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

Key Movements in Final Action Dates in April: 

EB-1

  • China EB-1 and India EB-1 will become current after having a date cutoff of Aug. 1, 2020, in March.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance one and a half months to Sept. 1, 2016.
  • India EB-2 will advance three and a half months to May 1, 2010.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will advance five weeks to March 15, 2018.
  • India EB-3 will advance two months to Sept. 1, 2010.
  • 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 Sept. 1, 2016 Current May 1, 2010 Current Current Current
EB-3 Current March 15, 2018 Current Sept. 1, 2010 Current Current Current

The State Department also released its Dates for Filing chart for April. 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 in the coming days.

USICS used Final Action Dates in January, February and March after using Dates for Filing for the first three months of the fiscal year.

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) has posted a pre-publication version of a notice delaying the effective date of the agency’s rule to amend wage obligations for certain visa classifications and permanent labor certifications (PERM). The delay does not change the scheduled phase-in of higher wage obligations beginning July 1, but DOL continues to review whether to delay implementation.

Key Points:

  • The DOL 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 confirmed it will delay the effective date of the rule from March 15 to May 14.
  • Higher wages are scheduled to phase in starting July 1, but the notice states that DOL is reviewing the regulation and is considering whether to propose a further delay of the effective date and accompanying implementation periods. The agency would open a public comment period before further delaying the rule.
  • DOL also indicated it may “issue a request for information soliciting public input on other sources of information and/or methodologies that could be used to inform any new proposal(s) to further amend [prevailing wage] regulations.”
  • The wage regulation is subject to ongoing litigation.

Background: DOL attempted to increase wage obligations for the H-1B, H-1B1 and E-3 categories and PERMs through an Interim Final Rule (IFR) issued on Oct. 8, 2020, that took effect immediately. Federal courts struck down the IFR, finding that it did not go through proper rulemaking procedures, and the agency stopped applying it last fall. DOL published an amended final rule on Jan. 14.

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) released updated guidance late Wednesday confirming that applicants no longer need to provide documentation required under the 2019 public charge rule.

Key Points:

  • USCIS said it would apply the public charge inadmissibility statute consistent with the 1999 Interim Field Guidance.
  • The 2019 rule will not apply to new or pending applications or petitions.
  • USCIS also said that applicants for adjustment of status no longer have to provide the Form I-944, Declaration of Self-Sufficiency, or any evidence or documentation that the form requires.
  • USCIS posted a pre-publication version of a final rule removing the 2019 public charge rule from the regulations.

Background: The USCIS guidance was expected after Secretary of Homeland Security Alejandro Mayorkas issued a statement earlier this week saying the administration would no longer defend the 2019 public charge rule in the multiple court cases challenging it. After the Supreme Court and other federal courts dismissed their appeals, a final court order from the Northern District of Illinois took effect, vacating the rule.

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.

Secretary of Homeland Security Alejandro Mayorkas issued a statement Tuesday that said the administration would no longer defend the 2019 public charge rule in the multiple court cases challenging it.

Key Points:

  • The Justice Department withdrew its appeals in the U.S. Supreme Court and two federal appeals courts in cases involving the public charge rule.
  • As a result of the cases being dismissed, the public charge rule is no longer in effect.
  • Public charge inadmissibility determinations will once again be based on longstanding policies in place before the implementation of the public charge rule.

Background: In announcing the decision to stop defending the public charge rule, Mayorkas said the regulation was “not in keeping with our nation’s values” because it penalized individuals for accessing health benefits and other government services available to them. In November, a federal court in Illinois struck down the rule in its entirety. The government’s move to abandon its appeal of that ruling means that the court’s decision becomes final.

BAL Analysis: The announcement by the Department of Homeland Security that it will return to previous public charge guidelines is welcome news. U.S. Citizenship and Immigration Services is expected to issue guidance confirming that applicants no longer need to provide documentation required under the rule, and DHS is expected to announce additional details regarding its plans for the rule going forward. A full review of public charge actions by DHS and other agencies remains ongoing under an executive order issued by President Joe Biden.

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.

Secretary of Homeland Security Alejandro Mayorkas has designated Venezuela for Temporary Protected Status, according to a notice published in the Federal Register today.

Key Points:

  • The TPS designation runs for 18 months, through Sept. 9, 2022.
  • The 180-day registration period opens today and ends Sept. 5, 2021.
  • Only Venezuelan nationals who have continuously resided in the United States as of March 8, 2021, and have been continuously physically present in the U.S. since March 9, 2021, and who meet other eligibility requirements, may apply for TPS. They may also apply for Employment Authorization Documents (EADs) and for travel authorization.
  • Registration details are available in the Federal Register notice.

Additional Information: Under a Jan. 19 memorandum, Venezuelan nationals residing in the United States may also be eligible for Deferred Enforced Departure (DED) and DED-related employment authorization through July 20, 2022. Individuals who apply for and receive TPS and who are also covered by DED do not need to apply for EADs under both programs. Individuals who believe they are eligible for TPS are encouraged to apply during the registration period, even if they are also covered by DED, in case they do not qualify for late TPS filing once their DED has expired.

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 Feb. 28, the department was adjudicating applications filed in July and earlier, conducting audit reviews on applications filed in March and earlier, and reviewing appeals for reconsideration filed in October and earlier.

Average PERM processing times:

  • Adjudication – 219 days.
  • Audit review – 341 days.

PWD Processing: As of Feb. 28, the National Prevailing Wage Center was processing PWD requests filed in September and earlier for H-1B cases and August and earlier PERM cases, according to the Labor Department. Redeterminations were being considered on appeals filed in January and earlier for H-1B and PERM cases. Center director reviews were being conducted on PERM cases filed in February and earlier. There were no center director reviews pending for H-1B cases.

Average times for issuance of PWDs:

  • H-1B – 147 days (OES), 129 days (non-OES).
  • PERM – 144 days (OES), 117 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 July and earlier and is starting to see PWDs for requests filed in September 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.

United States Citizenship and Immigration Services will open this year’s H-1B electronic registration period at noon EST on Tuesday, March 9. The registration period will close at noon EDT on March 25.

Here is some of the key information for those new to the process or in need of a refresher:

  • Petitioners for cap-subject H-1B visas must submit an electronic registration during the registration period for each prospective H-1B candidate. Petitioners or their representative must submit registrations via a myUSCIS online account and pay a $10 government filing fee for each registration.
  • Registrations cannot be submitted after the March 25 deadline. No priority is given to early submissions.
  • Following the registration period, USCIS will conduct a random lottery of properly submitted registrations if there are more registrations than visas available. The agency intends to send selection notifications via users’ myUSCIS accounts by March 31.
  • Petitioners whose registrations are selected in the lottery will be invited to file full H-1B petitions beginning April 1.

Additional Information: This year marks the second year that USCIS has used the H-1B electronic registration process. Earlier this week, USCIS began allowing H-1B petitioners and registrants to create new myUSCIS online accounts. Those who already had an active H-1B registrant account do not need to create a new one. USCIS will continue to post information about registration on its H-1B Electronic Registration Process website.

BAL Analysis: Employers who do not already have an active H-1B registrant account are encouraged to create one as soon as possible to ensure that any technical issues can be addressed before registration opens. Those with existing accounts are encouraged to log in before the registration period to ensure they have continued access. BAL will continue following developments during the H-1B registration period and will provide updates as information 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. State Department this week moved to tighten the standards for National Interest Exceptions (NIEs) to the U.S.’s entry ban on most travel from Europe.

Key Points:

  • On Tuesday, March 2, the State Department rescinded its previous national interest determination related to Presidential Proclamation 10143, which bans most travel from Ireland, the United Kingdom and any of the Schengen Area countries.
  • Under the previous policy, NIEs were available to certain technical experts and specialists, senior-level managers and executives, treaty traders and investors, professional athletes, and their dependents.
  • The agency announcement states that now, NIEs will only be available for business travel if it is related to providing vital support for critical infrastructure. Consular posts have indicated that they will follow the Department of Homeland Security’s designations of critical infrastructure sectors, and some posts have advised that senior executives and managers traveling to observe operations, hold regular meetings with clients, or for routine operational travel may not be eligible for an exemption.
  • NIE policies remain unchanged for academics, students and journalists and those traveling for humanitarian reasons, public health response or national security.
  • NIEs issued under the previous policy will remain valid.

BAL Analysis: The Department of State announced the new policy on its website and individual consulates have provided guidance, but the official directive from the agency to consular posts is not publicly available. Foreign nationals should consult their BAL professional before planning international travel. COVID-19 physical presence bans remain in effect for Brazil, China, Iran, Ireland, South Africa, the United Kingdom and the Schengen Area countries. Additionally, the work visa ban remains in place and is scheduled to expire on March 31.

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 announced flexible measures today for foreign students affected by delayed receipt notices for Form I-765, Application for Employment Authorization. The measures will apply only to applications received on or after Oct. 1, 2020, through May 1, 2021.

Key Points:

  • Flexibility on 14-month OPT period. USCIS will give F-1 students 14 months from the date of Form I-765 approval to complete their 12 months of post-completion Optional Practical Training (OPT). Normally, students have 14 months from the date of graduation to complete up to 12 months of training. F-1 students requesting post-completion OPT who receive approval of Form I-765 for less than the full amount of time requested because of the delays, can request a correction from USCIS.
  • Refiling following rejection. USCIS will accept a refiled Form I-765 for OPT and STEM OPT if the original application was (1) received within the applicable time frame (Oct. 1, 2020, through May 1, 2021) and (2) USCIS rejected the application. This measure was put in place because some applicants had missed their window to refile because of the delays. More information on refiling following a rejection is available here.
  • Missing or Deficient Signatures. USCIS will issue a Request for Evidence (RFE) rather than a denial if the lockbox accepts a Form I-765 application for OPT or STEM OPT with a missing or deficient signature. Applicants will then be given the opportunity to respond and provide the required signature or correct the deficiency in question.

Background: USCIS has recently reported delays in the issuance of receipt notices for Form I-765 for OPT for F-1 students. The agency says the delays are because of COVID-19 protocols, an increase in certain filings and postal delays, among other factors. The agency said it is implementing the flexible measures to mitigate the impact of the delays on applicants for OPT.

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) will allow H-1B petitioners and registrants to create new myUSCIS online accounts beginning Tuesday, March 2, at noon Eastern Time.

The timeline of key dates in the H-1B registration process is as follows:

  • March 2. Petitioners and registrants can create new H-1B registrant accounts beginning at noon ET. Those with an active H-1B registration account do not need to create a new account.
  • March 9. The H-1B registration period opens at noon Eastern.
  • March 25. The H-1B registration period closes at noon Eastern.
  • March 31.  USCIS intends to send selection notifications via users’ myUSCIS accounts by this date.
  • April 1. Selected registrants can begin filing H-1B cap-subject petitions.

Background: USCIS announced the time line for the H-1B electronic registration period earlier this month. During the registration period, petitioners for cap-subject H-1B visas must submit an electronic registration for each prospective H-1B candidate. Petitioners or their representative must submit registrations via a myUSCIS online account and pay a $10 government filing fee for each registration. Registrations may not be submitted after the March 25 deadline. Following the registration period, USCIS will conduct a random lottery on properly submitted registrations if there are more registrations than visas available. Those who are selected are invited to submit an H-1B cap-subject petition.

BAL Analysis: Employers who do not already have an active H-1B registrant account are encouraged to create one as soon as possible on or after March 2 to ensure that any technical issues can be addressed before registration opens on March 9. Those with existing accounts are encouraged to log in before the registration period to ensure they have continued access.

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.