The U.S. Citizenship and Immigration Services (USCIS) Ombudsman reported that USCIS has reduced its capacity to print lawful permanent resident cards (green cards) and employment authorization documents (EADs) because of a hiring freeze at the cash-strapped agency.

Key Points:

  • USCIS expects the backlog in producing and issuing these documents to continue “for the foreseeable future,” the agency’s Ombudsman has confirmed. If USCIS employees are furloughed on Aug. 3, as planned, backlogs will increase.
  • The Ombudsman is sending weekly spreadsheets to USCIS of the backlog of applicants who have been approved but whose cards have not been printed.
  • Those who are experiencing a delay in receiving their green card or EAD may request assistance from the USCIS Ombudsman at: https://www.dhs.gov/topic/cis-ombudsman/forms/7001.
  • Lawful permanent residents seeking proof of their status may request a “stamp of temporary evidence” in their passport by calling the USCIS Contact Center at 1-800-375-5283 and making an appointment at their local USCIS field office.

Background: Last month, USCIS reduced its production of green cards and EADs after ending its contract with a company that printed the documents for the government. The agency said it planned to take production in-house by hiring more federal employees. USCIS has reported a $1.2 billion budget deficit since May, has frozen hiring and is scheduled to furlough 70% of its employees on Aug. 3.

BAL Analysis: EAD and green card applicants should anticipate lengthy delays in receiving their documents. BAL is closely monitoring the USCIS budget issues and their impact on processing 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 U.S. government has ordered the closure of the Chinese Consulate General in Houston.

Key Points:

  • The U.S. gave the Chinese government until July 24 to cease operations and move personnel out of the consulate.
  • The Houston consulate served applicants in eight U.S. states: Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, Oklahoma and Texas. China also operates consulates in Chicago, New York, Los Angeles and San Francisco, in addition to the embassy in Washington, D.C.
  • Travel between the U.S. and China has slowed dramatically because of the COVID-19 pandemic and related entry restrictions in both countries. Those who did have applications pending at the Houston consulate should anticipate the possibility of delays. Additional information will be provided as it becomes available.

Background: In a widely reported statement, the State Department said it was closing the consulate “in order to protect American intellectual property and American’s (sic) private information.” A spokesman for 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. An article in China’s Global Times, which is close to the ruling Communist Party, suggested that China could order the closure of the U.S. Consulate in Hong Kong in response to the State Department’s latest decision. Other media outlets have suggested the government may close the U.S. consulate in Wuhan.

BAL Analysis: Applicants should prepare for delays in the processing of visas and documents, and await additional details for which consulates will assume jurisdiction over applications that had been previously submitted in Houston.

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 has announced that in August it will only accept employment-based adjustment-of-status applications based on the State Department’s Final Action Dates chart.

The Dates for Filing chart published in the August Visa Bulletin will not apply. Employment-based immigrants must follow the Final Action Dates chart (below) to determine whether they are eligible to file their adjustment-of-status petitions with USCIS. Only applicants with priority dates earlier than the dates listed in the chart will be permitted to file their applications for adjustment of status in August.

Final Action Dates for Employment-Based Preference Cases:

Preference  All Other Countries  China  El Salvador,   Guatemala,   Honduras  India  Mexico  Philippines  Vietnam
EB-1 Current Feb. 8, 2018 Current Feb. 8, 2018 Current Current Current
EB-2 Current Jan. 15, 2016 Current July 8, 2009 Current Current Current
EB-3 April 1, 2019 Feb. 15, 2017 April 1, 2019 Oct. 1, 2009 April 1, 2019 April 1, 2019 April 1, 2019

Additional information: August will mark the fifth time this fiscal year that USCIS will use Final Action Dates for employment-based adjustment-of-status applications. The Final Action Dates chart is less progressive than the Dates for Filing chart in a number of categories. Family-based applicants must use the applicable Dates for Filing chart, except for F2A category applicants, who may use Final Action Dates.

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.

Priority-date cutoffs will advance significantly in most employment-based categories, according to the State Department’s August Visa Bulletin.

Key movements:

EB-1

  • China EB-1 will advance almost six months to Feb. 8, 2018.
  • India EB-1 will advance nine months to Feb. 8, 2018.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance more than two months to Jan. 15, 2016.
  • India EB-2 will remain at July 8, 2009.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will advance almost eight months to Feb. 15, 2017.
  • India EB-3 will advance four months to Oct. 1, 2009.
  • The cutoff for all other countries will advance almost a year to April 1, 2019.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China El Salvador Guatemala Honduras India Mexico Philippines Vietnam
EB-1 Current Feb. 8, 2018 Current Feb. 8, 2018 Current Current Current
EB-2 Current Jan. 15, 2016 Current July 8, 2009 Current Current Current
EB-3 April 1, 2019 Feb. 15, 2017 April 1, 2019 Oct. 1, 2009 April 1, 2019 April 1, 2019 April 1, 2019

The State Department also released its Dates for Filing chart for August. 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. BAL will update clients once officials confirm whether the chart can be used.

BAL Analysis: The advancement in numbers for Chinese and Indian applicants primarily reflects slowdowns in processing adjustment-of-status applications. The State Department has said that the slowdown could have resulted in even greater advancements, but that the advancements must also reflect USCIS processing limitations.

The government’s reduced processing capacity makes it unreasonable to expect that an even more accelerated advancement in the Final Action Dates would increase actual number usage this fiscal year. Additionally, such abrupt movements would likely result in corrective action in the form of retrogression, which should be avoided. As a result, while numbers may continue to advance, there may not be a dramatic advancement even if processing continues to slow.

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 it is extending flexible measures regarding Form I-9 employment eligibility verification. The measures were set to expire yesterday.

Key points:

  • The temporary measures have been extended another 30 days and are now scheduled to expire Aug. 19.
  • The guidelines allow employers who are operating 100% remotely to conduct remote verification of employee documents, e.g., using fax, email or video link, for the purpose of Form I-9 employment eligibility verification procedures.
  • Employers that follow the remote verification procedures must comply with strict guidelines when “normal operations resume,” including physical inspection of the documents that were viewed remotely within three business days.
  • The initial guidance granted an automatic extension of 60 days to employers who were served notices of inspection (NOIs) in March but had not yet responded. Today’s announcement confirms that after July 19 no additional extensions will be granted to employers who were served NOIs during the month of March 2020.
  • The original guidance including eligibility requirements can be found here.

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 confirmed via Twitter that it will extend restrictions on nonessential travel at land ports of entry with Canada and Mexico until Aug. 20. The agency has not yet released a formal announcement.

Key points:

  • Only “essential travel” is permitted at all 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 include 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, initially for 30 days, and have since been extended in 30-day increments.

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.

Flexible Form I-9 temporary measures for employers who are operating remotely are set to expire this Sunday, July 19, unless extended.

Key points:

  • The temporary measures, in effect since March 20, allow employers who are operating 100% remotely because of COVID-19 to conduct remote verification of employee documents, e.g., using fax, email or video link, for purposes of Form I-9 employment eligibility verification procedures.
  • Employers that followed the remote verification procedures must comply with strict protocols when “normal operations resume,” including physical inspection of documents that were remotely viewed, within three business days.
  • The government has not yet indicated whether these measures will be extended again.
  • Employers should review the original ICE guidance on the temporary measures in case the measures are not extended.

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.

Today, the State Department issued two announcements regarding limited exceptions to President Donald Trump’s proclamations suspending the entry of certain immigrants and nonimmigrants.

Key points:

  • The proclamations restricting entry include certain limited exceptions for humanitarian travel, public health response, and national security. The government has not issued detailed guidance on how travelers can establish eligibility for these exceptions.
  • Today’s announcement states that other limited exceptions to the immigrant and nonimmigrant visa restrictions may be provided to:
    • Spouses and children of nonimmigrant visa holders in restricted categories, such as H, L, and J, who are already exempt from or are not subject to the work-visa ban. The work-visa ban covers those who were outside the U.S. on June 24 and do not already hold a valid nonimmigrant visa in the H-1B, H-2B, L-1, or most J-1 categories.
    • Children who would age out of their current immigrant visa classification before the proclamation expires or within two weeks thereafter. The proclamations are set to expire Dec. 31.
    • Certain H and J visa applicants who are traveling to work in support of a critical U.S. foreign policy objective (such as COVID-19 response) and/or traveling at the request of the U.S. government.
  • A second announcement relates to the current entry ban on travelers from Schengen Area countries, the United Kingdom, and Ireland. The State Department indicated that students traveling from those countries with valid F-1 and M-1 visas, do not need to seek a national interest exception to travel to the U.S. Students from those areas who are traveling on a J-1 may contact the nearest embassy or consulate to initiate an exception request. The announcement did not address travelers from China, Iran, or Brazil, who are currently subject to entry restrictions.

Additional information: The announcement provides that the State Department will continue to issue H, L and J visas to otherwise qualified family derivative applicants who are already excepted from the work-visa travel ban or where the main applicant is currently in the U.S. Additionally, the agency confirmed that winners of the FY2020 Diversity Visa lottery who have not been issued an immigrant visa as of April 23 are subject to the immigrant visa ban unless they fall under an exception.

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 group of green card applicants and immigration advocacy organizations filed a lawsuit in federal court Monday challenging the U.S. Citizenship and Immigration Services (USCIS) implementation of the public charge rule.

Key points:

  • The suit alleges that USCIS implemented the public charge regulation by issuing guidance to USCIS officers that exceeds the regulation itself and the Immigration and Nationality Act with the aim of disqualifying all but the wealthiest of applicants from obtaining permanent residency.
  • The suit also claims that the new 18-page Form I-944 (Declaration of Self-Sufficiency) requires applicants to furnish large volumes of information not contemplated by the regulation.
  • The groups have asked the court to overturn the USCIS guidance and Form I-944.

Background: The public charge rule significantly broadens the grounds of inadmissibility for green card applicants on the basis that they may become dependent on government benefits. The rule has been in effect since Feb. 24. Several courts blocked its initial implementation in October 2019, but the Supreme Court lifted those injunctions allowing USCIS to implement the rule while lawsuits proceed in court.

BAL Analysis: This new lawsuit challenges the way USCIS has implemented the rule, alleging that the agency improperly set a presumption of inadmissibility, raised the burden of proof from “preponderance of the evidence” to “clearly and beyond a doubt,” and makes the lack of health insurance a negative factor even if an applicant has the opportunity to obtain insurance, such as through an upcoming open enrollment period. BAL is monitoring litigation over the public charge rule and will continue to provide updates as the cases progress.

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.

More than 100 leading U.S. companies are urging President Donald Trump to leave the Deferred Action for Childhood Arrivals program (DACA) in place.

Last month, the Supreme Court ruled that the Trump administration’s 2017 attempt to end DACA was unlawful, but left the door open for the Department of Homeland Security (DHS) to alter or eliminate the program by following different administrative procedures. In a letter to Trump, the Coalition for the American Dream, a group of 140 employers and trade associations, said getting rid of DACA would further weaken the American economy.

“This is no time to disrupt the economic recovery of our companies and communities, nor time to jeopardize the health and safety of these vulnerable individuals,” the letter says. “We ask that you leave DACA in place and refrain from taking any additional administrative actions that would negatively impact the DACA program.”

The coalition is advocating for a bipartisan permanent legislative solution for DACA recipients, often called Dreamers. DACA provides protection from deportation for some 800,000 individuals who were brought to the U.S. illegally as children. DACA only protects recipients from deportation and allows them to legally work in the U.S. It does not provide legal status for them.

“DACA recipients have been critical members of our workforce, industries, and communities for years now, and they have abided by the laws and regulations of our country in order to maintain their DACA status,” the letter says. “Their work and commitment to our companies, their families and communities are critical to our nation’s strength, especially since there are tens of thousands of DACA recipients working as front line doctors and nurses and in other critical industries fighting COVID19.”

The letter also cites strong support for DACA from most Americans. A recent Pew Research poll shows about three-quarters of U.S. adults say they favor granting permanent legal status to DACA recipients.

BAL Analysis: The future of DACA remains unknown, and the Trump administration has made conflicting remarks about the program in the days after the Supreme Court ruled against the administration’s initial attempt to end it. DHS also has not made any announcements regarding initial applications for DACA. BAL is closely monitoring the administration’s response to the ruling and will provide updates and analysis as more information becomes available. For more information, please visit BAL’s DACA Resource Center.

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.