The U.S. Justice Department and Department of Homeland Security published a fact sheet this week on how employers can avoid violating the law when using proprietary or commercial electronic programs to complete the Form I-9 or E-Verify process.

Key Points:

Additional Information: BAL continues to review the information published this week and will be providing substantive updates through BAL Community in January, including during a Jan. 17 event, “How to Run a Simple I-9 Audit.” For more information on BAL Community, visit Community.BAL.com.

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

Copyright © 2023 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 on Thursday announced it would extend interview waiver authorities for certain nonimmigrant visa applicants.

Interview waivers have played a key role in helping reduce State Department processing backlogs. In announcing the extension, the department also put in place some changes to the current policy. Beginning Jan. 1, consular officers will have the authority to waive interviews for:

  • First-time H-2 visa applicants (temporary agricultural and nonagricultural workers).
  • Other nonimmigrant visa applicants applying for any nonimmigrant visa classification who (1) were previously issued a nonimmigrant visa in any classification, unless the only prior issued visa was a B visa; and (2) are applying within 48 months of their most recent nonimmigrant visa’s expiration date.

Applicants renewing a nonimmigrant visa in the same classification within 48 months of the prior visa’s expiration date continue to be eligible for an interview waiver.

The new interview waiver authorities will be reviewed annually and will remain in place until further notice.

To be eligible for an interview waiver, applicants must meet certain criteria, including that they:

  • Apply in their country of nationality or residence.
  • Have never been refused a visa (unless such refusal was overcome or waived).
  • Have no apparent or potential ineligibility.

The department stressed that consular officers may still require in-person interviews on a case-by-case basis or because of local conditions.

BAL Analysis: The extension of interview waiver authorities is welcome news that should help the State Department continue to improve visa wait times. While the interview waiver authorities no longer specifically cover F, M, and academic J visa applicants or individual petition-based based H-1, H-3, H-4, L, O, P, and Q visa applicants, these individuals may qualify for an interview waiver under one of the above-noted categories. Applicants are reminded that interviews may be required on a case-by-case basis and should check embassy and consulate websites for more detailed information about visa application requirements and procedures.

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

Copyright © 2023 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 Labor has asked for public input on whether to revise its list of Schedule A job classifications that do not require permanent labor certification.

Key Points:

  • In October, President Biden issued an Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, which included several provisions designed to streamline immigration procedures to help keep the United States competitive in AI and other emerging technological fields.
  • One of the provisions directed DOL to consider additions to the Schedule A list of occupations by soliciting public input to identify occupations in AI, STEM and other sectors for which there are an insufficient number of ready, willing, able and qualified U.S. workers.
  • On Thursday, DOL published a Request for Information on Schedule A revisions. The deadline for submitting comments is Feb. 20, 2024.

BAL Analysis: Green cards in the EB-2 and EB-3 classifications generally require permanent labor certification, or PERM; however, PERM is not required for occupations on the Schedule A list of shortage occupations. Schedule A has not been revised since 2004, and the DOL’s move to ask for public input is a welcome development towards modernizing the list and the process for revising it. This is a preliminary step in the rulemaking process, and several steps must be completed before the list can be updated. BAL will continue following this matter and will provide updates as information becomes available.

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

Copyright © 2023 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 will allow a limited number of H-1B holders to renew their visas in the United States under a pilot program, the details of which were unveiled Wednesday.

Key Points:

  • The pilot will run from Jan. 29 to April 1, 2024, and will be open to a total of 20,000 H-1B visa holders.
  • To be eligible, applicants must:
    • Be seeking to renew an H-1B visa.
    • The H-1B visa being renewed was issued by Mission Canada with an issuance date from Jan. 1, 2020, through April 1, 2023, or by Mission India with an issuance date from Feb. 1, 2021, through Sept. 30, 2021.
    • Not be subject to a nonimmigrant visa issuance fee (i.e., a “reciprocity fee”).
    • Be eligible for an interview waiver.
    • Have submitted 10 fingerprints to the State Department in connection with a previous visa application.
    • Not have a “clearance received” annotation on the prior H-1B visa.
    • Not require a waiver of visa ineligibility or inadmissibility.
    • Have an approved and unexpired H-1B petition.
    • Have been most recently admitted to the U.S. in H-1B status.
    • Be currently maintaining H-1B status in the U.S.
    • Have a period of authorized admission in H-1B status that has not expired.
    • Intend to re-enter the U.S. in H-1B status after a temporary period abroad.
  • Eligible visa holders will be able to apply for renewal online beginning Jan. 29, 2024.
  • The State Department will open about 4,000 application slots every week, dividing them roughly equally between individuals whose prior visas were approved by Mission Canada and those whose visas were approved by Mission India. Application slots will become available on Jan. 29, Feb. 5, Feb. 12, Feb. 19 and Feb. 26.
  • The State Department said the average processing times for domestic visa renewal would be six to eight weeks. Officials aim to complete processing of all applications by May 1.
  • The program is voluntary, and eligible applicants may continue to submit renewal applications at visa processing posts abroad. Those who do not meet the pilot’s eligibility criteria must continue to submit visa renewal applications outside of the United States.
  • The State Department is expected to publish a notice on the pilot program in the Federal Register Thursday. A pre-publication version of the notice is available here.

BAL Analysis: The pilot program is an important step toward bringing back domestic visa renewal, which has not been widely available in the U.S. since 2004. The pilot will be open only to a limited number of H-1B visa holders, but it could be expanded to other individuals and visa categories later in 2024. BAL will provide additional updates as information becomes available.

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

Copyright © 2023 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.

Leading business and immigration organizations have called on U.S. Citizenship and Immigration Services to implement proposed changes to the H-1B lottery ahead of the upcoming H-1B cap season.

In October, USCIS published a wide-ranging proposed regulation that would have broad consequences for the H-1B program, including shifting to a beneficiary-based H-1B lottery.

In a Dec. 5 comment, Compete America — a coalition of businesses, trade organizations and higher-education associations — said they have “serious concerns” about the “vulnerabilities” in the current H-1B registration process.

“The gaming of the registration system that occurred this year drove selection rates down for legitimate users of the H-1B program and caused uncertainty for U.S. employers and their employees,” the coalition said. “The H-1B program is critical to a wide range of industries in the United States, and allowing this gaming to continue for even one more year would be detrimental to the country’s economy.”

Key Points:

  • Compete America encouraged the Department of Homeland Security to move forward with the proposed changes to the H-1B registration and lottery immediately, while waiting to finalize other provisions of the proposed regulation.
  • Last summer, the American Immigration Council, American Immigration Lawyers Association, Information Technology Industry Council and TechNet called on USCIS to take “immediate steps to address the procedural deficiencies that were highlighted” in the fiscal year 2024 H-1B lottery process. AILA and AIC reiterated this request in a preliminary comment on the proposed rule.
  • USCIS will continue accepting comments on the proposed regulation through Dec. 22. The agency then must review the comments before formulating a final regulation or regulations.

BAL Analysis: USCIS has indicated that it may seek to finalize provisions related to cap registrations separately from other provisions in the proposed regulation but has not definitively said it will do so. The deadline to submit comments on the proposed H-1B regulation is this Friday, Dec. 22. BAL will continue monitoring the proposal through the regulatory process and will provide updates as information becomes available.

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

Copyright © 2023 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 Register notice about a State Department pilot program to revive domestic visa renewal for a limited number of nonimmigrant visa holders has cleared review at the White House Office of Management and Budget.

Key Points:

  • Details of the pilot program are still not publicly available, but OMB review is the last step before publication.
  • In a briefing last month, the State Department indicated the pilot would initially be open to about 20,000 H-1B visa holders but could be expanded later next year.
  • Domestic visa renewal has not been broadly available since 2004. The State Department announced plans for a domestic visa renewal pilot in February.

BAL Analysis: While the pilot would be a significant step toward bringing back a domestic visa renewal program, it will initially apply to a limited number of H-1B visa holders before potentially being expanded. Eligibility criteria, scope and duration of the pilot will not be known until the notice is published in the Federal Register. BAL will continue following the matter and will provide more information once it becomes available.

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

Copyright © 2023 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 updated current passport processing times, showing reduced wait times for both routine and expedited services.

Key Points:

  • As of Dec. 18, processing times are now six to eight weeks for routine applications and two to three weeks for expedited applications, according to the department.
  • Government officials stated that the current processing times have returned to the benchmarks from March 2020.

Additional Information: It may take up to two weeks for applications to arrive by mail at a passport agency or center, and then an additional two weeks or more to receive a completed passport in the mail. These mailing times are not included in the processing times described above. Individuals must be traveling within 14 calendar days in order to schedule an in-person appointment for urgent passport or emergency passport processing services.

BAL Analysis: The decrease in wait times is welcome news, especially following significant delays over the summer. Wait times fluctuate with changes in demand, and travelers are urged to continue preparing well in advance of planned international travel.

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

Copyright © 2023 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.

 

On today’s BAL Immigration Report, we look back at some of the most important business immigration stories of 2023.

  • Proposed fee hikes
  • Domestic visa renewal
  • And forthcoming changes to the H-1B program

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on Apple, Spotify and Google Podcasts or on the BAL news site.

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

Copyright © 2023 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 posted a Federal Register notice detailing the extension of Temporary Protected Status reregistration periods from 60 days to 18 months for the designations of El Salvador, Haiti, Honduras, Nepal, Nicaragua and Sudan.

Key Points:

  • DHS previously announced the reregistration period extension on Sept. 8, 2023.
  • Under this extension, the reregistration periods now run through the following dates:
    • El Salvador — March 9, 2025
    • Haiti — Aug. 3, 2024
    • Honduras — July 5, 2025
    • Nepal — June 24, 2025
    • Nicaragua — July 5, 2025
    • Sudan — April 19, 2025
  • The extension allows TPS beneficiaries from these countries to submit Form I-821, Application for Temporary Protected Status, and Form I-765, Application for Employment Authorization, any time before the dates noted above.

Additional Information: U.S. Citizenship and Immigration Services stressed that the announcement does not change previously announced extensions of the TPS designations for the six countries in question. The announcement also does not change any TPS eligibility requirements, but rather extends the period when existing beneficiaries may reregister for benefits.

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

Copyright © 2023 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 Wednesday that it has received enough petitions to reach congressionally mandated H-1B caps. This means there will not be a third H-1B lottery this fiscal year.

Key Points:

  • The annual H-1B cap is set at 65,000 visas plus an additional 20,000 for advanced degree holders (the master’s cap).
  • USCIS said Wednesday it had received sufficient petitions to reach both caps and would send non-selection notices to registrants through their online accounts over the next few days. Once this happens, the status for properly submitted registrations that were not selected for the FY2024 H-1B cap will show: “Not Selected: Not selected — not eligible to file an H-1B cap petition based on this registration.”
  • USCIS will continue to accept and process cap-exempt H-1B petitions. It will also continue to accept petitions to:
    • Extend the amount of time a current H-1B worker may remain in the U.S.
    • Change the terms of employment for current H-1B workers.
    • Allow current H-1B workers to change employers.
    • Allow current H-1B workers to work concurrently in additional H-1B positions.

Additional Information: USCIS completed its initial lottery of H-1B cap-subject registrations in March, selecting 110,791 of 758,994 eligible registrations. The agency completed a second lottery in July, selecting an additional 77,609 eligible registrations, significantly more than it has selected in second lotteries in past years. Employers are encouraged to work with their BAL attorney to consider alternatives for registrations that were not selected.

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

Copyright © 2023 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.