Priority-date cutoffs will advance significantly in key employment-based categories next month, according to the State Department’s June Visa Bulletin.

Key Movements in Final Action Dates in June: 

EB-1

  • All countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance five months to May 1, 2017.
  • India EB-2 will advance four months Dec. 1, 2010.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will advance three and a half months to Sept. 1, 2018.
  • India EB-3 will advance nine months to Nov. 1, 2011.
  • All other countries under EB-3 will remain current.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China El Salvador Guatemala Honduras India Mexico Philippines Vietnam
EB-1 Current Current Current Current Current Current Current
EB-2 Current May 1, 2017 Current Dec. 1, 2010 Current Current Current
EB-3 Current Sept. 1, 2018 Current Nov. 1, 2011 Current Current Current

The State Department also released its Dates for Filing chart for June. Applicants seeking to file for adjustment of status are reminded that the chart does not take effect unless U.S. Citizenship and Immigration Services confirms that it does via a web posting after the Visa Bulletin is released.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

 

BAL submitted a comment this week in response to the U.S. Citizenship and Immigration Services (USCIS) request for ideas on how to improve access to immigration services and benefits.

USCIS published its Request for Public Input last month as part of its implementation of President Biden’s Feb. 2 Executive Order on legal immigration. In response, BAL recommended actions to reduce barriers and restore faith in the legal immigration system, including:

  • Resuming the prior USCIS policy of waiving most employment-based green card interviews;
  • Reducing green card wait times for foreign nationals;
  • Expanding availability of premium processing and automatic work authorization extensions;
  • Transitioning to electronic filing; and
  • Modernizing the Form I-9 process.

BAL also offered suggestions on how USCIS could improve case adjudication, customer service and case assistance processes. BAL’s full comment to USCIS is available here.

BAL Analysis: USCIS has taken a number of positive steps in recent months to improve immigration policies and processes, including its April 27 guidance on deference to prior approvals and its temporary policy to suspend certain biometrics requirements. The Request for Public Input was a welcome opportunity for BAL and other stakeholders to present ideas for additional changes. The comment period closes May 19. BAL will continue to track the Biden administration’s policies on immigration and will provide updates on important developments as they occur.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The White House announced Friday that it would rescind a 2019 proclamation that would have denied immigrant visas to applicants based on their ability to cover health costs. The proclamation, issued by the Trump administration, never took effect because it was blocked in court.

Key Points:

  • The 2019 proclamation would have required immigrant visa applicants to have an approved health insurance policy within 30 days of entering the U.S. or the financial resources to pay for reasonably foreseeable medical costs.
  • In November 2019, a federal court in Oregon issued a temporary restraining order, blocking the implementation of the proclamation days before it was scheduled to take effect. The court subsequently issued an injunction to block implementation for the duration of the lawsuit challenging the proclamation.
  • On Friday, May 14, President Joe Biden issued a proclamation rescinding the 2019 proclamation and directing the relevant cabinet secretaries to issue revised guidance as needed.

BAL Analysis: The revocation of the 2019 proclamation means that immigrant visa applicants will not be subject to additional criteria the Trump administration sought to impose, concerning their ability to pay healthcare expenses. BAL will continue to follow the Biden administration’s policies on immigration and will provide updates on important developments.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) has officially announced the temporary suspension of the biometrics submission requirement for certain Form I-539 applicants. The change takes effect May 17.

Key Points:

  • This suspension will apply to applicants filing Form I-539 requesting:
    • Extension of stay in or change of status to H-4 nonimmigrant status.
    • Extension of stay in or change of status to L-2 nonimmigrant status.
    • Extension of stay in or change of status to E-1 nonimmigrant status.
    • Extension of stay in or change of status to E-2 nonimmigrant status (including E-2C (E-2 CNMI Investor)).
    • Extension of stay in or change of status to E-3 nonimmigrant status (including those selecting E-3D).
  • The temporary suspension will only apply to Form I-539 applications if they are (1) pending as of May 17 and the applicant has not received a biometric services appointment, or (2) filed on or after May 17.
  • Form I-539 applicants who have already received a biometric services appointment notice should attend their scheduled appointment. The agency also said it would retain discretion to request biometrics on a case-by-case basis.
  • The suspension will apply until May 17, 2023, unless extended or revoked by the USCIS director.

Background: USCIS disclosed plans for the new biometrics policy last week in a filing in Edakunni v. Mayorkas.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The Department of Labor (DOL) will delay its regulation to amend wage obligations for certain temporary visa classifications and permanent labor certifications (PERM), according to a pre-publication notice posted Wednesday.

Key Points:

  • The agency will delay the wage rule’s effective date until Nov. 14, 2022, and the beginning of the transition period to higher wages until Jan. 1, 2023. Higher wage requirements had been scheduled to phase in starting July 1, 2021.
  • The rule restructures the wage leveling system by which employers determine required wages under the H-1B, H-1B1 and E-3 nonimmigrant programs and PERM applications.
  • DOL will continue to accept information (including anonymous submissions) from the public on prevailing wage data and methodology until June 1. DOL stated in the notice that the agency will use the information in its review of the rule and “may take additional action as needed, such as potentially engaging in new rulemaking.”
  • The wage rule is subject to ongoing litigation.

Background: The DOL wage rule was originally issued in October 2020 and took effect immediately without notice or a public comment period. It was then struck down by a federal court in December. The Trump administration issued a new version of the rule in January, providing for less dramatic wage increases, a delayed effective date and a phased-in approach to implementing new wage levels. The Biden administration has now delayed the rule again to allow more time to review it. A pre-publication version of the delay rule is available here. The final rule is scheduled for publication in the Federal Register on May 13.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) has withdrawn a proposed regulation that would have significantly expanded biometrics collection.

Key Points:

  • USCIS proposed the regulation in September to expand biometrics collection requirements to any applicant, regardless of age, including U.S. citizen sponsors; require more types of biometrics, including palm prints, iris images and voice recognition, and, in some cases, DNA; and increase frequency of biometrics collection, including continuous screening until an applicant becomes a naturalized U.S. citizen. In addition, under the proposal, biometrics collected by USCIS would have been shared with Customs and Border Protection (CBP) and Immigration and Customs Enforcement (ICE).
  • USCIS withdrew the proposed rule pursuant to President Joe Biden’s Feb. 2 Executive Order 14012 on legal immigration and the administration’s priorities to ease barriers and burdens in the immigration system.
  • DHS will continue to require submission of biometrics where appropriate.

BAL Analysis: The proposed rule would have significantly expanded biometrics collection and, in some cases, may have prolonged processing times. With the withdrawal of the proposed rule, however, current rules regarding biometrics collection remain in place.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The Labor Department has posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing: As of April 30, the department was adjudicating applications filed in October and earlier, conducting audit reviews on applications filed in June and earlier, and reviewing appeals for reconsideration filed in November and earlier.

Average PERM processing times:

  • Adjudication – 221 days.
  • Audit review – 348 days.

PWD Processing: As of April 30, the National Prevailing Wage Center was processing PWD requests filed in November and earlier for H-1B and PERM cases, according to the Labor Department. Redeterminations were being considered on appeals filed in March and earlier for H-1B and PERM cases. Center director reviews were being conducted for H-1B and PERM cases filed in April and earlier.

Average times for issuance of PWDs:

  • H-1B – 145 days (OES), 129 days (non-OES).
  • PERM – 143 days (OES), 126 days (non-OES).

BAL Analysis: BAL’s internal case tracking is consistent with the Labor Department’s published processing times. BAL is seeing approvals for PERM applications filed in October and earlier and is starting to see PWDs for requests filed in November and earlier.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) is finalizing a plan to temporarily suspend the collection of in-person biometrics from certain Form I-539 applicants, according to an agency court filing. The change could take effect as soon as May 17.

Key Points:

  • USCIS disclosed plans for the policy in a filing in Edakunni v. Mayorkas. The agency has not yet made an official announcement, but is expected to provide official details in the coming days.
  • The suspension of the biometrics requirement would apply to H-4, L-2, E-1, E-2 and E-3 categories of Form I-539 applications that are (1) pending as of the effective date if the applicant has not yet received a biometric services appointment notice or (2) filed after the effective date.
  • Applicants who have received a biometric services appointment notice before the effective date would need to fulfill the in-person biometrics requirement.
  • USCIS will retain the right to require biometrics on a case-by-case basis.
  • The suspension is intended to automatically expire after May 17, 2023, but will be subject to revision or by the USCIS director.

BAL Analysis: The suspension will ease the Form I-539 application process and could improve overall processing times. Applicants are reminded, however, that the suspension has not yet taken effect, nor has it been detailed in a formal USCIS announcement. Applicants must attend their scheduled biometrics appointments. Even after the new policy takes effect, applicants who have already received a biometric services appointment notice will be expected to fulfill the biometrics requirement. BAL continues to monitor the situation and will provide additional information as it becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The U.S Embassy in Moscow has announced that it would reduce consular services starting May 12 after Russia moved to prohibit U.S. Mission Russia from employing non-Russian nationals.

Key Points:

  • Effective May 12, the U.S. Embassy in Moscow will only offer emergency U.S. citizen services and consular services for “a very limited number of age-out and life or death emergency immigrant visas.”
  • The announcement states that non-immigrant visa processing for non-diplomatic travel will cease for the foreseeable future.
  • The U.S. Embassy in Moscow will not offer routine notarial services, Consular Reports of Birth Abroad, or renewal passport services for the foreseeable future.
  • Residents of Russia who require a new U.S. passport to remain in Russia legally or who need a passport for a demonstrable, life or death emergency should email moscowacs@state.gov to have their request considered.

BAL Analysis: The change will significantly limit U.S. consular services available in Russia, and some applicants may have to apply through an embassy or consulate outside of Russia in order to obtain a visa. BAL will continue to follow developments and will report additional information as it becomes available.

Source: This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The U.S. government has begun enforcing a proclamation banning entry to most foreign nationals traveling from India as nonimmigrants. The White House announced the restrictions on Friday.

Key Points:

  • The ban applies to most foreign nationals who have been physically present in India in the 14 days prior to entering the U.S. as nonimmigrants (i.e., on temporary visas).
  • Officials confirmed in an FAQ that the entry ban does not apply to foreign nationals holding unused, unexpired immigrant visas. It also does not apply to U.S. citizens, lawful permanent residents, the immediate family of citizens and lawful permanent residents, and a limited number of others. The full FAQ is available here.
  • The U.S. State Department said Friday that the same National Interest Exemption (NIE) standards that apply to the U.S.’s other regional travel bans will apply to the India ban as well. The State Department has update the NIE standards a number of times, most recently on April 26.
  • Consular services in India remain limited after consulates announced widespread cancellations.

Background: Besides India, the U.S. continues to bar entry to most foreign nationals who have been physically present in Brazil, China, Iran, Ireland, South Africa, the United Kingdom or the Schengen Area in the 14 days prior to entering the country. U.S. citizens, lawful permanent residents and a limited number of others are exempt. Anyone flying to the U.S., including citizens and lawful permanent residents, must provide documentation of a negative viral COVID-19 test taken within three days of travel or evidence of recovery from a recent COVID-19 infection.

BAL Analysis: BAL continues to urge foreign nationals to consult their BAL professional before planning international travel, as travel restrictions may change with little notice and could affect travelers’ ability to re-enter the U.S. BAL continues to monitor the U.S.’s COVID-19 travel and immigration restrictions and will provide additional information as it becomes available.

Source: This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.