Priority-date cutoffs will advance modestly in most employment-based categories, according to the State Department’s February Visa Bulletin. USCIS confirmed it will use the Final Action Dates chart for adjustment-of-status applications next month.

Key Movements:

EB-1

  • China EB-1 will advance four months to Jan. 1, 2020.
  • India EB-1 will also advance four months to Jan. 1, 2020.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance two weeks to June 15, 2016.
  • India EB-2 will advance four days to Oct. 12, 2009.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will advance a little more than two weeks to Jan. 1, 2018.
  • India EB-3 will advance nine days to April 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
EB-1 Current Jan. 1, 2020 Current Jan. 1, 2020 Current Current
EB-2 Current June 15, 2016 Current Oct. 12, 2009 Current Current
EB-3 Current Jan. 1, 2018 Current April 1, 2010 Current Current

Additional Information: Priority-date cutoffs advanced dramatically in the October Visa Bulletin, did not change in November and advanced modestly in most categories in December. Priority cutoff dates retrogressed sharply in January following USICS’s switch to the Final Action Dates after it used 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 Labor Department has posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing: As of Dec. 31, the department was adjudicating applications filed in June and earlier, conducting audit reviews on applications filed in February and earlier, and reviewing appeals for reconsideration filed in August and earlier.

Average PERM processing times in December:

  • Adjudication – 175 days.
  • Audit review – 317 days.

PWD Processing: As of Dec. 31, the National Prevailing Wage Center was processing PWD requests filed in July and earlier for H-1B and PERM cases, according to the Labor Department. Redeterminations were being considered on appeals filed in November and earlier for PERM cases and December and earlier for H-1B cases. Center director reviews were being conducted on PERM cases filed in November and earlier. There were no center director reviews pending for H-1B cases.

Average times for issuance of prevailing wage determinations:

  • H-1B – 134 days (OES), 138 days (non-OES).
  • PERM – 130 days (OES), 113 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 June and earlier, and is seeing PWDs for requests filed in July and earlier for H-1B cases and PERM cases.

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.

A limited “H-1B strengthening” final rule that the Department of Homeland Security posted to its website last Friday is expected to be withdrawn in compliance with a memorandum issued by the White House Chief of Staff yesterday.

Key Points:

  • The web posting of the rule has been removed. The rule would have clarified how U.S. Citizenship and Immigration Services determines whether there is an “employer-employee” relationship between the H-1B petitioner and the beneficiary for the purposes of qualifying as a U.S. employer.
  • The regulation was not published in the Federal Register before President Joe Biden took office. The White House memo directs agencies to withdraw regulations that were not published in the Federal Register as of Jan. 20 and to consider delaying regulations that have not yet taken effect by postponing their effective dates by 60 days.
  • The Labor Department also posted guidance last week that would have required certain companies hosting third-party H-1B workers to file Labor Condition Applications, but has withdrawn the guidance.

Background: The rule had a more limited scope than the H-1B Strengthening Interim Final Rule that a court set aside in December.

BAL Analysis: BAL is closely following the Biden administration’s approach to multiple H-1B regulations and will update clients 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.

President Joe Biden assumed the presidency today and is expected to take numerous actions affecting immigration policy his first day in office. Biden will sign a series of executive actions to undo several Trump-era orders and will send a comprehensive immigration reform bill to Congress.

Key executive actions:

  • Freeze on midnight regulations. Biden will issue a memo putting a freeze on any new Trump regulations that have not taken effect and allowing the new administration to review regulations in the works. The memo directs all agencies to confer with the director of the White House Office of Management and Budget before moving forward with any regulations.
  • Repeal the Muslim ban. Biden will sign an executive order repealing two Trump presidential orders that ban entry from a number of Muslim-majority and African countries. The first proclamation, known as the Muslim Ban, bars nationals from Libya, North Korea, Somalia, Syria, Venezuela and Yemen, and was upheld by the Supreme Court in 2018. The second proclamation suspended immigrant and diversity visas for nationals of Eritrea, Kyrgyzstan, Myanmar and Nigeria and suspended diversity visas for nationals of Sudan and Tanzania. Biden’s order will direct the State Department to restart visa processing for the affected countries, including for applicants stuck in the waiver process.
  • Restore DACA. Biden will sign a presidential memo directing the Secretary of Homeland Security, in consultation with the Attorney General, to “preserve and fortify” the Deferred Action for Childhood Arrivals (DACA) program. The memo also calls on Congress to enact legislation providing broader relief by giving those who came to the U.S. as undocumented children a permanent status and path to citizenship.

Key provisions of Biden’s immigration bill:

  • Modernize employment-based visas. The bill proposes several changes to employment-based visas and green cards, including provisions that would eliminate per-country green card caps and clear visa backlogs, make it easier for foreign graduates of U.S. universities with advanced STEM degrees to remain in the U.S., provide H-1B dependents with work authorization, and allow caps on green card to be adjusted according to labor demands.
  • Path to citizenship for undocumented individuals. The bill would create a roadmap to citizenship for undocumented individuals and immediate eligibility for green cards for Dreamers, Temporary Protected Status (TPS) holders and immigrant farmworkers who meet specific requirements.
  • Diversity Visas. The bill would prohibit religious discrimination in travel bans, limit presidential authority to issue future bans, and proposes to increase the number of green cards under the Diversity Visa program from 55,000 to 80,000 per year.
  • Improve employment verification process. The bill would require the Department of Homeland Security and the Department of Labor to establish a commission to improve the employment verification process. It would also include provisions to prevent labor abuses and increase penalties for employers who violate labor laws.

BAL Analysis: President Biden has set out an ambitious immigration agenda on Day 1, and has indicated he will take additional actions in the coming weeks. BAL is closely monitoring the administration’s actions on executive orders, regulatory changes and broader legislative reforms and will continue to provide timely 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.

President Trump issued a presidential proclamation Monday announcing the termination of certain COVID-19 physical presence bans, but the Biden administration has indicated it will keep them in place for the time being.

Key Points:

  • The proclamation states that the travel bans that bar entry to travelers who have been physically present in Brazil, Ireland, the United Kingdom or any of the 26 countries of the Schengen region, will be terminated at 12:01 a.m. EST on Jan. 26.
  • President-elect Joe Biden’s White House Press Secretary, Jen Psaki, immediately responded on Twitter stating that the Biden administration does not intend to lift the travel bans on Jan. 26 and will in fact strengthen public health measures related to international travel.
  • The incoming administration had already indicated that it plans to delay or stop Trump orders and regulations that have not taken effect by the time Biden takes office at noon on Wednesday, Jan. 20.

Background: During the first half of 2020, President Trump imposed a series of “physical presence” bans that bar travelers who have been physically present in Brazil, China, Iran, Ireland, the United Kingdom or the Schengen region within 14 days of seeking to enter the United States. Monday’s proclamation does not cover China or Iran. The U.S. government will also implement a COVID-19 testing requirement for all international air travelers starting Jan. 26.

BAL Analysis: The physical presence travel bans remain in place at this time, and the incoming administration has indicated it will not be lifting them on Jan. 26. BAL is closely monitoring ongoing travel restrictions and the Biden administration’s response to the multiple Trump travel bans and will update clients 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 Department of Homeland Security (DHS) and Department of Labor (DOL) have released last-minute policy changes to the H-1B nonimmigrant program.

Key Points:

  • DHS posted a pre-publication version of a final rule, “Strengthening the H-1B Nonimmigrant Classification Program,” a narrower version of the Interim Final Rule (IFR) that was set aside in court in December.
  • The rule is scheduled to take effect 180 days after publication in the Federal Register.
  • According to the advance copy, the rule amends current regulations “to clarify how U.S. Citizenship and Immigration Services (USCIS) will determine whether there is an ‘employer-employee relationship’ between the petitioner and the beneficiary for the purposes of qualifying as a ‘United States employer.’” The rule does not finalize other provisions from the previous IFR version.
  • DOL issued two guidance documents regarding the obligations of common-law secondary employers of H-1B workers. The guidance is scheduled to take effect July 14.

Additional information: The incoming Biden administration has indicated that it intends to delay any regulations that have not taken effect by Wednesday when President-elect Joe Biden takes office. BAL is closely monitoring developments on H-1B regulations and the new administration’s posture toward midnight regulations and will update clients 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.

U.S. Citizenship and Immigration Services announced today that it will temporarily suspend in-person services next Tuesday and Wednesday to ensure the safety of its employees and individuals with appointments.

  • In-person services will not be available at field offices, asylum offices or application support centers on Jan. 19 and 20.
  • The agency will reschedule appointments that had been scheduled on the two days and send notices to applicants of their new appointment dates.

Additional information: The USCIS website and USCIS Contact Center will remain available for information, case status updates, and other online tools and resources.

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. Immigration and Customs Enforcement (ICE) announced Tuesday that it is creating the Optional Practical Training (OPT) Employment Compliance Unit, a full-time unit dedicated to monitoring and investigating employer and student compliance with OPT and Curricular Practical Training (CPT) programs.

The OPT Employment Compliance Unit will have authority to:

  • Report its findings in annual public reports, including details on the duties, hours and compensation of OPT workers as compared to data from the Labor Department. The first report will be published on ICE.gov by July 31.
  • Recommend investigations of employers and students to the Homeland Security Investigations unit and refer evidence of unlawful practices to appropriate agencies, such as reporting wage violations to the Labor Department and discriminatory hiring practices to the Justice Department.
  • Monitor whether employers are adhering to the attestations and training plans required of OPT-STEM extension programs, including conducting worksite visits to ensure that foreign students are employed under terms and conditions commensurate with those of U.S. workers.

Background: The OPT and CPT programs allow F-1 students to be employed under qualifying training programs for up to 12 months. In 2008, the OPT-STEM extension was introduced allowing eligible students with STEM degrees to extend their one-year OPT program for an additional 17 months. In 2016, a regulation replaced the 17-month OPT-STEM extension with a 24-month OPT-STEM extension.

BAL Analysis: The announcement states that the new unit is intended to ensure that employers are not using OPT programs in a way that harms U.S. workers or foreign student employees. Employers should anticipate greater scrutiny and enforcement of all requirements under OPT, OPT-STEM extension and CPT programs, and are encouraged to review their policies and procedures. BAL can assist in a compliance review and assessment.

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 Homeland Security will extend the ban on nonessential land travel with Canada and Mexico. Prepublication versions of the notices extending the bans were posted today.

Key Points:

  • The restrictions will remain in place until 11:59 p.m. EST on Feb. 21.
  • Only “essential travel” is permitted through land ports of entry along the U.S.-Canada and U.S.-Mexico borders.
  • The list of individuals permitted to engage in “essential travel” includes: U.S. citizens and lawful permanent residents (LPRs) returning to the U.S. and people traveling to work in the U.S. (e.g., agricultural workers), engaging in lawful cross-border trade (e.g., truck drivers transporting goods), or traveling to attend school, receive medical treatment, for public health purposes, or a limited number of other reasons.
  • The restrictions do not apply to air or sea travel, but do apply to passenger rail, passenger ferry travel and pleasure boat travel.

Additional Information: The nonessential travel bans were imposed March 20 because of the COVID-19 pandemic. They were initially in place for 30 days and have since been extended in month-long increments since then.

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 will soon require individuals traveling to the country by air to test negative for the COVID-19 virus.

Key Points:

  • The new CDC requirement will take effect Jan. 26.
  • From that date, anyone traveling to the U.S., including U.S. citizens and lawful permanent residents, will be required to provide (1) documentation of a negative viral COVID-19 test taken within three days of travel or (2) documentation of recovery from a previous COVID-19 infection, including positive test results and a letter from a health care provider or public health official clearing the passenger for travel.
  • Passengers who do not provide the required documentation will not be permitted to board their airplanes. Travelers under the age of two are exempt.
  • The CDC recommends that following arrival, travelers get re-tested within three to five days and remain at home for seven days
  • The testing requirement follows implementation last month of a similar requirement for travelers from the United Kingdom.

Additional Information: The testing requirement will be in addition to “physical presence” bans and other COVID-19 travel restrictions. The physical presence bans bar entry to most travelers who have been in BrazilChinaIranIreland, the United Kingdom or any of the 26 Schengen Area countries in the 14 days before entry. The Trump administration also recently extended the immigrant visa ban and nonimmigrant work-visa ban through March 31, 2021. U.S. citizens, lawful permanent residents, spouses and children of U.S. citizens and a limited number of others are exempt from both the physical presence and work visa bans.

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