Scammers posing as immigration authorities are calling immigrants and seeking payment, the Department of Homeland Security has warned in a fraud alert.

The scammers identify themselves as “U.S. immigration” employees and the caller ID appears as though the calls originate from the DHS Office of Inspector General’s 1-800 hotline. They then ask for personal information, often by claiming that the recipient has been the victim of identity theft.

Reminders:

  • DHS is reminding the public that it never seeks payment over the phone or in an email. All requests for payment are made via mail on official DHS letterhead.
  • To verify whether the call is from U.S. immigration authorities, individuals may call the National Customer Service Center at 1-800-375-5283, make an InfoPass appointment here, or go to the MyUSCIS webpage.
  • Suspicious calls may be reported to the Federal Trade Commission’s complaint website. Suspicious emails may be forwarded to U.S. Citizenship and Immigration Services at uscis.webmaster@uscis.dhs.gov.

BAL Analysis: Unfortunately, email, phone and phishing website scams have become increasingly common around the world. Individuals should protect their personal information, including any relevant immigration-related details, and hang up if they receive suspicious calls seeking personal information or demanding payment. Additional information on common scams and tips to avoid them is available at the USCIS avoiding scams website.

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 has dismissed a lawsuit brought by the Washington Alliance of Technology Workers (WashTech) that challenged the STEM OPT regulations.

The lawsuit challenged the 2016 regulation that allows F-1 student visa holders who have degrees in science, technology, engineering or mathematics (STEM) fields to extend their one-year Optional Practical Training (OPT) period for an additional 24 months. The lawsuit also challenged the 1992 regulation that introduced the one-year OPT for certain F-1 students.

Among their legal claims, WashTech alleged that the regulations violated the Administrative Procedures Act, discriminated against American tech workers and increased the number of foreign employees in direct competition with U.S. workers for tech jobs.

Key points:

  • The court found that WashTech lacked standing on its challenge to the 1992 OPT rule permitting the initial 12-month period of OPT.
  • Although the court found that WashTech did have standing to challenge the 2016 STEM OPT regulation based on its members’ claims that the regulation harmed them by increasing competition in the STEM job market, the group did not allege sufficient facts to assert the claim. The court therefore dismissed the claims against the 2016 regulation.

Background: The litigation dates to 2014, when WashTech sued the Department of Homeland Security (DHS) over the previous regulation in force at the time that permitted the 17-month STEM OPT extension. A federal judge agreed that the STEM OPT rule, promulgated in 2008, was deficient in the way it was issued, but allowed DHS time to issue a new regulation through proper rulemaking procedures. DHS proposed a new rule for notice and comment, and issued a final rule in March 2016. In June 2016, WashTech filed the lawsuit challenging the new rule.

BAL Analysis: The dismissal ends this lawsuit, and the current rules governing OPT and the 24-month STEM extension remain in place. WashTech has not yet indicated whether it will appeal the ruling. The Trump administration has signaled an intention to limit work authorization for foreign students but has not yet taken action. If the administration seeks to modify the OPT regulation, it is expected that the government will do so through notice-and-comment rulemaking. As a practical matter, this would mean that the current version of the OPT regulation would remain in place for the next six to 12 months. BAL will continue to monitor for any developments regarding the STEM OPT program.

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 May 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 May 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 May.

Application Final Action Dates for Employment-Based Preference Cases:

Preference China El Salvador Guatemala Honduras India Mexico Philippines All Other Countries
EB-1 Current Current Current Current Current Current
EB-2 Feb. 8, 2013 Current June 22, 2008 Current Current Current
EB-3 Oct. 1, 2014

 

March 15, 2017 March 25, 2005 March 15, 2017 Jan. 1, 2013 March 15, 2017

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

U.S. Citizenship and Immigration Services said in a policy memo that a ruling by the Administrative Appeals Office in the case Matter of O-A-, Inc. will be adopted and followed by USCIS officers in similar cases.

The ruling addresses educational credentials of foreign individuals under the EB-2 category and clarifies how USCIS will calculate years of requisite post-baccalaureate experience, where the individual has earned a provisional certificate before receiving a formal diploma. The EB-2 advanced degree category requires a bachelor’s degree plus five years of post-baccalaureate experience.

Key points:

  • USCIS officers must conduct a case-by-case analysis to determine whether at the time the provisional certificate is issued, the individual has completed all substantive requirements of earning the degree and that the university has approved the degree.
  • If the employer proves that the provisional certificate represents completion of all substantive degree requirements and the degree was in fact approved by the educational institution, USCIS will consider the date of the provisional certificate rather than the date of the diploma for purposes of calculating whether the individual possesses five years of post-baccalaureate experience.

Background: The case involved a computer software company sponsoring a software developer for a green card in the employment-based second preference category. The employer presented evidence that the individual had five years of experience following the date of her provisional certificate, but USCIS denied the petition on the grounds that she fell just short of the five years if counted from the date of her actual diploma.

The employer also submitted a letter from a director of the university stating that the provisional certificate was proof that the individual completed all degree requirements and that issuance of the formal diploma was delayed because of administrative reasons.

On appeal, the AAO ruled that the statute and regulations on the EB-2 classification speak in terms of “degrees,” not diplomas, and a case-specific analysis is required to determine whether a provisional certificate meets the substantive requirements of a degree.

BAL Analysis: The adoption of the ruling by USCIS adjudicators will benefit employers sponsoring EB-2 candidates on the basis of a provisional educational certificate. Officers will take a case-specific approach and employers bear the burden of proving that the provisional certificate is equivalent to fulfilling all degree requirements.

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 is working through a backlog of premium processing requests that were submitted before the program was temporarily suspended April 3. In some cases, processing fees have been returned because the agency was unable to process petitions within 15 days.

Key Points:

  • USCIS announced in March that it would suspend premium processing of all H-1B petitions filed on and after April 3, the first day of filing for cap-subject petitions.
  • USCIS subsequently reported a backlog of receipt notices for H-1B petitions filed before April 3, as petitioners rushed to submit premium processing requests before the suspension took effect.
  • In the last week, BAL has received returned premium processing fees from USCIS, which has said in return notices that it was unable to process petitions within 15 days.
  • USCIS has indicated that for such cases, the agency retained the Form I-907. USCIS said these petitions will continue to be prioritized even though the agency was unable to meet the 15-day processing time.

BAL Analysis: It remains unclear how long USCIS will take to process cases for which it has returned premium processing fees, though the agency said such cases will continue to be prioritized. Those with case-specific questions should contact their BAL attorney.

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.

President Donald Trump signed an Executive Order Tuesday that includes directives to revamp the H-1B program.

Key Points:

  • The Executive Order directs the Secretary of State, Attorney General, Secretary of Labor, and Secretary of Homeland Security to propose new rules and issue new guidance to “protect the interest of United States workers in the administration of our immigration system, including through the prevention of fraud and abuse.”
  • The Order also directs the agencies to suggest reforms to prioritize “the most-skilled or highest-paid petition beneficiaries” in awarding H-1B visas.
  • Though the Order does not provide detail regarding these reforms or impose deadlines on the agencies, a background briefing posted by the White House indicates that the administration is considering specific changes to the H-1B system, including giving greater weight to H-1B applicants with advanced degrees and higher wages, and increasing application fees.
  • Nothing in the Order is expected to have an impact on this year’s H-1B selection process. U.S. Citizenship and Immigration Services (USCIS) announced Monday that it had completed the H-1B lottery for the 2018 fiscal year after receiving 199,000 cap-subject petitions.

BAL Analysis: The Executive Order does not make immediate changes to the H-1B program, but directs the relevant federal agencies to come up with ideas for creating a system that gives more weight to higher skilled, higher paid workers. This year’s H-1B lottery process will not be affected.

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 Monday that it received 199,000 cap-subject H-1B petitions during this year’s filing period. The agency has completed the computer-generated lottery to determine which petitions will be eligible for processing.

Key Points:

  • This was the fifth consecutive year that the H-1B cap was reached within the first week of filing. Caps are set at 65,000 visas for individuals with undergraduate or equivalent degrees and 20,000 visas for individuals with a master’s degree or higher from U.S. universities.
  • While the cap was easily eclipsed, the number of petitions filed this year was down compared with the past two years. USCIS received more than 236,000 petitions in 2016 and nearly 233,000 petitions in 2015.
  • Employers whose petitions were selected will receive receipt notices and, if approved, employees will be eligible to begin work in H-1B status beginning Oct. 1, the start of the 2018 fiscal year.
  • BAL began receiving receipts today and expects more over the coming weeks.
  • Petitions subject to the cap that are not selected or that were received after the filing period closed will be returned along with their filing fees.
  • USCIS will continue to accept H-1B petitions that are exempt from the cap as well as petitions to extend the amount of time a current H-1B worker can stay in the country, to change the terms of employment for current H-1B workers, to allow H-1B workers to switch employers, or to allow H-1B workers to accept concurrent employment in a second H-1B position.

BAL Analysis: The number of H-1B petitions easily exceeded the H-1B cap again this year, even as the number of petitions dropped by about 15 percent. The odds of success in the lottery are still relatively low, and companies may want to consider alternative visa options or overseas assignments for high-skilled employees whose petitions are not selected. Please consult with a BAL professional for advice regarding alternatives to the H-1B visa category and other strategic options to fulfill workforce needs. BAL is continuing to monitor for any effects the current suspension of premium processing might have on overall case timeframes.

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 U.S. Citizenship and Immigration Services (USCIS) appeals panel ruled this week that visa petitions based on illegal employment contracts will be rejected—and, specifically, that L-1B petitioners intending to keep workers on foreign payroll must meet both federal and state minimum-wage requirements.

Key Points:

  • The case, Matter of I- Corp., involved a semiconductor manufacturing company seeking to temporarily employ a foreign worker on an L-1B visa in Oregon. The petitioner indicated that it would employ the worker for a two-year period, paying a wage of 43,445 Malaysian ringgits per year. At the time, that would have amounted to a salary of about $13,468 per year, or $6.47 per hour. The federal minimum wage was $7.25 per hour, and the Oregon state minimum wage was $8.95 per hour.
  • The Administrative Appeals Office (AAO) ruled that petitioners must meet both federal and state minimum wage requirements for petitions to be considered.
  • The AAO noted that while the Immigration and Nationality Act (INA) does not itself mention minimum wage requirements, USCIS cannot approve petitions that are based on contracts that violate federal or state labor law. “While wage laws are not expressly restated in the (INA), it is implied that authorized employment must comply with both the Act and the (the Fair Labor Standards Act),” the panel said. “Only when it sought to exceed FLSA protections has Congress included specific wage-related provisions” in the INA.
  • The case, which reached the AAO after the petition was rejected on unrelated grounds, was remanded to USCIS’s California Service Center to determine whether the employee would be paid the appropriate minimum wage under both federal and state law.
  • USCIS has formally adopted this decision, meaning the ruling establishes policy guidance that is binding on all USCIS employees.

BAL Analysis: The ruling makes it clear that petitioners must be prepared to meet the requirements of both federal and state minimum-wage laws, and it has potentially significant consequences for companies that file L-1 petitions with USCIS for workers who will remain on foreign payroll. USCIS has noted in past policy memoranda that what counts as “‘total compensation’ is fact-dependent, but may include, besides wages or salary, other guaranteed forms of payment made to an employee for services to be rendered for the petitioner” and that this compensation “may be paid in the form of money, a commodity, a service, or a privilege, including food, transportation and housing allowances, as well as guaranteed bonuses.” Those with any questions on minimum compensation requirements, including requirements as they related to the I-Corp case, should contact BAL.

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.

 

Priority cutoff dates for China EB-2 and most EB-3 categories will advance modestly next month, according to the State Department’s May Visa Bulletin. Cutoff dates for employment-based categories for Indian nationals will see very little or no movement.

Key movements in priority cutoff dates:

  • China EB-3 will advance by 1 ½ months to Oct. 1, 2014, while China EB-2 will advance by three weeks to Feb. 8, 2013.
  • India EB-3 will advance one day to March 25, 2005, while India EB-2 will remain set at June 22, 2008.
  • Philippines EB-3 will advance by 3 ½ months to Jan. 1, 2013.
  • EB-3 categories for Mexico, El Salvador, Guatemala, Honduras and All Other Chargeability Areas will advance by one month to March 15, 2017.

Additional notes: All EB-1 categories will remain current. All EB-2 categories other than India and China will also remain current.

Application Final Action Dates for Employment-Based Preference Cases:

Preference China El Salvador Guatemala Honduras India Mexico Philippines All Other Countries
EB-1 Current Current Current Current Current Current
EB-2 Feb. 8, 2013 Current June 22, 2008 Current Current Current
EB-3 Oct. 1, 2014

 

March 15, 2017 March 25, 2005 March 15, 2017 Jan. 1, 2013 March 15, 2017

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

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 U.S. Labor Department has posted processing times current as of March 31 for permanent labor certification (PERM) applications and prevailing wage determination requests.

PERM processing: Applications filed in January 2017 and earlier are currently being adjudicated, according to the department. Audit reviews are being conducted on applications filed in August 2016 and earlier, and at least some appeals filed in February and earlier are being reviewed for reconsideration.

Average PERM processing times in February:

  • Adjudication – 78 days.
  • Audit review – 234 days.

PWD processing: The National Prevailing Wage Center is currently processing requests filed in January 2017 and earlier for H-1B cases and PERM cases. Redeterminations are being considered on appeals filed in January 2017 and earlier for H-1B cases and PERM cases. Center director reviews are being conducted on appeals filed in February for H-1B and PERM cases.

Average time for issuance of prevailing wage determinations in February:

  • H-1B – 99 days (OES), 140 days (non-OES).
  • PERM – 80 days (OES), 100 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 consistent with the Labor Department processing times. BAL is seeing approvals for PERM applications filed in January 2017 or earlier and is awaiting prevailing wage determinations for requests filed in January 2017.

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.