Update on applications received for requested date of need from Oct. 1, 2024, through March 31, 2025 (fiscal year (FY) 2025 first half of the visa cap):

The Department of Labor reported that as of June 14, a total of 5,947 cases were issued Final Decisions. Certified positions for this period were allocated for 111,225 workers.

In April, U.S. Citizenship and Immigration Services reached the additional H-2B visa cap made for returning workers for the early second half of FY 2025 with start dates from April 1 to May 14, 2025.

Update on applications received for requested date of need from April 1, 2025 (FY 2025 second half of the visa cap):

As of June 14, a total of 8,723 cases were issued Final Decisions. Certified positions for this period were allocated for 118,846 workers.

Additional Information: Per USCIS, allocation of the 64,716 supplemental H-2B visas for the late second half of FY 2025 (May 15 through Sept. 30) 5,000 visas were limited to returning workers who were issued H-2B visas or held H-2B status in fiscal years 2022, 2023 or 2024, regardless of country of nationality.

These late second half of FY 2025 petitions must request employment start dates from May 15, 2025, through Sept. 30, 2025.

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

Copyright © 2025 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 expanded a Preliminary Injunction (PI) on June 17 pausing enforcement of the Trump administration’s new passport policy and allowing the issuance of U.S. passports to applicants with an “X” marker or those listing a sex different from their sex at birth.

Key Points:

  • In February, the State Department provided guidance on the use of sex markers, stipulating that the department will no longer issue U.S. passports or Consular Reports of Birth Abroad (CRBAs) with an “X” marker, and requiring that a passport reflect an applicant’s sex assigned at birth.
  • On June 17, a federal judge for the United States District Court District of Massachusetts issued a PI requiring the State Department to allow individuals to apply for U.S. passports that reflect their gender identity.
  • The order blocks enforcement of the State Department’s passport policy created to implement President Trump’s January 20 Executive Order, which mandated that federal agencies recognize only the gender assigned at birth.
  • Previously the court had issued an injunction that applied only to a limited group of individuals who are parties to the lawsuit. The PI issued June 17 expands the class of persons who will benefit from the injunction to all individuals who have applied for, or but for the Trump administration’s policy, would have applied for a U.S. passport with an “M” or “F” sex designation that is different from the sex assigned at birth; or with an “X” designation.

Additional Information: In granting the PI, the Court ultimately found the plaintiff’s significant hardships outweighed the government’s burden stating, “The balance of the equities and the public interest favor granting preliminary injunctive relief to members of the PI Class. The plaintiffs have demonstrated that members of the PI Class are likely to face significant hardships absent preliminary injunctive relief. The government contends that the balance of the equities nevertheless tilts in its favor, primarily because of the administrative burden associated with class-wide relief. While this burden may be more than de minimis, it does not outweigh the equities favoring the PI Class.” The complete Court order can be read here.

The Trump administration is expected to appeal the ruling.

BAL will continue to monitor litigation related to this policy and provide updates.

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

Copyright © 2025 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 State Department announced expanded screening and vetting procedures for F, M and J nonimmigrant visa applicants.

Key Points:

  • Per the State Department’s announcement, it “will conduct a comprehensive and thorough vetting, including online presence, of all student and exchange visitor applicants in the F, M, and J nonimmigrant classifications.”
  • All student and exchange visitor (F,M, and J) applicants “will be instructed to adjust the privacy settings on all of their social media profiles to ‘public’.”
  • Overseas posts will soon resume scheduling appointments, and applicants are advised to check embassy or consulate websites for availability.

Additional Information: BAL is monitoring this guidance and any related litigation.

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

Copyright © 2025 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 issued policy guidance on how the agency processes Form N-648, Medical Certification for Disability Exceptions, to prevent fraudulent exceptions to naturalization requirements.

Key Points:
  • Under this policy guidance, USCIS is focusing greater attention on the accuracy of medical certifications and ways to identify and prevent fraud.
  • The guidance confirms that the medical professional completing Form N-648 must not only verify that the disability or impairment exists but also explain how it leaves the individual unable to complete naturalization requirements.
  • The guidance also states that submitting multiple Forms N-648 concurrently may raise concerns about the credibility of the disability claim and could be subject to further review.
  • The updated policy guidance is effective immediately and applies to all Forms N-648 filed on or after June 13, 2025.

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

Copyright © 2025 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) updated its Policy Manual with guidance on how the agency discloses derogatory information upon which an adverse decision is based.

Key Points:

  • The policy guidance states that a detailed description of the derogatory information will be provided to the benefit requestor if USCIS relies on this information to make its decision and the requestor was unaware of it.
  • The guidance clarifies instances when USCIS may not disclose derogatory information, including when the information is classified, sensitive or privileged.
  • The policy update is effective immediately and applies to pending benefit requests and those filed on or after June 12, 2025.

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

Copyright © 2025 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 updating its Policy Manual to clarify that a Form I-693, Report of Immigration Medical Examination and Vaccination Record, is only valid while the application the Form I-693 was submitted with is pending.

Key Points:

  • The guidance is effective immediately and applies to applications pending or filed on or after June 11, 2025.
  • If the application a Form I-693 was submitted with is withdrawn or denied, the Form I-693 is no longer valid and a newly completed Form I-693 signed by a civil surgeon must be submitted with a new application.
  • By limiting the validity period to only the current immigration benefit application or request, the agency aims to ensure timely medical treatments and safeguard public health.

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

Copyright © 2025 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 posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing Times: As of June 9, the department was adjudicating PERM applications filed in February 2024 and earlier and reviewing appeals for reconsideration filed in March 2025 and earlier.

Average Number of Days to Process PERM Applications

Determinations Month Calendar Days
Analyst Review May 2025 500
Audit Review N/A N/A

PWD Processing Times: As of May 31, the National Prevailing Wage Center is completing the processing of PWD requests filed in:

  • February 2025 and earlier for H-1B visa Occupational Employment and Wage Statistics (OEWS) cases
  • January 2025 and earlier for H-1B visa non-OEWS cases
  • February 2025 and earlier for PERM OEWS cases
  • December 2024 and earlier for PERM non-OEWS cases

Redeterminations were being considered on appeals filed in February 2025 and earlier for H-1B visa cases and PERM cases.

Center Director Reviews were being conducted for both H-1B visa cases and PERM cases filed in October 2024 and earlier.

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

Copyright © 2025 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 July Visa Bulletin. U.S. Citizenship and Immigration Services announced filings for employment-based visa preference categories must use the Final Action Dates chart. China dates advanced slightly in every category and India showed slight advancement in the EB-3 visa category.

Final Action Dates:

EB-1 visa

  • China EB-1 visa Final Action Dates advanced seven days to Nov. 15, 2022.
  • India EB-1 visa Final Action Dates remained the same (Feb. 15, 2022).
  • For all other countries under the EB-1 visa category, including Mexico and the Philippines, Final Action Dates remained current.

EB-2 visa

  • China EB-2 visa Final Action Dates advanced 14 days to Dec. 15, 2020.
  • India EB-2 visa Final Action Dates remained the same (Jan. 1, 2013).
  • For all other countries under the EB-2 visa category, including Mexico and the Philippines, Final Action Dates remained the same (Oct. 15, 2023).

EB-3 visa

  • China EB-3 visa Final Action Dates advanced nine days to Dec. 1, 2020.
  • India EB-3 visa Final Action Dates advanced seven days to April 22, 2013.
  • The Philippines EB-3 visa Final Action Dates remained the same (Feb. 8, 2023).
  • For all other countries under the EB-3 visa category, including Mexico, Final Action Dates advanced nearly two months to April 1, 2023.
Preference category All chargeability areas except those listed China India Mexico Philippines
EB-1 visa Current Nov. 15, 2022 Feb. 15, 2022 Current Current
EB-2 visa Oct. 15, 2023 Dec. 15, 2020 Jan. 1, 2013 Oct. 15, 2023 Oct. 15, 2023
EB-3 visa April 1, 2023 Dec. 1, 2020 April 22, 2013 April 1, 2023 Feb. 8, 2023

Additional Information: Review BAL’s employer’s guide to reading the Visa Bulletin to better understand this monthly report.

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

Copyright © 2025 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’s Presidential Proclamation restricting entry to the U.S. from 19 countries has gone into effect as of June 9. The administration’s additional Proclamation restricting entry under student and exchange visitor programs at Harvard University has been put on hold as of June 5 and is not currently in effect.

Key Points:

  • As BAL previously reported, a Presidential Proclamation issued June 4 restricts entry to the U.S. from 19 total countries deemed high risk for terrorism and national security threats.
    • These restrictions took effect June 9 at 12:01 a.m. EDT.
    • The restrictions apply to nationals of the designated countries who were not in the U.S. as of June 9 and did not have a valid visa on that date.
  • Another Presidential Proclamation, also issued June 4, intended to suspend entry of any foreign national into the United States as a nonimmigrant to pursue a course of study or exchange visitor program at Harvard University under the F-1, M-1 or J-1 visa programs.
    • U.S. District Judge Allison Burroughs in Boston issued a temporary restraining order against the proclamation on June 5 after Harvard filed a legal challenge.
    • Burroughs also extended the temporary hold she placed on the attempt of the Department of Homeland Security to revoke Harvard’s certification to enroll international students.

Additional Information: Foreign nationals are reminded to speak with their BAL team prior to international travel and to be aware of general travel requirements, including maintaining valid status in the U.S. BAL will continue to monitor developments and update accordingly. U.S. immigration policies may change quickly and without prior notice.

For the latest updates and insights regarding immigration policy, in-house immigration professionals are invited to join BAL Community at no cost.

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

Copyright © 2025 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 published notice in the Federal Register that the designation of Nepal for Temporary Protected Status (TPS) will terminate on Aug. 5, 2025.

Key Points:

  • The notice states that the DHS Secretary determined that Nepal no longer continues to meet the conditions for the designation of TPS.
  • Nationals of Nepal (and nonimmigrants with no nationality who last habitually resided in Nepal) who have been granted TPS under Nepal’s designation will no longer have TPS as of Aug. 5, 2025 (60 days after the publication date in the Federal Register).
  • Through the notice, DHS automatically extends the validity of certain Employment Authorization Documents (EADs) previously issued under the TPS designation of Nepal through Aug. 5, 2025.
  • The notice states that as continued proof of employment authorization through Aug. 5, 2025, Nepalese TPS beneficiaries can show their EADs that have the notation A-12 or C-19 under “Category” and a “Card Expires” date of June 24, 2018; June 24, 2019; March 24, 2020; Jan. 4, 2021; Oct. 4, 2021; Dec. 31, 2022; June 30, 2024; and June 24, 2025.

Additional Information: Nepal was initially designated for TPS on June 24, 2015, for a period of 18 months, based on an earthquake that resulted in a substantial disruption of living conditions. Since then, TPS has been extended several times, with the last 18-month extension starting on Dec. 25, 2023, and in effect through June 24, 2025.

DHS estimates that approximately 12,700 nationals of Nepal (and nonimmigrants having no nationality who last habitually resided in Nepal) hold TPS under Nepal’s designation. Of those, approximately 5,500 have become lawful permanent residents of the U.S.

DHS determined that “conditions in Nepal have improved in several areas relevant to the affected living conditions and Nepal’s ability to handle the return of its nationals.” The termination notice can be viewed here.

The termination of the designation is subject to litigation. BAL will continue to monitor this litigation and related cases.

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

Copyright © 2025 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.