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 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 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.

IMPACT — MEDIUM

The U.S. Department of State has ordered the temporary departure of non-emergency government personnel and eligible family members from the U.S Embassy in Niamey, Niger, due to a military coup against President Mohamed Bazoum.

Key Points:

  • Due to reduced personnel, the U.S. Embassy in Niamey remains open only for emergency assistance to U.S. citizens in Niger.
  • The U.S. Embassy advises U.S. citizens in Niger to limit unnecessary movement around Niamey. U.S. citizens who want to depart Niger and require assistance should register via the assistance request form available on the Niamey embassy’s website.

Additional Information: The State Department updated its travel advisory on Niger to Level 4: Do Not Travel due to military action related to the coup, civil unrest and ongoing threats of crime, terrorism and kidnapping. More information is available here. The State Department said it would continue to provide updates on embassy and consulate websites and on travel.state.gov.

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.

U.S. Citizenship and Immigration Services has published a new Form I-9 that will become mandatory Nov. 1.

The agency also provided updated guidance for employers that relied on temporary Form I-9 flexible measures during the COVID-19 pandemic, and U.S. Immigration and Customs Enforcement announced it is considering a remote verification pilot program for employers who are not enrolled in E-Verify.

Key Points:

  • New Form I-9: On Tuesday, USCIS published a streamlined version of the Form I-9. Employers may begin using the new edition (dated “08/01/2023”) immediately, but are not required to until Nov. 1, 2023. A summary of the changes on the new form is available here. The form itself is available here.
  • Updated guidance: USCIS confirmed 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.
    • The follow-up reviews can be completed under the alternate procedures if the employer (1) was enrolled in E-Verify at the time the employee was hired, (2) created an E-Verify case for the employee in question and (3) performed a remote Form I-9 document inspection for the employee under the temporary measures between March 20, 2020, and July 31, 2023. More information on these requirements is available on the E-Verify website.
    • USCIS guidance on notating Form I-9 when completing reviews due Aug. 30 is available here.
  • ICE pilot program: ICE posted a notice Wednesday indicating it would accept comments on a potential pilot program to allow non-E-Verify employers to complete Forms I-9 virtually. Currently, the alternative review option is only available to qualified employers that are in “good standing” in E-Verify. Information about the potential pilot program is available here.

BAL Analysis: Employers are encouraged to familiarize themselves with the new Form I-9 and should have plans in place to begin using the new version no later than Nov. 1. Employers are also reminded that they must complete follow-up Form I-9 document checks by Aug. 30 for employees whose I-9 documents were reviewed virtually during the pandemic. BAL will continue to follow the development of a possible pilot program for non-E-Verify employers and will provide updates as information becomes available.

This alert has been provided by 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. government took action this week to limit Hungarian citizens’ access to the Visa Waiver Program (VWP) due to security concerns over passports issued from 2011 to 2020.

Key Points:

  • Authorities reduced Electronic System for Travel Authorization (ESTA) validity from two years to one year for Hungarian nationals.
  • Instead of allowing multiple entries under the VWP, ESTAs for Hungarian citizens will be valid for only one entry to the United States.
  • The action was taken in response to ongoing concerns about the security of Hungarian passports issued from 2011 to 2020, which were issued “without stringent identity verification mechanisms in place,” according to David Pressman, U.S. Ambassador to Hungary, in an interview with Politico.
  • The change applies to all Hungarian passport holders, not just those with passports issued from 2011 to 2020.

Background: U.S. officials have been working with Hungary for years to address concerns about passport security, but said they took the unprecedented action to curtail VWP access due to Hungarian inaction on the matter.

‌This alert has been provided by 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 late Monday that it had completed the second H-1B registration lottery for the 2024 fiscal year.

Key Points:

  • The agency selected an additional 77,609 registrations in the second lottery, bringing the total number of registrations selected this year to 188,400.
  • USCIS said it has notified all prospective petitioners with selected registrations that they are eligible to file H-1B cap-subject petitions. The filing period will last at least 90 days.
  • Only petitioners with selected registrations may file H-1B cap-subject petitions for FY 2024, and only for the beneficiary named in the applicable selected registration notice.

Background: USCIS completed its initial lottery of H-1B cap-subject registrations in March, selecting 110,791 of 758,994 eligible registrations. Last week, USCIS announced it would conduct a second registration lottery, saying it had “recently determined that (the agency) would need to select additional registrations to reach the FY 2024 numerical allocations.”

BAL Analysis: With the additional selections in the second lottery, this year’s overall H-1B cap selection rate rose to 24.8%. This selection rate is roughly on par with last year’s selection rate of 26.9%, even with a surge in registrations this year. Employers should begin preparing to file full petitions for selected candidates and 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. 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.

COVID-era Form I-9 temporary measures come to an end today, a day before a new Department of Homeland Security I-9 regulation goes into effect.

Key Points:

  • Temporary COVID-19 measures that allowed employers to conduct some Form I-9 document checks remotely during the COVID-19 pandemic come to an end today.
  • A new DHS regulation establishing optional alternatives to in-person Form I-9 processing takes effect Tuesday, Aug. 1. Under the regulation, qualified E-Verify employers may begin using the alternative procedure, provided they meet all requirements outlined in the “Optional Alternative 1” notice.
  • The “alternative” program is optional. Employers who prefer to review documents in person may do so. Employers that do not meet the requirements for the new process must review I-9 documents in person.
  • USCIS has stated it will post a new Form I-9 version Aug. 1. Employers will continue to be able to use the previous version of the form through Oct. 31. It will no longer be valid starting Nov. 1.
  • Employers should monitor the USCIS “I-9 Central” page and M-274 Handbook for Employers for guidance on how to complete the Form I-9.

Reminder: Employers have until Aug. 30 to conduct follow-up document inspections for employees whose Form I-9 identity and work authorization documents were inspected remotely under the temporary COVID-19 measures. The follow-up inspections can be completed under the new DHS rule, provided the employer (1) was enrolled in E-Verify at the time the employee was hired, (2) created an E-Verify case for the employee in question and (3) performed a remote Form I-9 document inspection for the employee under the temporary measures between March 20, 2020, and July 31, 2023. Employers that do not meet these requirements must physically review documents by Aug. 30.

BAL Analysis: The new remote verification option is welcome news for employers, especially because it will be available in some cases to employers who must complete follow-up document review for employees hired during the pandemic. Employers are encouraged to continue working closely with BAL on Form I-9 compliance matters.

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.