The White House Office of Management and Budget has completed its review of a Department of Homeland Security proposal to “modernize and reform” the H-2A and H-2B nonimmigrant worker programs.

Key Points:

  • The text of the proposal is not yet available, but a summary of the regulation indicates the changes will be aimed at reducing inefficiencies, enhancing pay protections and addressing “aspects of the program that may unintentionally result in exploitation or other abuse of persons seeking to come to this country as H-2A and H-2B workers.”
  • The rule will not revise the temporary labor certification process.
  • OMB is the last step in the regulatory process before publication.
  • A separate Department of Labor proposal to improve protections for temporary agricultural workers remains under White House review.

BAL Analysis: Both the DHS and DOL regulations will be published as proposed rules, meaning they will go through a notice-and-comment period before they are updated and published as final rules. BAL will continue following the development of these regulations and will provide updates on how they will impact H-2A and H-2B employers.

This alert has been provided by the BAL Global Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

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 COVID-era policy that allows visa applicants more time to book appointments after paying the applicable State Department fee ends this month.

Key Points:

  • Visa applicants typically have 365 days from the time they pay the Machine-Readable Visa (MRV) fee to schedule an appointment before their receipt expires.
  • Applicants were given additional time to book appointments under a temporary COVID-19 policy that will come to an end on Sept. 30, 2023.
  • Under this change, all MRV fee receipts issued before Oct. 1, 2022, will expire Sept. 30, 2023. While appointments using receipts issued before Oct. 1, 2022, must be made before Sept. 30, the interviews themselves can occur after that date.

BAL Analysis: Applicants with MRV receipts issued before Oct. 1, 2022, are encouraged to book appointments this month in order to avoid having to pay their MRV fee another time. Similarly, applicants with receipts issued before this date should not to attempt to change their appointment dates on or after Oct. 1, 2023. Doing so will result in the appointment being canceled and the forfeiture of their receipt. For more information, find the State Department’s announcement of this change here.

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

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 announced the extension and redesignation of South Sudan for Temporary Protected Status for 18 months, from Nov. 4, 2023, through May 3, 2025.

Key Points:

  • The TPS extension will allow currently eligible TPS beneficiaries from South Sudan to retain TPS through May 3, 2025, provided they continue to meet eligibility requirements.
  • The redesignation will allow additional South Sudanese nationals who have continuously resided in the United States since Sept. 4, 2023, and been continuously physically present in the United States since Nov. 4, 2023, to file first-time TPS applications.
  • DHS posted a Federal Register notice, detailing the eligibility criteria, timelines and procedures for current beneficiaries to re-register and renew Employment Authorization Documents (EADs), and for new applicants to submit initial applications under the redesignation and apply for EADs.

Additional Information: In a statement, Homeland Security Secretary Alejandro Mayorkas said the extension and redesignation would allow the U.S. to “continue to offer safety and protection to South Sudanese nationals who may not be able to return to their country due to the ongoing armed conflict and humanitarian crisis.” DHS said the extension would allow approximately 133 current beneficiaries to retain TPS, while the redesignation would allow roughly 140 additional individuals to file first-time TPS applications.

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

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 temporary policy on employment authorization extensions is set to end. Student visa issuance is on the rise. And a look at the impact of USCIS processing delays.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify 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.

A multiyear decline in foreign-student enrollment in American colleges and universities appears to be ending.

Key Points:

  • According to the U.S. State Department, 411,131 F-1 visas for foreign students were issued in Fiscal Year 2022, compared with 364,204 in 2019, the most recent non-pandemic year. The FY 2022 total was also the highest number since FY 2016, when 471,728 F-1 visas were issued.
  • The government expects the numbers this year to continue increasing.
  • Most of the increase in 2022 — 70% — was driven by visas issued to Asian students. Of these 274,880 visas, 115,115 went to Indian students.
  • The increase is occurring despite rising rejection rates of F-1 applicants. In all, the U.S. State Department rejected 35% of all F-1 applicants in 2022, a sharp increase from previous years.
  • In May, U.S. Immigration and Customs Enforcement terminated COVID-era guidance that allowed F and M students to count more online classes than normal toward a full course of study. The long-term impact of this change on enrollment trends is not known at this point.

Background: The United States recorded its high-water mark of 644,253 F-1 visa issuances for foreign students in 2015, then saw the numbers decline steadily for the next four years, reaching 364,204 in 2019. In 2020, the onset of the COVID-19 pandemic caused issuances to plummet to 111,387. In 2021, the 357,839 F-1 issuances nearly reached pre-pandemic levels, and they’ve been increasing ever since.

BAL Analysis: There is intense global competition to attract young minds who will shape future talent pools. The increasing numbers are good news for American employers because they represent a talent pipeline of educated, diverse, skilled workers already acclimated to American life and equipped to join the U.S. workforce, especially in STEM fields.

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

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 temporary policy that provides for longer automatic extensions of some workers’ employment authorization documents is set to end Oct. 26.

Key Points:

  • In May 2022, U.S. Citizenship and Immigration Services published a Temporary Final Rule that increased the automatic employment authorization extension for certain renewal applicants from up to 180 to up to 540 days.
  • The temporary rule is set to expire Oct. 26, 2023.
  • Eligible applicants who have already filed or are requesting an employment authorization extension on or before Oct. 26 will continue to be eligible for extensions of up to 540 days; those who file after Oct. 26 will be eligible for extensions of up to 180 days.
  • The extension applies to applicants who file Form I-765, Application for Employment Authorization, if they:
    • Properly file Form I-765 for a renewal of their employment authorization and/or EAD before their current EAD expired.
    • Are otherwise eligible for a renewal, i.e., their renewal application is under a category that is eligible for an automatic extension, and the category on their current EAD matches the “Class Requested” listed on Form I-797C, Notice of Action.

BAL Analysis: USCIS implemented the temporary rule in 2022 as part of a package of initiatives to address processing delays and a growing case backlog. At this time, it appears unlikely the temporary rule will be extended. Applicants who are eligible to receive the 540-day extension are encouraged to file their Form I-765 before Oct. 26.

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

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.

Employers that relied on Form I-9 flexible measures during the COVID-19 pandemic have until Aug. 30 to complete follow-up document inspections.

Key Points:

  • Employers enrolled in E‑Verify during the COVID‑19 temporary flexibilities may use the alternative procedure to satisfy the requirement of physically examining Form I‑9 documents that had been examined remotely under the COVID‑19 flexibilities. More information is available on this USCIS website.
  • In order to qualify for to use the alternative procedure to satisfy this requirement, employers must be enrolled in E-Verify and have:
    • Performed the initial remote examination of an employee’s documents between March 20, 2020, and July 31, 2023.
    • Been enrolled in E‑Verify at the time they completed the Form I-9 for that employee.
    • Created a case in E‑Verify for that employee (except for reverification).
  • Employers that meet all of the requirements can choose whether to use the alternative procedure or conduct an in-person physical examination by Aug. 30, 2023.
  • Employers that do not meet all of these requirements must perform an in-person physical examination of Form I-9 documents by Aug. 30, 2023.

Background: USCIS confirmed earlier this month that E-Verify employers that checked Form I-9 identity and work authorization documents remotely under temporary COVID-19 flexibilities “must still complete the steps of the new alternative procedure to finalize the Form I-9” by Aug. 30 even if they followed a process similar to the alternative procedure. USCIS guidance on notating Form I-9 when completing reviews due Aug. 30 is available here.

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

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 publishes a proposal on allowing third parties at interviews for U.S. citizen services. Foreign musicians and artists express concern about proposed filing fee increases. And a look at how passport applications have swamped the State Department — and what that means for business.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify 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 State Department has published a proposed rule that would allow third parties to attend interviews for certain U.S. citizen services.

Key Points:

  • Under the proposed rule, third parties, including attorneys and interpreters, would be able to attend:
    • Appointments in support of an application for U.S. passports, either domestically or overseas.
    • Appointments related to a request for a Consular Report of Birth Abroad or a Certificate of Loss of Nationality of the United States.
    • Appointments for certain other services offered by American Citizens Services units at U.S. embassies and consulates overseas.
  • The State Department is accepting comments on the proposal until Sept. 25.

BAL Analysis: While State Department guidance has permitted third-party attendance at some appointments in the past, there are no regulations on the issue and policies vary from post to post. The Department said it published the proposal “to provide greater transparency to the public” and an “explicit framework” through which the department “may facilitate such third-party attendance” at interview appointments.

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

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.

Lawmakers introduce a Name, Image and Likeness bill with new provisions for F-1 student athletes. The U.S. curtails consular services in Niger. And a closer look at USCIS’ second H-1B lottery.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify 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.