period to prepare for departure or to transfer — that is a grace period, not additional work authorization. This answer states the litigation posture as of August 13, 2026; because the appeal is active, verify before acting.