A federal court has issued a temporary restraining order against U.S. Citizenship and Immigration Services (USCIS) for delays in printing employment authorization documents (EADs).

Key points:

  • The temporary order requires USCIS to print EADs within seven days for applicants whose EAD applications have been approved but who have not received their cards.
  • The court said that even though USCIS is not bound by a specific timeline for printing EADs, the agency does not have “unfettered discretion to issue EADs at any time they wish.”
  • The order is in effect until the court’s hearing on whether to issue a preliminary injunction on Monday, Aug. 10.

Background: The lawsuit was brought by several applicants who have waited months without receiving their EAD cards following approval of their applications, alleging they will lose their jobs and health insurance, and be unable to find work or support their families without proof of employment authorization. The USCIS Ombudsman recently acknowledged delays in printing EADs, as well as green cards, because USCIS ended a contract with the company that printed them.

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.

U.S. Immigration and Customs Enforcement (ICE) has issued clarifying questions for fall 2020 students, announcing that new and initial students on F and M visas will not be permitted to enter the United States if they attend universities that only offer online courses this fall.

The new policy will not affect the ability of previously enrolled F and M students who have maintained their status to attend universities with fully online coursework. ICE also indicated that F or M students who attend schools with a mix of in-person and online classes should also not be impacted. Additionally, recent graduates in an active SEVIS status will be able to continue to work during their 12-month optional practical training (OPT) period or a STEM OPT extension, if applicable.

Key points:

  • ICE announced on July 24 that nonimmigrant F and M students who obtained their status after March 9 will not be able to enter the United States for the fall term if their coursework is 100% online.
  • ICE has also said that school officials should not issue a Form I-20 to new and initial nonimmigrant students if their coursework is 100% online.
  • F and M students who were enrolled in school on March 9 and who have maintained their status since then may obtain visas, continue their studies and enter the United States whether or not their coursework is 100% online.
  • New and initial students will be permitted to enter the United States and begin their studies if they are at a school that offers classes in person or has a mix of in-person and online coursework.
  • While the changes will impact the ability of new students in online-only instruction programs to obtain practical training authorization (OPT or CPT) for 2021 summer internships, it does not impact the ability of students already in their programs and present in the U.S. to apply for these benefits.

Background: The July 24 announcement followed legal wrangling over ICE’s move earlier last month to bar all F and M students from taking a full online course load this fall. After a number of universities sued over the July policy, ICE backed down and the agency agreed to extend temporary COVID-19 measures implemented in March. These measures allow foreign students to take more online courses than normally permitted because of the COVID-19 pandemic.

BAL Analysis: The change will limit the ability of some new and initial students on F and M visas to come to the United States and enroll in their universities this fall, especially given that a number of schools have announced plans to hold fall semester classes mostly or entirely online. The policy will not affect previously enrolled students who have maintained their status or the ability of previously enrolled students to obtain practical training authorization. A number of questions remain unanswered, including whether the State Department will issue visas to new students who have already been issued a valid Form I-20. BAL continues to monitor the administration’s response to the COVID-19 pandemic and will provide updates on key developments 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 © 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.

President Donald Trump signed an executive order today aimed at reviewing the hiring practices of federal contractors.

Key points:

  • The order states that it is the policy of the executive branch to create opportunities for U.S. workers to compete for jobs, including jobs created through federal contracts.
  • It requires federal agencies to assess whether their contractors’ use of temporary foreign labor or offshoring practices have affected opportunities for U.S. workers.
  • The order also directs the Department of Homeland Security (DHS) and Labor Department (DOL) to, within 45 days, “take action, as appropriate and consistent with applicable law, to protect United States workers from any adverse effects on wages and working conditions caused by the employment of H-1B visa holders at job sites (including third-party job sites), including measures to ensure that all employers of H-1B visa holders, including secondary employers, adhere to the requirements” under immigration law.

BAL Analysis: The executive order has no immediate impact on the H-1B program. DHS and DOL were already directed by the June 22 work-visa ban to issue regulations or take other actions to ensure the presence of H-1B workers in the U.S. does not disadvantage U.S. workers. The agencies have not yet released details of additional actions relating to the H-1B program. BAL will continue to provide updates on developments 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 © 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.

U.S. Citizenship and Immigration Services (USCIS) has posted its final fee regulation for public inspection.

Key points:

  • The regulation is scheduled to be published in the Federal Register on Monday, and the prepublication version states that it will not take effect until 60 days after official publication (Oct. 2).
  • The rule will significantly increase filing fees across the board, introduce new fees and eliminate some fee reductions. H-1B petition filing fees would increase by 21%; L-1 petition fees would increase by 75%. The 9-11 response and biometric entry-exit fee of $4,500 for L-1 petitions and $4,000 for H-1B petitions will apply to all covered petitions, including new and extension petitions, by employers with more than 50 employees and more than 50% of their workforce in H-1B or L-1 status.
  • The current Form I-129 Petition for Nonimmigrant Worker will be separated into new forms for each visa classification, such as H-1, L, O, TN, with their own filing fees. USCIS will post new and revised forms 30 days before the rule goes into effect (Sept. 2) and the new forms will become mandatory Oct. 2.
  • The premium processing time frame will be lengthened from about two weeks (15 calendar days) to about three weeks (15 business days).
Category Current Fee Final Fee Change ($) Change (%)
H-1B $460 $555 $95 21%
L-1 $460 $805 $345 75%
O $460 $705 $245 53%
E $460 $695 $235 51%
TN $460 $695 $235 51%
LPR or Adjustment of Status $1,140 $1,130 $10 -1%
AOS for derivative children under 14 $750 $1,130 $380 51%
Employment Authorization (non-DACA) $410 $550 $140 34%
Naturalization (online) $640 $1,160 $520 81%
Naturalization (paper) $640/$320 $1,170 $530/$850 83%/266%

BAL Analysis: Current fee levels will remain in effect until the new rule takes effect. Employers should prepare for the increases in USCIS filing fees this fall. The rule may be subject to litigation, which could affect implementation timelines. BAL is reviewing the rule and will provide additional analysis in coming days.

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.

 

 

A federal court in New York has issued a preliminary injunction blocking the government from enforcing the public charge rule during the COVID-19 national emergency.

Key points:

  • This is the second time the U.S. District Court Judge George B. Daniels has blocked the public charge rule from taking effect. The first injunction was reversed by the U.S. Supreme Court on Jan. 27, and the rule took effect Feb. 24.
  • Daniels ruled that a new injunction was warranted, citing the surge in the COVID-19 pandemic in the six months since the Supreme Court decision.
  • The court said that there is “ample evidence” that the public charge rule “deters immigrants from seeking testing and treatment for COVID-19,” in turn impeding efforts to stem the spread of the disease. It also concluded that “informal guidance” issued by U.S. Citizenship and Immigration Services (USCIS) stating that the rule would not apply to certain COVID-19 benefits was insufficient to mitigate harm and that uncertainty about the scope of the guidance “further adds to confusion and chaos.”

Background: The lawsuit was filed by several states and nonprofit organizations. The public charge rule significantly broadens the grounds of inadmissibility of green card applicants on the basis of their past or future reliance on public benefits. Adjustment of status applicants are required to provide extensive financial and health details and complete an 18-page Form I-944 Declaration of Self-Sufficiency.

BAL Analysis: The Department of Homeland Security has not yet issued any guidance in response to the ruling. The government is likely to appeal the decision, as in previous proceedings on this issue. BAL is closely following the case and the response from DHS and will report developments 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 © 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 Department of Homeland Security (DHS) announced Tuesday that it would continue to accept Deferred Action for Childhood Arrivals (DACA) renewal applications, but not new enrollees, while it undertakes a review of the program. The announcement followed a Supreme Court ruling in June, holding that the Trump administration’s initial attempt to end the program was unlawful.

Key points:

  • DHS will essentially maintain the status quo that has been in place for years following the administration’s 2017 attempt to end DACA: renewals will continue to be accepted, but new enrollees will not.
  • However, DHS will limit renewal grants of DACA and work authorization to one-year periods, when the agency had previously issued grants in two-year increments.
  • DHS said it would reject DACA recipients’ requests for advanced parole (new and pending) except in “exceptional circumstances.”

Additional information: In its ruling in June, the Supreme Court held that the way the administration moved to end DACA was unlawful, but the Court left the door open for DHS to modify or end the program if it followed proper procedures. In an eight-page memo, DHS highlighted a number of “areas of concern” on DACA, including whether Congress should resolve the issue, whether deferred action should be taken on a case-by-case basis, that the program may send mixed messages about the government’s enforcement of immigration laws, and that the program may encourage people to bring children to the U.S. unlawfully.

BAL Analysis: While DHS considers the future of the DACA program, it will continue to accept renewals and grant renewals for one-year periods. This means that the DACA status quo will largely remain in place past the November presidential election, which could determine the future of the program. DACA remains popular among most Americans and has strong support in the business community. BAL will continue to monitor the administration’s actions on DACA and will provide more 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.

 

U.S. Citizenship and Immigration Services (USCIS) has agreed to postpone its scheduled furlough of its employees, Senator Patrick Leahy, D-Vt., vice chair of the Senate Appropriations Committee announced today.

Key points:

  • USCIS will delay the planned furlough of 13,000 employees through Aug. 31. They were scheduled to take effect Aug. 3.
  • Discussions continue in Congress regarding the agency’s request for emergency funding.
  • USCIS will soon publish a regulation to raise immigration application fees.

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.

China has ordered the closure of the U.S. Consulate General in Chengdu. The move was made in retaliation for the U.S.’s order earlier this week for China to close the Chinese Consulate General in Houston.

Key Points:

  • Chinese authorities gave the U.S. 72 hours to shut down operations at the Chengdu consulate.
  • The Chengdu consular district includes the Provinces of Sichuan, Yunnan, and Guizhou, as well as Tibet and the Chongqing municipality. The U.S. also operates consulates in mainland China in Guangzhou, Shanghai, Shenyang and Wuhan as well as the embassy in Beijing. The U.S. also has a consulate in Hong Kong.
  • Travel between China and the U.S. has slowed dramatically because of the COVID-19 pandemic and related entry restrictions in both countries. Those who did have applications pending at the Chengdu consulate should anticipate the possibility of delays.

Background: The U.S. ordered the closure of the Chinese consulate in Houston earlier this week, saying it was doing so “to protect American intellectual property and American’s (sic) private information.” China’s Foreign Ministry called the U.S.’s move “outrageous” and “unjustified” and said China would take “legitimate and necessary” counter measures if the decision is not reversed. Chine authorities ordered the closure of the Chengdu consulate on Friday.

Analysis & Comments: Applicants should prepare for delays in processing and await additional details on which consulates will assume jurisdiction over applications that had been previously submitted in Chengdu.

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 Department of Homeland Security has announced that it will lift its ban on Trusted Traveler programs for New York residents.

Key Points:

  • Residents of the state of New York will once again be eligible to enroll and re-enroll in Trusted Traveler programs such as Global Entry, NEXUS, SENTRI and FAST.
  • The change will be of limited immediate impact because operations are suspended at Trusted Traveler Program enrollment centers until at least Sept. 8 because of COVID-19.

Background: DHS suspended the enrollment of New York residents in Trusted Traveler programs in February, citing a New York law that limited information sharing between the New York Department of Motor Vehicles and DHS. DHS said Thursday that New York had amended the law in question to “expressly allow for information-sharing of NY DMV records ‘as necessary for an individual seeking acceptance into a trusted traveler program, or to facilitate vehicle imports and/or exports.”

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 Office of Management and Budget has completed its review of the U.S. Citizenship and Immigration Services (USCIS) final fee regulation.

Key points:

  • The proposed version of the regulation included increased fees for USCIS petitions and applications, but it is not yet known whether the agency made significant changes in the final version.
  • USCIS is expected to post the text of the final regulation for public inspection in the coming days before officially publishing it in the Federal Register.
  • The text for public inspection will indicate when the regulation will become effective, i.e., whether it will have a delayed effective date.
  • The proposed version also contained certain policy changes in addition to the fee increases, which, if included in the final rule, could make it subject to litigation.

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.