U.S. Citizenship and Immigration Services announced both the federally mandated H-1B visa regular cap and master’s cap had been reached for fiscal year 2025. This means the agency will not be selecting additional registrations entered into the lottery earlier this year.

Key Points:

  • USCIS has reached the congressionally mandated 65,000 H-1B visa regular cap and the 20,000 H-1B visa U.S. advanced degree exemption (also known as the master’s cap) for FY 2025.
  • Non-selection notices will be sent to registrants through their online accounts. The status for properly submitted registrations not selected for the FY 2025 H-1B allocations will then show “Not selected — not eligible to file an H-1B cap petition based on this registration.”

Additional Information: USCIS will continue to accept and process petitions otherwise exempt from the cap. Such petitions include those filed for current H-1B workers to extend the time they may remain in the U.S., change their terms of employment, allow them to change employers or allow them to work concurrently in additional H-1B positions.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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 special enrollment period for eligible Deferred Action for Childhood Arrivals (DACA) recipients to apply for healthcare coverage through the Affordable Care Act (ACA) Health Insurance Marketplace is currently open through Jan. 15, 2025.

Key Points:

  • Enrollment began Nov. 1, several months after the Department of Health and Human Services (HHS) finalized a rule change expanding healthcare access for DACA recipients.
  • Uninsured DACA recipients who file a federal tax return can enroll in health insurance plans at healthcare.gov or their state’s insurance marketplace.
  • The final rule does not allow DACA recipients to obtain full Medicaid or Children’s Health Insurance Program (CHIP) coverage.
  • The enrollment period ends Jan. 15, 2025.

Additional Information: Approximately 100,000 uninsured DACA recipients who were previously excluded from eligibility are expected to enroll through the ACA Marketplace or a Basic Health Program. Although the final rule was legally challenged after the HHS announcement in Kansas v. United States of America, eligible DACA recipients can still apply for coverage while a decision is pending.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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) is suspending certain regulatory requirements for F-1 nonimmigrant students from Lebanon who are experiencing severe economic hardship as a direct result of the current crisis in Lebanon, allowing eligible students to request employment authorization, work an increased number of hours while school is in session and reduce their course load while continuing to maintain their F-1 nonimmigrant status.

Key Points:

  • This notice applies exclusively to F-1 nonimmigrant students who meet all of the following conditions:
    • Are a citizen of Lebanon regardless of country of birth (or an individual having no nationality who last habitually resided in Lebanon);
    • Were lawfully present in the United States on November 27, 2024, in F-1 nonimmigrant status under section 101(a)(15)(F)(i) of the Immigration and Nationality Act (INA), 8 U.S.C. 1101(a)(15)(F)(i);
    • Are enrolled in an academic institution that is Student and Exchange Visitor Program (SEVP)-certified for enrollment for F-1 nonimmigrant students;
    • Are currently maintaining F-1 nonimmigrant status; and
    • Are experiencing severe economic hardship as a direct result of the current crisis in Lebanon.
  • This notice applies to F-1 nonimmigrant students in an approved private school in kindergarten through grade 12, public school grades 9 through 12 and undergraduate and graduate education.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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 announced that Lebanon is designated for Temporary Protected Status (TPS) for 18 months, beginning on November 27, 2024, and ending on May 27, 2026.

Key Points:

  • Lebanese nationals, and individuals having no nationality who last habitually resided in Lebanon, who have continuously resided in the United States since October 16, 2024, and who have been continuously physically present in the United States since November 27, 2024, are eligible to apply for TPS.
  • DHS estimates that approximately 11,000 individuals are eligible to apply for TPS under the designation of Lebanon.
  • Visit the USCIS TPS web page at https://uscis.gov/tps for guidance on the registration process and additional information on eligibility.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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.

In the world of immigration, a Request for Evidence (RFE) is a notice issued by U.S. Citizenship and Immigration Services (USCIS) requesting additional information or documentation for an immigration petition or application prior to rendering a final decision. While an RFE may be discouraging, it does not necessarily mean that an immigration petition or application will be denied, but it may lead to uncertainty and delays when applying for an employment-based visa or work authorization. With the support of your legal partner, you may address USCIS’ queries and overcome the RFE successfully.

By developing a strong employment-based visa application initially, you are more likely to avoid RFEs and achieve faster, more favorable outcomes. Moreover, even if USCIS issues an RFE, strong employment-based applications filed initially often provide robust foundations to push back on any USCIS challenge. Here are some of the common reasons for RFEs, strategies to increase your chance of approval and how to manage RFEs if you do receive one.

Common visa application issues that lead to RFEs

While RFEs can seem intimidating and create significant delays, they’re more common than you might think. For fiscal year (FY) 2023, 9.9% of H-1B applications received RFEs — as well as 31.5% of L-1A applications, 38.2% of L-1B applications, 22.6% of O applications and 17.2% of TN applications. Similar trends are evident for FY 2024.

Percentage of visa applications that received RFEs per fiscal year 

H-1B visa applications L-1A visa applications L-1B visa applications O visa applications TN visa applications
FY ’24 (Oct.-June) 8.6% 27% 27.8% 19.3% 16.2%
FY ’23 9.9% 31.5% 38.2% 22.6% 17.2%
FY ’22 9.6% 34.4% 40.5% 20.7% 17.1%
FY ’21 16.2% 49.9% 57.0% 27.8% 24.3%
FY ’20 28.7% 51.9% 58.4% 30.4% 21.6%
FY ’19 40.1% 53.8% 55.0% 26.4% 24.5%
FY ’18 37.9% 43.9% 48.9% 22.8% 28.2%
FY ’17 21.3% 33.7% 41.6% 21.9% 21.9%

Source: USCIS Immigration and Citizenship data

During the first Trump administration, the percentage of visa applications that received RFEs climbed to 40% for H-1B, nearly 54% for L-1A, 58% for L-1B, 30% for O and 28% for TN.

Specific reasons for getting an RFE vary depending on the visa type, but there are several common issues across various applications:

  • USCIS error or administrative challenge
  • Incomplete or missing supporting documents, such as proof of employment, financial records or educational qualifications
  • Inaccurate or incomplete responses that may cause confusion or lead to misinterpretation
  • Failure to meet specific eligibility criteria for the visa type, such as educational or experience requirements

Visa application strategies to avoid RFEs

Preparation and attention to detail are crucial in avoiding unnecessary delays or denials. While you can’t guarantee a visa application won’t result in an RFE, you can take precautionary measures to reduce the risk.

Understand the specific evidentiary requirements for your case 

Each immigration case is unique, so it’s important to thoroughly understand the specific evidentiary requirements for the visa type you apply for. Review USCIS guidelines and instructions to ensure you provide all necessary documentation.

For example, if the petition you are filing requires that the offered position must be a “specialty occupation,” such as an H-1B or an E-3 petition, you must provide a detailed job description as well as supporting documentation that demonstrates the complex nature of the role.

Submit complete and accurate documentation 

Incomplete documentation is a common trigger for RFEs, and inaccurate documentation or information can result in the rejection of your petition, or it can greatly increase the difficulty of addressing the RFE itself.

Double-check all forms, supporting materials and evidence to ensure they are complete and up to date. Ensure you submit all required educational transcripts, diplomas and evaluations to demonstrate the foreign national’s qualifications for the position, as well as all the documentation required on behalf of the company.

By providing a comprehensive, well-organized package, you minimize the chances of receiving an RFE.

Address potential red flags proactively 

USCIS officers are trained to identify potential red flags in petitions and/or applications. Take a proactive approach by addressing any potential concerns or red flags in your initial submission. Include explanatory letters, additional evidence and relevant supporting documentation to clarify any issues.

For example, one common red flag for adjudicating officers is whether or not a legitimate employee-employer relationship exists between the company and the employee. Make sure to include employment contracts, offer letters, pay stubs and tax documents to establish a clear employer-employee connection.

BAL has developed AI and automation-powered analysis tools specific to immigration policy and industry benchmarking of historical data, enabling us to identify potential high-risk areas in a case and take proactive measures to achieve swifter, more favorable decisions.

In one case, BAL’s data analysis increased a client’s overall approval rate on some immigration case types by as much as 20%.

How to respond to an RFE

If you do receive an RFE on a visa application or petition, there is still a good chance it can be approved — you just need to respond to each of the issues identified in the Service’s request promptly and thoroughly.

Follow these steps to increase your chances of approval:

  1. Carefully read and comprehend the RFE to determine the best course of action.
  2. Gather the requested evidence and information, including supporting documents, affidavits, expert opinions or other relevant material to strengthen your case. Be thorough in your research and provide comprehensive, accurate information.
  3. Craft a well-structured and persuasive response. Address each point raised in the RFE and provide detailed explanations or documentation. Use a professional tone and avoid unnecessary or irrelevant information. Highlight the strengths of your case.

In general, stay organized, thorough and focused on addressing the concerns raised.

Partner with BAL for better outcomes 

Hiring foreign national talent can help fill skills gaps and bring specialty knowledge into your workforce, but RFEs can cause major delays, unnecessary stress and additional expenses in the work authorization process.

BAL’s attorneys work diligently to avoid RFEs and ensure a seamless process. Our innovative technology and decades of experience in employment-based immigration law have led to a lower percentage of RFEs than the national average. For example, while 9.6% of H-1B petitions resulted in RFEs for FY 2023, only 5.3% of H-1B petitions filed by BAL received RFEs in the same period.

Contact our team to learn how we can provide a smooth, error-free visa application or petition process.

In this week’s episode, BAL’s Jeremy Fudge and Frieda Garcia celebrate the BAL Immigration Report’s 100th episode, and gratitude for BAL’s exceptional clients, historic milestones and growth over the last 44 years. Download the episode wherever you get your podcasts and don’t forget to subscribe!

Explore more episodes of the BAL Immigration Report podcast, available on Apple, Spotify and the BAL immigration news page.

This podcast has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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 announced the countries whose nationals are eligible to participate in the H-2A and H-2B visa programs for the next year.

Key Points:

  • DHS published a Federal Register notice listing the countries whose nationals are eligible for H-2A and H-2B nonimmigrant temporary worker visas, effective from Nov. 8, 2024, to Nov. 7, 2025.
  • The update adds Belize to the list of countries whose nationals are eligible for H-2A and H-2B visas. No countries previously designated as eligible for these visas were removed from the list.
  • The full list of eligible countries is available here.

Additional Information: This update does not affect the status of H-2 beneficiaries currently in the U.S. unless they apply to extend their stay in H-2 status with a petition filed on or after Nov. 8, 2024.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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 it plans to make nearly 65,000 additional H-2B temporary nonagricultural worker visas available for fiscal year (FY) 2025.

Key Points:

  • DHS, in consultation with the Department of Labor, expects to make an additional 64,716 H-2B visas available for FY 2025, on top of the congressionally mandated annual allotment of 66,000 H-2B visas.
  • These additional H-2B visas are the maximum number permitted under congressional authority. DHS and DOL have previously authorized supplemental cap numbers in FYs 2017-19 and 2021-24.
  • DHS intends to make these supplemental visas available in early FY 2025.

Additional Information: The supplemental H-2B allotment will include 20,000 visas for workers from Colombia, Costa Rica, Ecuador, El Salvador, Guatemala, Haiti or Honduras. The remaining 44,716 supplemental visas will be available to returning workers who received an H-2B visa or were otherwise granted H-2B status during one of the previous three fiscal years.

DHS stated that “the supplemental visa allocation will help address the need for seasonal and temporary workers in areas where too few U.S. workers are available, willing and qualified to do the temporary work and address the labor needs of American businesses.”

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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 released the December Visa Bulletin. Filings for employment-based preference categories must use the Dates for Filing chart for December 2024 which will remain the same as last month and shows no advancement for EB-1/EB-2/EB-3. Final Action Dates for India EB-2/EB-3 show some advancement.

Final Action Dates and Dates for Filing Movement:

EB-1

  • China EB-1 Final Action Dates and Dates for Filing will remain the same.
  • India EB-1 Final Action Dates and Dates for Filing will remain the same.
  • All other countries under EB-1, including Mexico and the Philippines, Final Action Dates and Dates for Filing will remain the same.

EB-2

  • China EB-2 Final Action Dates and Dates for Filing will remain the same.
  • India EB-2 Final Action Dates advance 15 days to Aug. 1, 2012. Dates for Filing will remain the same.
  • All other countries under EB-2 Final Action Dates, including Mexico and the Philippines, and Dates for Filing will remain the same.

EB-3

  • China EB-3 Final Action Date and Dates for Filing will remain the same.
  • India EB-3 Final Action Dates advanced seven days to Nov. 8, 2012. Dates for Filing will remain the same.
  • All other countries under EB-3 Final Action Dates, including Mexico and the Philippines, and Dates for Filing will remain the same.

Final Action Dates for Employment-Based Preference Cases

Preference All chargeability areas except those listed China India Mexico Philippines
EB-1 Current Nov. 8, 2022 Feb. 1, 2022 Current Current
EB-2 March 15, 2023 March 22, 2020 Aug. 1, 2012 March 15, 2023 March 15, 2023
EB-3 Nov. 15, 2022 April 1, 2020 Nov. 8, 2012 Nov. 15, 2022 Nov. 15, 2022

Dates for Filing of Employment-Based Visa Applications

Preference All chargeability areas except those listed China India Mexico Philippines
EB-1 Current Jan. 1, 2023 April 15, 2022 Current Current
EB-2 Aug. 1, 2023 Oct. 1, 2020 Jan. 1, 2013 Aug. 1, 2023 Aug. 1, 2023
EB-3 March 1, 2023 Nov. 15, 2020 June 8, 2013 March 1, 2023 March 1, 2023

 

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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.

In this week’s episode, BAL’s Edward Rios and Christopher Barnett discuss AI implementation and adoption in the global mobility arena.

Plus, the latest immigration news including an update on litigation against the Keeping Families Together program.

This podcast has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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.