A federal judge in Texas has set a hearing for June 1 in a case challenging the legality of the Biden administration’s Deferred Action for Childhood Arrivals regulation.

Key Points:

  • Judge Andrew Hanen is hearing the case after the Fifth Circuit Court of Appeals ruled that the memorandum that created DACA in 2012 was unlawful but also asked the district court to consider the legality of the 2022 final rule.
  • The Biden administration constructed the regulation to “preserve and fortify” DACA, but the states challenging the program say it “suffers the same flaws” as the 2012 memorandum.
  • Currently, the Department of Homeland Security continues to adjudicate renewal applications (both DACA and employment authorization) and advance parole requests for existing DACA recipients; the agency remains prohibited from granting initial DACA requests and accompanying requests for employment authorization.

BAL Analysis: Judge Hanen ruled in 2021 that the Obama administration did not follow proper procedures when it created DACA and is now weighing the Biden administration’s attempt to protect the program through federal regulation. Given the uncertainty around the litigation, individuals who are eligible to renew their DACA and related employment authorization are urged to do so as soon as they are eligible. BAL will continue to monitor the ongoing litigation and will provide updates on important developments related to DACA. For more information, visit BAL’s DACA Resource Center 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 national COVID-19 public health emergency expired at the end of the day Thursday, a change that affects some immigration policies.

  • Vaccine Requirements. As of Friday, May 12, nonimmigrant foreign nationals are no longer required to show proof of COVID-19 vaccination to enter the country by land, air or sea. Vaccine requirements remain in place for immigrant visa applicants. The Centers for Disease Control and Prevention issued updated instructions to panel physicians, saying that immigrant visa applicants who are “due for the first, second or third dose of a primary (COVID vaccination) series should receive the one dose for which they are due, but should no longer be delayed to complete the entire series before completing the exam.”
  • F-1 Student Guidance. The Student and Exchange Visitor Program ended COVID-19 guidance that allowed F and M students to count online classes toward a full course of study beyond normal limitations. Students will be able to complete spring and summer coursework under the COVID-19 policy, but not coursework undertaken during the 2023-24 academic year. Students participating in Optional Practical Training or a STEM OPT extension can still work remotely so long as they comply with all regulatory requirements and “continue the training’s mentoring relationship”; training plans must be updated to reflect the remote worksite. An updated FAQ is available here.
  • Form I-9 Flexible Measures. Flexible measures that allow some employers operating remotely to inspect Form I-9 employment eligibility documents virtually will expire July 31. Employers will have 30 days from that date (i.e., until Aug. 30), to reach compliance with inspection requirements, including conducting physical inspections of documents that were reviewed virtually while the flexible measures were in place. The Department of Homeland Security continues to work on a rule that would give Immigration and Customs Enforcement authority to allow remote inspection of documents in some cases; however, it is not yet know when the final rule will be published.
  • USCIS Deadlines. In March, U.S. Citizenship and Immigration Services ended COVID-related flexible deadlines for responding to agency requests. Petitioners and applicants for USCIS benefits must respond by deadlines listed in notices and requests from the agency, as they were required to do before the pandemic.

BAL Analysis: BAL will continue to monitor the impact of COVID-19 on immigration policy and will provide updates as information becomes available.

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.

U.S. Citizenship and Immigration Services announced that in June it will follow the State Department’s Final Action Dates chart, as published in the June Visa Bulletin, to determine whether applicants are eligible to file for adjustment of status.

Final Action Dates

EB-1

  • China EB-1 will remain at Feb. 1, 2022.
  • India EB-1 will remain at Feb. 1, 2022.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will remain at June 8, 2019.
  • India EB-2 will remain at Jan. 1, 2011.
  • All other countries under EB-2 will remain at Feb. 15, 2022.

EB-3

  • China EB-3 will remain at April 1, 2019.
  • India EB-3 will remain at June 15, 2012.
  • All other countries under EB-3 will remain at June 1, 2022.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China India Mexico Philippines
EB-1 Current Feb. 1, 2022 Feb. 1, 2022 Current Current
EB-2 Feb. 15, 2022 June 8, 2019 Jan. 1, 2011 Feb. 15, 2022 Feb. 15, 2022
EB-3 June 1, 2022 April 1, 2019 June 15, 2012 June 1, 2022 June 1, 2022

Additional Information: Family-based applicants may use the Dates for Filing chart next month, according to the USCIS announcement. More information 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.

IMPACT — MEDIUM

The U.K. Home Office published guidance and reporting requirements for employers who sponsor remote workers.

Key Points:

  • Sponsors must report through the Sponsor Management System if the sponsored employee:
    • Is or will be working at a different site, branch or office, or a different client’s site, not previously declared to U.K. Visas and Immigration.
    • Is or will be working remotely from home on a permanent or full-time basis (with little or no requirement to physically attend a workplace).
    • Has moved or will be moving to a hybrid working pattern.
  • Individuals are considered to be in a hybrid working pattern if the sponsored employee is working remotely on a regular and planned basis from their home or other location that is not listed on the sponsor license.
  • Sponsors are not required to report day-to-day changes in work locations.

Additional Information: Reports must be made within 10 business days after the change in location. More information regarding the reporting requirements for remote workers is available here.

BAL Analysis: Employers should review the hybrid working pattern guidance to ensure that they adhere to the new reporting requirements.

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.

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 released the June Visa Bulletin, showing no movement for key employment-based categories.

Final Action Dates

EB-1

  • China EB-1 will remain at Feb. 1, 2022.
  • India EB-1 will remain at Feb. 1, 2022.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will remain at June 8, 2019.
  • India EB-2 will remain at Jan. 1, 2011.
  • All other countries under EB-2 will remain at Feb. 15, 2022.

EB-3

  • China EB-3 will remain at April 1, 2019.
  • India EB-3 will remain at June 15, 2012.
  • All other countries under EB-3 will remain at June 1, 2022.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China India Mexico Philippines
EB-1 Current Feb. 1, 2022 Feb. 1, 2022 Current Current
EB-2 Feb. 15, 2022 June 8, 2019 Jan. 1, 2011 Feb. 15, 2022 Feb. 15, 2022
EB-3 June 1, 2022 April 1, 2019 June 15, 2012 June 1, 2022 June 1, 2022

Dates for Filing

EB-1

  • China EB-1 will remain at June 1, 2022.
  • India EB-1 will remain at June 1, 2022.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will remain at July 8, 2019.
  • India EB-2 will remain at May 1, 2012.
  • All other countries under EB-2 will remain at Dec. 1, 2022.

EB-3

  • China EB-3 will remain at June 1, 2019.
  • India EB-3 will remain at Aug. 1, 2012.
  • All other countries under EB-3 will remain at May 1, 2023.

Dates for Filing for Employment-Based Preference Cases:

Preference All Other Countries China India Mexico Philippines
EB-1 Current June 1, 2022 June 1, 2022 Current Current
EB-2 Dec. 1, 2022 July 8, 2019 May 1, 2012 Dec. 1, 2022 Dec. 1, 2022
EB-3 May 1, 2023 June 1, 2019 Aug. 1, 2012 May 1, 2023 May 1, 2023

Additional Information: U.S. Citizenship and Immigration Services has not yet announced whether it will use the Final Action Dates or Dates for Filing chart in June. BAL will update clients once USCIS announces which chart will be used.

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 Labor Department has posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing: As of April 30, the department was adjudicating applications filed in July and earlier, conducting audit reviews on applications filed in April and earlier, and reviewing appeals for reconsideration filed in August and earlier.

Determinations: February 2023 March 2023 April 2023
Adjudication 264 days 271 days 279 days
Audit Review 383 days 402 days 383 days

PWD Processing: As of April 30, the National Prevailing Wage Center was processing PWD requests filed in January 2022 and earlier for H-1B OES and PERM OES cases, February 2022 and earlier for H-1B non-OES cases, and January 2022 and earlier for PERM non-OES cases. Redeterminations were being considered on appeals filed November and earlier for H-1B cases, and October and earlier for PERM cases.

BAL Analysis: BAL’s internal case tracking is mostly consistent with the Labor Department’s published processing times. BAL is seeing faster PWD issuances for PERM OES and non-OES cases. BAL is seeing approvals for PERM applications filed in July and earlier, and is starting to see PWDs for requests filed in January and earlier for H-1B OES cases, February and earlier for H-1B non-OES cases, and November and earlier for PERM OES and non-OES cases.

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 U.S. State Department has announced the winners of the 2024 Diversity Visa lottery.

Key Points:

  • DV2024 entrants can check their entries on the Entrant Status Check website. Results will remain posted through Sept. 30, 2024.
  • To check their results, individuals who entered the lottery will need to provide their entry confirmation number, last name and year of birth.
  • Those who are selected in the lottery will be given instructions in Entrant Status Check about how to apply for immigrant visas for themselves and eligible family members.
  • Selected entrants are encouraged to complete the online DS-260 application immediately to schedule an interview appointment at the appropriate U.S. embassy or consulate.
  • The State Department will not mail notification letters or notify selectees by email, nor will U.S. embassies or consulates provide a list of selectees. The Entrant Status Check webpage is the only way to see selections.

Additional Information: The Diversity Visa program provides for 55,000 immigrant visas to be issued to individuals from countries with low levels of immigration to the United States. Individuals register during an annual registration period and are selected through a random lottery. The registration period for fiscal year 2024 Diversity Visas opened Oct. 5, 2022, and closed Nov. 8, 2022.

Individuals who entered the Diversity Visa 2023  program have until Sept. 30, 2023, to check the status of their entry. The DV2023 registration period was from Oct. 6, 2021, through Nov. 9, 2021.

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.

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.

U.S. Immigration and Customs Enforcement announced Thursday that it would give employers 30 days to reach compliance with Form I-9 document inspection requirements once COVID-related I-9 flexibilities come to an end on July 31, 2023.

Key Points:

  • In March 2020, ICE introduced Form I-9 flexible measures that allow employers operating remotely because of COVID-19 to verify employee employment eligibility documents virtually, e.g., by fax, email or video.
  • These measures were extended several times, most recently in October 2022. ICE’s announcement Thursday confirms that these measures will remain in place for eligible employers through July 31, even after the COVID-19 public health emergency ends on May 11.
  • Under the guidance, employers that follow virtual procedures must comply with certain guidelines when “normal operations” resume. Initially, this included conducting physical inspections of documents that were viewed remotely within three business days; ICE has now extended that period to 30 days from the date the temporary measures expire, i.e., until Aug. 30, 2023.

Additional Information: The Department of Homeland Security continues to work on a rule that would give ICE authority to allow remote inspection of documents in some cases. The agency published a proposed rule in August 2022 and received more than 500 public comments, including one from BAL. DHS is currently reviewing the public comments and plans to issue a final rule later this year.

BAL Analysis: The 30-day grace period will give employers some additional time to review documents in person once the temporary flexibilities end; however, this is still a tight time frame, particularly given that some employers have been relying on the temporary policy for more than three years. BAL continues to encourage companies that have not yet started in-person reviews to start planning as soon as possible. BAL will continue to monitor the development of DHS’ new I-9 rule and will provide updates as information becomes available.

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.