The Department of Homeland Security has created a streamlined process for considering deferred action requests from noncitizen workers who are victims of, or witnesses to, labor violations.

Key Points:

  • The streamlined process builds on DHS’ longstanding policy of considering deferred action on a case-by-case basis in order to protect employees from immigration-related retaliation if they cooperate with workplace investigations.
  • Requests for deferred action must include a letter from a federal, state or local labor agency asking DHS to consider deferred action on behalf of workers employed by companies subject to investigation.
  • Grants of deferred action will typically last for two years. Individuals who are granted deferred action may apply for employment authorization, provided they can show an economic necessity for employment and meet other eligibility criteria. Deferred action may be extended, depending on several factors, including the status of the investigation in question.

Additional Information: The new process is part of DHS’ worksite enforcement strategy announced in October 2021. As part of the strategy, DHS directed U.S. Immigration and Customs Enforcement, U.S. Customs and Border Protection and U.S. Citizenship and Immigration Services to “update policies to enhance the Department’s impact in supporting the enforcement of employment and labor standards.” More information, including an FAQ page, is available here on the DHS website.

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 released the February Visa Bulletin, showing no movement for priority-date cutoffs for Final Action Dates and Dates for Filing charts EB-1, EB-2 and EB-3 categories.

Final Action Dates: Key Movements

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 Oct. 8, 2011.
  • All other countries under EB-2 will remain at Nov. 1, 2022.

EB-3

  • China EB-3 will remain at Aug. 1, 2018.
  • India EB-3 will remain at June 15, 2012.
  • All other countries under EB-3 will remain current.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China El Salvador Guatemala Honduras India Mexico Philippines
EB-1 Current Feb. 1, 2022 Current Feb. 1, 2022 Current Current
EB-2 Nov. 1, 2022 June 8, 2019 Nov. 1, 2022 Oct. 8, 2011 Nov. 1, 2022 Nov. 1, 2022
EB-3 Current Aug. 1, 2018 Current June 15, 2012 Current Current

Dates for Filing: Key Movements

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 Sept. 1, 2018.
  • India EB-3 will remain at Aug. 1, 2012.
  • All other countries under EB-3 will remain current.

Dates for Filing for Employment-Based Preference Cases:

Preference All Other Countries China El Salvador Guatemala Honduras India Mexico Philippines
EB-1 Current June 1, 2022 Current June 1, 2022 Current Current
EB-2 Dec. 1, 2022 July 8, 2019 Dec. 1, 2022 May 1, 2012 Dec. 1, 2022 Dec. 1, 2022
EB-3 Current Sept. 1, 2018 Current Aug. 1, 2012 Current Current

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 February. 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.

U.S. Citizenship and Immigration Services announced Thursday that it would soon launch the final phase of its premium processing expansion for Form I-140 petitions under the EB-1 and EB-2 classifications.

Key Points:

  • Beginning Jan. 30, USCIS will accept premium processing requests for:
    • All pending E13 multinational executive and manager petitions and E21 NIW petitions.
    • All initial E13 multinational executive and manager petitions and E21 NIW petitions.
  • Earlier phases of the premium processing expansion only covered specific previously filed petitions in these categories.

Additional Information: USCIS is taking a phased approach to expanding premium processing as part of a broader effort to reduce backlogs and provide relief to foreign nationals affected by processing delays.

USCIS said it would further expand premium processing in March to certain F-1 students seeking Optional Practical Training (OPT) and F-1 students seeking STEM OPT extensions who have pending Forms I-765, Application for Employment Authorization. The agency plans to extend premium processing in April to OPT and F-1 students seeking STEM OPT extensions filing initial Forms I-765.

USCIS also said it is working toward expanding premium processing in May to certain student and exchange visitors with pending Forms I-539, Application to Extend/Change Nonimmigrant Status and in June to student and exchange visitors filing initial Forms I-539.

BAL Analysis: The extension of premium processing to additional benefit categories will shorten processing times for eligible applicants who pay the applicable fee. USCIS said it would provide more detailed information next month regarding the OPT/STEM OPT expansions in March and April. BAL 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.

The U.S. Department of Labor’s Office of Foreign Labor Certification has published assignment groups for employers seeking cap-subject H-2B visas for workers with April 1 start dates.

Key Points:

  • Between Jan. 1 and Jan. 3, OFLC received 8,693 H-2B applications covering 142,796 worker positions.
  • OFLC completed its randomization process and assigned applications to one of seven groups, from A to G. Group A includes enough worker positions to meet the semiannual H-2B cap of 33,000. Each subsequent group includes no more than 20,000 worker positions.
  • OFLC, through the National Processing Center, will now process applications in order of assignments and issue Notice of Deficiencies or Notice of Acceptances to Employers.
  • Upon receiving a Notice of Acceptance, employers will initiate recruitment in an effort to hire U.S. workers for the position in question, including posting a notice of the job opportunity for 15 business days. Employers then respond to the Notice of Acceptance in order to receive a Temporary Labor Certification, receipt of which allows employers to move forward with the I-129 Petition for Nonimmigrant Worker before DHS.
  • Fifteen days after USCIS announces that enough I-129s have been filed to reach the 33,000 cap, OFLC will begin releasing visas available under the supplemental allotment for the second half of FY 2023. Of the 64,716 visas available in the supplemental allotment, 20,000 are reserved specifically for nationals of El Salvador, Guatemala, Haiti and Honduras.

BAL Analysis: The number of applications demonstrates the ongoing popularity of the H-2B program. The limited number of visas means that even with the supplemental allotment, some employers will not be able to hire workers for whom they had submitted applications. Employers are encouraged to work closely with BAL on H-2B strategies, including the possibility of recruiting workers from El Salvador, Guatemala, Haiti and Honduras. BAL will continue following H-2B developments 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.

The U.S. State Department launched a form yesterday for Afghan parolees to file to seek family reunification.

Key Points:

  • Afghan parolees can now file the “Family Reunification Assistance for Afghan Parolees’ Immediate Family Members Outside the United States” form, Form DS-4317, to seek family reunification, including those who were granted Temporary Protected Status.
  • Form DS-4317 is located on the Family Reunification page, a new section of the Department’s Afghanistan Inquiries page, which directs individuals seeking reunification to available pathways.
  • Reunification procedures will depend on an individual’s immigration status or method of entry to the United States.

Additional Information: Afghan nationals can check this website, the U.S. Mission to Afghanistan website or the U.S. Citizenship and Immigration Services website for information on how they can seek reunification.

BAL Analysis: The State Department launched the Afghan family reunification page to help Afghan families that are still separated and seeking reunification. Parolees should review the requirements listed on Form DS-4317 before filing to seek family reunification. BAL will continue to follow developments specifically affecting Afghan nationals 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.

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. companies laid off tens of thousands of employees in the final months of 2022 as employers tightened their belts amid fears of an economic downturn. While layoffs are always challenging, they are particularly difficult for nonimmigrant visa holders whose lawful presence in the United States is tied to their employment.

Regulations provide up to 60 days as a grace period for workers in E-1, E-2, E-3, H-1B, H-1B1, L-1, O-1 or TN classifications (and their dependents) if they are terminated from previously approved employment. Visa holders cannot work during this time but remain eligible to change employers or change immigration status.

As outlined on a recently launched U.S. Citizenship and Immigration Services web page, options for nonimmigrants may include:

  • Maintaining their current nonimmigrant status by finding a new employer.
  • Changing to a different nonimmigrant status with a new employer, e.g., some L-1 workers may be eligible for new employment under the TN, E-3 or H-1B1 classifications.
  • Becoming the dependent of a nonimmigrant spouse, e.g., applying for an H-4 or L-2 visa.
  • Applying for F-1 status and enrolling as a full-time student.
  • Applying for adjustment of status in an immigrant classification that permits self-petitioning, e.g., EB-1 Extraordinary Ability, EB-2 National Interest Waiver or EB-5 Immigrant Investors.
  • Remaining in the United States by applying for a B-1 or B-2 visitor visa.
  • Departing the United States and applying for a new visa and/or seeking readmission to the United States while abroad.

Not all of these options include work authorization. For example, B-1 and B-2 visitor visa holders are barred from “performing skilled or unskilled labor” in the United States. F-1 students may engage in limited employment. Dependents are permitted to work incident to status in some cases, but are barred from work authorization in others.

The post-termination grace period ends 60 days after termination or until the end of the previously authorized validity period, whichever is shorter. A petition to change employers or change status stops the accrual of unlawful presence until the petition is adjudicated. H-1B workers can begin working for a new employer as soon as a change of employer petition is filed. More information is available on USCIS’ new Options for Nonimmigrant Workers Following Termination of Employment page.

BAL Analysis: Layoffs pose particular challenges for many nonimmigrant visa holders. While regulations provide a 60-day grace period, this is a tight window to find new employment or another basis to remain in the country. Individuals who lose a job are encouraged to seek immigration counsel to weigh their visa options and help focus their job search. BAL will continue following this issue 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.

Federal agencies have published their semiannual regulatory agenda, providing an indication of the Biden administration’s immigration priorities in the coming year.

Most of the proposed regulations were listed on previous regulatory agendas, though agency timelines have been adjusted in some cases. Highlights include:

  • H-1B requirements and oversight. The Department of Homeland Security plans to issue a proposed rule to “modernize” H-1B requirements and oversight and provide additional flexibility in the F-1 program. The changes may include:
    • Revising regulations related to the employer-employee relationship and providing flexibility for start-up entrepreneurs.
    • Implementing new guidelines for site visits.
    • Providing flexibility on start dates in limited circumstances.
    • Addressing “cap-gap” issues.
    • Strengthening the registration process to reduce the possibility of misuse and fraud.
    • Clarifying the requirement that an amended or new petition must be filed if there are material changes.

The regulatory agenda indicates the agency is targeting October 2023 to publish the proposal; the previous agenda had targeted May 2023.

  • Prevailing wage requirements. The Department of Labor is planning to publish a proposed rule to strengthen wage protections for the temporary and permanent employment of certain foreign nationals. According to DOL, the rule will establish a new wage methodology for setting prevailing wage levels for the H-1B/H-1B1/E-3 and PERM programs. The agency restarted the process to amend wage obligations after a federal court vacated the rule that was scheduled to take effect in November 2022. The agenda now indicates DOL is targeting September 2023 to publish the proposal.
  • Form I-9 physical examination. DHS plans to finalize a rule that would allow the agency to provide alternatives to physical document examination in some scenarios in the Form I-9 process. In August, DHS published a proposed I-9 rule and is targeting May 2023 to publish the final rule. Temporary Form I-9 flexibilities are currently set to expire July 31, 2023.
  • USCIS and State Department fees. USCIS is currently accepting public comments on a proposal to raise fees by a weighted average of 40 percent. The regulatory agenda does not include a timeline for publication of a final rule; USCIS must complete several steps before the proposal is implemented. The new fees will not take effect for several months and the agency could make changes in formulating the final rule. Last month, the State Department submitted a final rule to increase nonimmigrant and special visa application processing fees to the White House Office of Management and Budget. The text of the rule is not available, but OMB review is the last step in the rulemaking process before it can be published. The regulatory agenda indicates the State Department is targeting March 2023 to publish the final rule.

Additional Information: Other items on the regulatory agenda include a proposal to amend regulations governing adjustment of status (target publication July 2023) and a final rule on State Department’s interview wavier policy (target publication April 2023). The agenda no longer includes a Trump-era proposal to eliminate the “B-1 in lieu of H” classification. The Trump administration published a proposed rule to eliminate the classification but never published a final rule. The State Department previously said it was “reconsidering” the rule and appears to have abandoned it for now.

The full regulatory agenda is available here.

BAL Analysis: While the changes the administration has outlined would have significant impact on immigration programs, they are at different stages in the rulemaking process, and policies are still being formulated. Proposed regulations are subject to a public notice-and-comment period during which members of the public may submit feedback. BAL will provide updates on individual regulations as they move through the rulemaking process.

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.

President Joe Biden announced a new program Thursday to allow nationals of Cuba, Haiti and Nicaragua to travel by air to the United States and apply for work authorization.

Biden announced the program in conjunction with a package of border enforcement plans. The Department of Homeland Security said it is based on similar programs for Venezuelans and Ukrainians launched last year.

Key Points:

  • Beginning today, up to 30,000 Cuban, Haitian, Nicaraguan and Venezuelan nationals per month will be admitted to the United States via parole for up to two years and will be eligible for work authorization.
  • Applicants will be considered on a case-by-case basis at the discretion of immigration officers and must pass national security and public safety screenings, have a supporter in the United States, complete vaccinations and fulfill other public health requirements.
  • Individuals who enter the United States, Mexico or Panama without authorization will generally be ineligible.
  • U.S.-based individuals and organizations seeking to become supporters must declare their ability to provide financial support and pass background checks. Individuals and organizational representatives can apply to support eligible individuals via  https://www.uscis.gov/CHNV.

Additional Information: DHS said the forthcoming border measures were designed to “limit irregular migration” and create “safe and orderly processes for people fleeing humanitarian crises” to come to the United States. The agency urged individuals to apply for travel authorization online and said they should not approach the U.S.-Mexico border to apply. More information is available on USCIS’ Processes for Cubans, Haitians, Nicaraguans, and Venezuelans page.

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. Embassy in Havana recently resumed all visa services for immigrant visa categories.

Key Points:

  • On Jan. 4, the U.S. Embassy in Havana resumed all immigrant visa services. This includes processing for immediate relative, family preference, diversity visa and K fiancé(e) visa categories.
  • Immigrant visa applicants whose appointments were originally scheduled at the U.S. Embassy in Georgetown, Guyana, will complete processing in Georgetown.
  • Diversity visa selectees are reminded that the U.S. Embassy in Havana is not an option for picking an interview location. Selectees should choose Georgetown for their interview location, and their cases will automatically be reassigned to Havana, unless they were already scheduled at Georgetown.
  • The U.S. Embassy in Havana’s consular section will continue to provide essential American Citizens Services and limited emergency nonimmigrant visa processing.

Additional Information: More information is available on the U.S. Embassy in Havana’s website.

BAL Analysis: The U.S. Embassy in Havana’s resumption of full immigrant visa services for Cuban nationals is welcome news, as many of these services have been suspended since 2017 amid a series of unexplained health incidents termed “Havana Syndrome.” The State Department said resumption is part of the broader expansion of the Embassy’s functions “to ensure safe, legal and orderly” immigration options for Cuban nationals. BAL 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.