U.S. Citizenship and Immigration Services has announced that it will resume premium processing for certain cap-exempt H-1B petitions.

Key points:

  • Effective immediately, premium processing will resume for H-1B petitions if the petitioner is (1) an institution of higher education; (2) a nonprofit organization affiliated with or related to an institution of higher education; or (3) a nonprofit or governmental research organization.
  • Premium processing will also be resumed for petitions where the employee will be employed at a cap-exempt institution or organization.
  • USCIS announced in June that it would resume premium processing for H-1B petitions filed on behalf of physicians in the Conrad 30 waiver program.
  • Those who qualify for premium processing as outlined above can now file a Form I-907, Request for Premium Processing Service, either with an H-1B petition or after an H-1B petition has been submitted but before it has been adjudicated.

Background: USCIS suspended H-1B premium processing in April, saying the reason was to focus on backlogged petitions. USCIS said Monday it “plans to resume premium processing of other H-1B petitions as workloads permit.”

BAL Analysis: While USCIS has resumed premium processing for some H-1B petitions and said it will “make additional announcements with specific details related to when we will begin accepting premium processing” for other petitions, the service is still not available for most H-1B petitions. Employers should continue to expect delays in H-1B receipt notices for H-1B petitions for which premium processing remains suspended. BAL will continue following USCIS developments on this issue and will update clients if premium processing is resumed for more H-1B petitions.

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

 

Copyright © 2017 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 processing times that are current as of June 30 for permanent labor certification (PERM) applications and prevailing wage determination requests.

PERM processing: Applications filed in April and earlier are now being adjudicated, according to the Labor Department. Audit reviews are being conducted on applications filed in December and earlier, and appeals filed in May and earlier are being reviewed for reconsideration.

Average PERM processing times in June:

  • Adjudication – 68 days.
  • Audit review – 224 days.

PWD processing: The National Prevailing Wage Center is currently processing requests filed in April and earlier for H-1B and PERM cases. Redeterminations are being considered on appeals filed in May or earlier for H-1B cases and January or earlier for PERM cases. Center Director Reviews are being conducted on appeals filed in April for H-1B and PERM cases.

Average time for issuance of prevailing wage determinations in June:

  • H-1B – 95 days (OES), 115 days (non-OES).
  • PERM – 96 days (OES), 108 days (non-OES).

The Labor Department reports PERM and prevailing wage determination processing timeframes on its iCERT page.

BAL Analysis: BAL’s internal case tracking is basically consistent with the Labor Department processing times. BAL is seeing approvals for PERM applications filed in April 2017 or earlier and is awaiting prevailing wage determinations for requests filed in May or later.

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

Copyright © 2017 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 Supreme Court on Wednesday affirmed a lower court’s ruling requiring the government to exempt grandparents and other close relatives of U.S. residents from the limited version of President Donald Trump’s travel ban that took effect June 29.

Key Points:

  • The Court denied a government motion for clarification of its June 26 ruling (the motion sought Court affirmation of the government’s more narrow interpretation of close family members), thereby leaving in place U.S. District Judge Derrick Watson’s July 14 ruling that the government must count grandparents, grandchildren, brothers-in-law, sisters-in-law, aunts, uncles, nieces and nephews as “close family members” for the purpose of determining who is exempt from the travel ban. This is in addition to the family relations of parent, parent-in-law, spouse, child, adult son or daughter, son-in-law, daughter-in-law, sibling, and fiancé, which the government had already recognized as “close family members” exempt from the ban.
  • The Court did grant the government’s request to put a stay on the portion of Judge Watson’s injunction that would have expanded the number of refugees who would have been exempt from the ban, pending resolution of the government’s appeal of this issue to the 9th Circuit Court of Appeals.
  • Justices Clarence Thomas, Samuel Alito, Jr. and Neil Gorsuch said they would have stayed the entirety of Judge Watson’s ruling.

Background: The Supreme Court ruled on June 26 that a limited version of Trump’s 90-day ban on travel to the U.S. by nationals of Iran, Libya, Somalia, Sudan, Syria and Yemen could take effect, but carved out an important exemption for those with a “bona fide” relationship to U.S. persons or entities. The government subsequently issued guidance exempting people with a parent, parent-in-law, spouse, child, adult son or daughter, son-in-law, daughter-in-law or sibling residing in the U.S. The State of Hawaii sued, saying that grandparents, grandchildren, brothers-in-law, sisters-in-law, aunts, uncles, nieces and nephews should also be provided exemptions under the Supreme Court ruling. Judge Watson agreed. While the Supreme Court affirmed this portion of his ruling, it stayed a separate portion of his ruling that would have exempted a greater number of refugees from enforcement of Trump’s executive order.

BAL Analysis: Overall, those with legitimate travel needs to visit family or for work or business will not be kept from traveling to the United States. Litigation is ongoing, however, and BAL is carefully monitoring the situation and will continue to provide updates on important developments. An FAQ on the Executive Order and who it applies to is available here.

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

 

Copyright © 2017 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 judge in Hawaii has ruled that the government must exempt grandparents and other close relatives of U.S. residents from the limited version of President Donald Trump’s travel ban that took effect June 29.

Key Points:

  • U.S. District Judge Derrick Watson ruled that the government must count grandparents, grandchildren, brothers-in-law, sisters-in-law, aunts, uncles, nieces and nephews as “close family members” for the purpose of determining who is exempt from the travel ban, which prevents nationals of Iran, Libya, Somalia, Sudan, Syria and Yemen from traveling to the U.S. for a 90-day period.
  • The Supreme Court ruled on June 26 that a limited version of the ban could take effect, but that those with a “bona fide” relationship to U.S. persons or entities must be exempted. The court specifically stated that those qualifying for an exemption based on individual relationships must have a “close familial relationship.” The government subsequently issued guidance exempting individuals with a parent, spouse, child, adult son or daughter, son-in-law, daughter-in-law or sibling residing in the U.S. The guidance was then amended to include fiancés on the list of those qualifying for exemption. The limited version of the ban took effect June 29.
  • The State of Hawaii challenged the government’s implementation of the Executive Order, saying that its interpretation of the Supreme Court’s ruling was too  narrow. Judge Watson agreed. “Common sense … dictates that close family members be defined to include grandparents,” Watson wrote. “Indeed, grandparents are the epitome of close family members.” Watson also accepted the state’s argument that grandchildren, brothers-in-law, sisters-in-law, aunts, uncles, nieces and nephews should also be covered as “close family members” qualifying for an exemption.
  • Hawaii’s legal challenge did not concern the government’s guidelines for those with employment or business ties to the U.S. However, as BAL previously reported, the State Department has made it clear that journalists, students and workers or lecturers who have valid invitations or employment contracts in the U.S. are exempt from the ban. The exemption does not apply to those who seek a relationship with an American business or educational institution purely for the purpose of maneuvering around the rules. A hotel reservation or car rental contract, even if prepaid, will also not count.
  • BAL anticipates that short-term business travelers in possession of an invitation letter from a U.S. company will also be exempt from the travel ban, but this is not clearly addressed in the guidance the State Department has issued.

BAL Analysis: The State Department and Justice Department are expected to review the decision and issue additional guidance. The administration will likely appeal the ruling, which broadens the categories of people who can qualify for an exemption to the travel ban based on a family tie to someone in the U.S. On the whole, those with legitimate travel needs to visit family or for work or business will not be kept from traveling for the time being, though the litigation is ongoing. BAL is carefully monitoring the situation and will continue to provide updates on important developments. An FAQ on the Executive Order and who it applies to is available here.

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

Copyright © 2017 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 this week that it will release a new version of Form I-9 for checking employment eligibility of newly hired employees. The form will be available Monday and will become mandatory beginning Sept. 18.

Key Points:

  • The revised version will include revisions related to the list of acceptable documents for I-9 verification, including the addition of Consular Report of Birth Abroad (Form FS-240) to the list of documents accepted under “List C” for verification of employment authorization. Other changes are largely cosmetic.
  • Instructions to Form I-9 will also be updated, and the changes to the form will be included in an updated Handbook for Employers: Guidance for Completing Form I-9 (M-274).
  • From Monday through Sept. 18, employers may use either the new Form I-9 or the current form. Use of the new form will become mandatory Sept. 18.

BAL Analysis: Employers should take note of the change and ensure that their human resource departments switch to the new forms no later than Sept. 18.

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

Copyright © 2017 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 Application Final Action Dates chart.

The Dates for Filing chart published in the State Department’s August Visa Bulletin will not apply. Employment-based immigrants must follow the Application 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.

Application Final Action Dates for Employment-Based Preference Cases:

Preference China El Salvador
Guatemala
Honduras
India Mexico Philippines All Other Countries
EB-1 Jan. 1, 2012 Current Jan. 1, 2012 Current Current Current
EB-2 April 22, 2013 April 1, 2015 July 22, 2008 April 1, 2015 April 1, 2015 April 1, 2015
EB-3 Jan. 1, 2012 Current July 15, 2006 Current June 1, 2015 Current

Family-based immigrants will also be required to use the Final Action Dates chart applicable to family-sponsored immigrants, which was also provided in the August Visa Bulletin.

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

Copyright © 2017 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.

Cutoff priority dates will be imposed for this first time this year in EB-2 categories for El Salvador, Guatemala and Honduras, Mexico, the Philippines and All Other Chargeability Areas, according to the State Department’s August Visa Bulletin. Cutoff priority dates will remain the same in all EB-1 categories and will advance across most EB-3 categories.

Key movements in priority cutoff dates: 

  • A cutoff priority date of April 1, 2015 was imposed in the EB-2 categories for El Salvador, Guatemala and Honduras, Mexico, the Philippines and All Other Chargeability Areas.
  • China EB-2 will advance by one month to April 22, 2013, while China EB-3 will remain set at Jan. 1, 2012.
  • India EB-2 will remain set at July 22, 2008, while India EB-3 will advance by five months to July 15, 2006.
  • The EB-3 categories for El Salvador, Guatemala and Honduras, Mexico and All Other Chargeability Areas will become current, advancing from a cutoff priority date of June 8, 2017 in the July Visa Bulletin.
  • Philippines EB-3 will advance by more than a year to June 1, 2015.

Additional notes: All EB-1 and categories other than those for China and India will remain current. The cutoff priority date for EB-1 China and EB-1 India will remain at Jan. 1, 2012. It is likely that the retrogression for certain categories is being undertaken to control the number of visas issued between now and the end of the fiscal year on Sept. 30, as the number of available immigrant visas runs out. The number of immigrant visas will increase again under the 2018 fiscal year’s annual limits. At that time, all EB-1 categories and all EB-2 categories other than China and India are likely to become current.

Application Final Action Dates for Employment-Based Preference Cases:

Preference China El Salvador Guatemala Honduras India Mexico

 

Philippines

 

All Other Countries
EB-1 Jan. 1, 2012 Current Jan. 1, 2012 Current Current Current
EB-2 April 22, 2013 April 1, 2015 July 22, 2008 April 1, 2015 April 1, 2015 April 1, 2015
EB-3 Jan. 1, 2012 Current July 15, 2006 Current June 1, 2015 Current

The State Department also released its Dates for Filing chart for August 2017. Applicants seeking to file for adjustment of status are reminded that the Dates for Filing chart does not take effect unless USCIS confirms it via a web posting in the next week or so. BAL will update clients once the State Department confirms whether the Dates for Filing chart can be used in August.

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

Copyright © 2017 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 will delay implementation of the International Entrepreneur Rule and has signaled its intent to rescind the rule altogether, according to a notice that is set to be published Tuesday in the Federal Register. The Trump administration’s moves to delay and possibly scrap the rule, which was finalized days before former president Barack Obama left office, are not surprising after the rule was sent to the Office of Management and Budget for additional review a little more than a month ago.

Key points:

  • The International Entrepreneur Rule, which was published in the Federal Register Jan. 17, would have granted qualifying foreign entrepreneurs permission to remain temporarily in the U.S. to grow their startup businesses. Applicants would have been required to meet minimum requirements for capital investments or government grants and demonstrate that their startup would provide a significant public benefit through rapid growth and job creation in the U.S.
  • The rule was slated to take effect July 17, but the effective date has now officially been postponed until March 14, 2018. The administration said it will begin the notice-and-comment rulemaking process on a rule to rescind the regulation and that it did not make sense to allow it to take effect in the meantime.
  • “Allowing the [rule] to go into effect while the agency undertakes notice and comment rulemaking to delay its effective date in order to consider a rescission would lead the public to continue to rely on the rule,” U.S. Citizenship and Immigration Services stated. “Such reliance would include expending significant effort and resources in order to establish eligibility under the criteria promulgated by the [rule] … In the event the [rule] is rescinded – which the [Department of Homeland Security] believes is highly likely – individuals who satisfied these and other requirements of the [rule] would quite possibly do so without being able to reap benefits from the rule.”

BAL Analysis: BAL supported the International Entrepreneur Rule and advocated to keep it in place. The administration’s moves to delay and eventually scrap the rule are unsurprising, however, especially after it was sent back to OMB for additional review this spring.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2017 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.

IMPACT – MEDIUM

Indian nationals are now eligible to apply for the U.S. Global Entry program, a trusted-traveler program that allows preapproved, low-risk travelers to use automated kiosks when clearing immigration at designated airports rather than having to wait in line. India is the 11th country whose nationals will be eligible for Global Entry.

Key points:

  • Applicants must apply online and pay a nonrefundable government fee of $100 for a five-year membership.
  • Once the online application is provisionally approved, the applicant must schedule an interview with a U.S. Customs and Border Protection officer, who will make a final decision on the application.
  • Membership in the program does not replace the need for travelers to obtain the appropriate visa before travel.

Background: Global Entry participants may bypass manned immigration inspection queues at entry points and undergo automated clearance at 53 U.S. airports and 15 preclearance locations, significantly reducing wait times upon arrival. India joins Argentina, Colombia, Germany, Mexico, the Netherlands, Panama, Singapore, South Korea, Switzerland and the United Kingdom among countries that have Global Entry arrangements with the U.S. Canadian nationals and those enrolled in NEXUS are also permitted to use Global Entry kiosks. Additional details are available on this CBP website.

BAL Analysis: Indian nationals who are frequent travelers will benefit from the program, as their entry clearance will be expedited at dozens of airports. Global Entry participants may also benefit from TSA security prescreening at designated international airports before boarding a flight to the U.S. Travelers are reminded that Global Entry does not ensure admission and they must still secure an appropriate visa before travel.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2017 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 is considering moving the issuance of visas, passports and other travel documents from the State Department to the Department of Homeland Security, according to a report commissioned by Secretary of State Rex Tillerson aimed at slashing the State Department’s budget by a third.

The move would provide “an opportunity to elevate efficiency and reduce cost,” according to recommendations in the report by private consulting firm Insigniam.

The State Department oversees the issuance of 10 million visas per year at consulates around the world, and such a change would represent a seismic shift in resources and agency functions.

Jeffrey Gorsky, Senior Counsel in BAL’s Washington, D.C. office, who previously headed the Legal Advisory Opinion section of the State Department’s Visa Office, said that the change would likely require Congressional approval, and, if implemented, could mean that visa decisions could be subject to judicial review. Currently, consular decisions on whether to grant or deny visas fall under the doctrine of non-reviewability and cannot be reviewed by a court.

In addition to the cost-cutting rationale, the report said that giving DHS authority over visa issuance would “elevate security at our borders.” Gorsky, however, said that enhanced security screening measures since the Sept. 11, 2001 terrorist attacks have largely negated this argument.

BAL Analysis: BAL is following this proposal and will report on any significant developments that could affect changes in how visas and other travel documents are issued. While there appears to be support in part of the administration for transferring these functions from the State Department to DHS, the likely need for Congressional action makes this transfer unlikely at this time.

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

Copyright © 2017 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.