The U.S. Department of Labor (DOL) announced it will publish a final rule to amend wage obligations for the H-1B, H-1B1 and E-3 specialty occupation visa classifications and for permanent labor certifications (PERMs).

Key Points:

  • DOL posted an advance copy of the rule on its website and will officially publish the rule in the Federal Register in the coming days.
  • The new regulation includes a transition period under which the new wage thresholds will not be applied until July 1, 2021, and will be implemented for different categories in a phased approach.
  • The new regulation is scheduled to take effect 60 days after it is published. The incoming administration has indicated that it plans to delay or halt Trump administration regulations that have not taken effect by the time President-elect Joe Biden takes office on Jan. 20.

Background: The agency previously 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. A federal court struck down the IFR, finding that it did not go through proper rulemaking procedures, and the agency stopped applying it in compliance with the court order. The new regulation makes changes to the IFR, including revised wage levels, a transition period that begins July 1, and a phased adoption of the new wage levels.

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.

 

Acting Secretary of Homeland Security Chad Wolf announced his resignation Monday.

Key Points:

  • Wolf cited “court rulings regarding the validity of my authority,” among other factors, as his reason for stepping down. He said that FEMA Administrator Pete Gaynor would fill in as acting secretary pending confirmation of a permanent replacement.
  • Wolf resigned with little more than a week before President-elect Joe Biden will take office. Biden announced in December that he would nominate Alejandro Mayorkas, a former Obama administration official, to lead DHS. Mayorkas’ appointment is subject to Senate confirmation.

Background: Wolf took over as acting secretary in November 2019, but did not go through the Senate confirmation process because he was not initially nominated to the cabinet-level position. A Government Accountability Office report subsequently found that Wolf’s appointment as acting secretary was unlawful in violation of agency succession rules. A number of lawsuits challenged DHS regulations, memoranda and other policies that were issued during his tenure, and a number of courts concluded that he had been appointed improperly. Eventually, President Trump formally nominated Wolf as Secretary of Homeland Security; the president withdrew the nomination last week.

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 posted the H-1B regulation that would replace the annual H-1B lottery for cap-subject petitions with a wage-based selection process. The final regulation is expected to be published tomorrow.

Key Points:

  • The final regulation is scheduled to be published in the Federal Register on Jan. 8 with a 60-day delayed effective date (March 9).
  • The incoming Biden administration has indicated that it plans to delay or halt Trump administration regulations that have not taken effect by Inauguration Day on Jan. 20.
  • USCIS proposed the regulation on Nov. 2, 2020, and accepted comments from the public for a 30-day period.

Additional Information: BAL is closely following the final regulation and will provide additional updates and analysis 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 said it will extend until March 31 its policy of granting consular officers greater leeway to waive some interview requirements.

Key Points:

  • Between now and March 31, consular officers will continue to have the authority to waive interviews for nonimmigrant visa applicants who are applying in the same visa classification and whose previous visas expired within the past 24 months. Normally only applicants whose visas expired in the past 12 months are eligible for a waiver.
  • Waivers will be granted at the discretion of the consular officer, meaning even some who meet the criteria may be required to complete an interview. Waivers are not available to applicants who never had a U.S. visa, who had a valid visa but for another classification, or whose visas expired more than 24 months ago.
  • The State Department began a phased resumption of routine visa services at U.S. consulates in July. Some consulates remain closed to all but emergency appointments, however, and others are offering reduced services because of COVID-19. The State Department encouraged applicants to review the websites of the nearest U.S. embassy or consulate for up-to-date information on what services are available and for instructions, if applicable, on how to apply for a visa without doing an interview.

Background: The State Department first implemented its expanded interview waiver policy in August in effort to limit the number of in-person visits and limit the spread of the COVID-19 virus.

BAL Analysis: While the expansion of the interview waiver benefits some applicants, the impact will likely continue to be limited both because consular officers retain discretion to require an interview and because of limited visa services because of the COVID-19 pandemic. BAL continues to monitor the administration’s response to the pandemic 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.

U.S. Citizenship and Immigration Services (USCIS) has extended the filing period for those applying for permanent residency under the Liberian Refugee Immigration Fairness program. The filing period had been set to expire Dec. 20, 2020.

Key Points:

  • Applicants filing for adjustment of status under the program now have until Dec. 20, 2021. Applications must be received by USCIS by that date.
  • Eligible applicants may also apply for an Employment Authorization Document at the same time or after they file their adjustment-of-status application.
  • More information is available on USCIS’ LRIF webpage and its special instructions for LRIF applicants.

Background: In 2018, President Trump moved to terminate the Deferred Enforced Departure program for Liberia, and extended the wind-down period a number of times, most recently until Jan. 10, 2021. The Liberian Refugee Immigration Fairness program, enacted on Dec. 20, 2019 under the National Defense Authorization law, allows certain Liberian nationals and eligible spouses and children to apply for green cards if they have been “continually physically present” in the U.S. since Nov. 20, 2014 and meet other eligibility criteria.

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 Donald Trump has extended immigrant and nonimmigrant work visa bans through March 31, 2021. The bans had been set to expire Dec. 31, 2020.

Key Points:

  • Under the extension, the government will continue to bar entry to most immigrant visa applicants who are outside the United States.
  • The government will also continue to bar entry to most new nonimmigrant visa holders under the H-1B, L-1, H-2B, and J-1 visa categories and derivative family members.
  • U.S. lawful permanent residents, spouses and children of U.S. citizens, current visa holders, individuals whose entry would be in the national interest and a limited number of others are exempt from the restrictions.

Background: On April 22, President Trump issued the initial proclamation to temporarily suspend the entry of most immigrant visa applicants because of the COVID-19 pandemic. On June 22, Trump issued a second proclamation, extending the immigrant visa ban and imposing the nonimmigrant visa ban as well.

BAL Analysis: BAL continues to monitor COVID-19 entry and travel restrictions and will provide updates as additional information becomes available.

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

Copyright © 2020 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 Trump administration has yet to indicate whether it will extend immigrant and nonimmigrant entry restrictions that were put in place because of the COVID-19 pandemic.

Key Points:

  • On April 22, President Trump issued a proclamation that temporarily suspended the entry of most immigrant visa applicants.
  • On June 22, Trump issued a second proclamation, extending the immigrant visa ban until Dec. 31 and suspending the entry of new nonimmigrant visa holders under the H-1B, L-1, H-2B and J-1 visa categories and derivative family members. The nonimmigrant visa restrictions were also left in place until Dec. 31.
  • The administration had issued no statement on a possible extension of the bans as of 5 p.m. EST today.

BAL Analysis: While the immigrant and nonimmigrant entry restrictions are set to expire today, it remains possible that the Trump administration may extend or reimpose the restrictions. BAL continues to monitor COVID-19 entry and travel restrictions and will provide updates as additional information becomes available.

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

Copyright © 2020 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 imposed a new COVID-19 testing requirement for people traveling from the United Kingdom. This new requirement is in addition to the existing physical presence ban limiting travel from the U.K.

Key Points:

  • Anyone two years or older traveling from the U.K., including U.S. citizens and lawful permanent residents, must take a COVID-19 test within three days before travel and must present documentation of negative test results to their airline before departure. The requirement took effect at 7:01 p.m. EST on Sunday, Dec. 27.
  • The requirement does not apply to people traveling from a third country with a layover of less than 24 hours in the U.K.; it does apply to people whose travel originates in the U.K. but who have a layover in a third country before arriving in the U.S.
  • Travelers who have tested positive for COVID-19 in the past three months do not need to be tested again if they (1) have documentation of the positive test and (2) have met the criteria to end isolation, as confirmed in a letter from their doctor or health department clearing them for travel.

Background: The testing requirement was imposed amid an outbreak of a new variant of the COVID-19 virus in the U.K. The U.S. had already banned most travel from the U.K. under a Presidential Proclamation issued on March 14. That ban remains in effect, but includes exemptions for U.S. citizens, lawful permanent residents, foreign national spouses of U.S. citizens or lawful permanent residents and a limited number of others. While the U.S. has imposed a number of similar “physical presence” bans (including on travel from BrazilChina, IranIreland and any of the 26 Schengen Area countries), this marks the first time that officials have implemented a testing requirement for those who are permitted to travel to the U.S.

Additional Information: An FAQ on the new testing requirement is available on this CDC web page. A public inspection notice is scheduled for publication in the Federal Register on Dec. 31. BAL will continue to monitor the U.S. government’s response to COVID-19 and will provide updates on important 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 © 2020 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.

Immigration and Customs Enforcement (ICE) announced today that will extend certain flexible Form I-9 procedures for employers operating remotely because of the COVID-19 national emergency for an additional 30 days.

Key Points:

  • The temporary measures, which were set to expire Dec. 31, have now been extended until Jan. 31, 2021.
  • The guidance allows employers who are operating 100% remotely because of COVID-19 to conduct verification of employee documents virtually, e.g., using fax, email or video link, for the purpose of Form I-9 employment eligibility verification procedures.
  • Employers that follow the virtual procedures must comply with guidelines when “normal operations resume,” including conducting physical inspection of documents that were viewed remotely within three business days.
  • Employers should consult the original March 20 ICE news release for information on how to obtain, remotely inspect and retain copies of identity and employment eligibility documents to complete Section 2 of Form I-9.
  • Employers are required to monitor the DHS and ICE websites for updates about when the extensions will end and normal operations will resume.

Background: ICE introduced the temporary measures on March 20 for an initial 60-day period and has extended them in monthly increments since then.

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

Copyright © 2020 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 State Department has released the January Visa Bulletin and U.S. Citizenship and Immigration Services has confirmed that adjustment-of-status applicants must use the Final Action Dates chart to determine filing eligibility in January. Following rapid advancements in October and the use of the Filing Dates chart from October to December, the switch to the Final Action Dates chart in January means that priority-date cutoffs for key employment-based categories will retrogress sharply next month.

Key Movements:

EB-1

  • China and India EB-1 will retrogress 14 months to Sept. 1, 2019.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will retrogress four months to June 1, 2016.
  • India EB-2 will retrogress 19 months to Oct. 8, 2009.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will retrogress five and a half months to Dec. 15, 2017.
  • India EB-3 will retrogress nearly four years to March 22, 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 Sept. 1, 2019 Current Sept. 1, 2019 Current Current
EB-2 Current June 1, 2016 Current Oct. 8, 2009 Current Current
EB-3 Current Dec. 15, 2017 Current Mar. 22, 2010 Current Current

BAL Analysis: Since the Final Action Dates will be used in January, most adjustment-of-status applicants in backlogged categories who are eligible to file in December will no longer be eligible to file new applications in January, but the change will not adversely affect applications that have been filed in December. Applicants should continue to work with their BAL professional to complete their applications in a timely manner.

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

Copyright © 2020 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.