Maintenance of Status RFEs in Cap Cases is the next challenge. The upcoming H-1B cap season is likely to bring increased scrutiny of maintenance-of-status issues for F-1 students. Due to the devastating $100,000 impact on denials, USCIS may focus more closely on status gaps, OPT timing, cap-gap coverage, CPT history, and SEVIS records when reviewing cap-subject petitions. In this presentation, we discuss why we think this trend is emerging, the common student-related risk areas that could trigger an RFE, and how students and employers can proactively prepare to reduce denial risk.