The U.S. Embassy in India has announced that certain Indian nationals can now use the interview waiver process when applying for a new visa.

Key Points:

  • Indian nationals with “clearance received” or “department authorization” on their previous visas can now use the interview waiver process to apply for a new visa.
  • Foreign nationals should visit this website to determine if they qualify to apply for a visa interview waiver in India.
  • Individuals applying through the interview waiver process should allow at least three weeks from the time a passport has been accepted at the Visa Application Center until the passport is delivered or they are notified that the passport is ready for pickup.

Additional Information: The State Department previously authorized consular officers to waive the in-person interview requirement for travelers applying for F, H-1, H-3, H-4, non-blanket L, M, O, P, Q and academic J visas who were previously issued any type of visa if they are applying for a visa in their country of nationality or residence. Foreign nationals renewing any nonimmigrant visa in the same category within 48 months of expiration are also eligible for interview waivers. Applicants should keep in mind that a consular officer may request an interview even if eligible under the interview waiver criteria. Visa processing may take longer than three weeks, including during the summer months when visa demand is high. More information regarding the interview waiver process 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 U.S. State Department has provided border crossing information to U.S. citizens who are trying to leave Sudan.

Key Points:

  • S. citizens leaving Sudan should check this website for country-specific border crossing instructions. The State Department has provided instructions for those traveling to Central African Republic, Chad, Egypt, Eritrea, Ethiopia and South Sudan.
  • The U.S. government and international partners are assisting U.S. citizens in Port Sudan, where there are options available to leave the country. For those who are able to depart Port Sudan via ferry, U.S. officials are receiving citizens in Jeddah, Saudi Arabia. U.S. citizens should contact U.S. Consulate General Jeddah with questions at (+966) 12 220 5000 or email Jeddahacs@state.gov.
  • U.S. citizens in Sudan should fill out this crisis intake form to receive options to leave Sudan as the security situation allows. Individuals do not need to submit this information again if they have already submitted information to the U.S. Embassy in Khartoum.
  • U.S. citizens in Sudan who are in need of assistance can call the State Department at 1-888-407-4747 (from the United States) or 1-202-501-4444 (from overseas) and enroll in the Smart Traveler Enrollment Program if they have not done so already.

Additional Information: As of April 22, the U.S. Embassy in Khartoum, Sudan, is no longer offering routine or emergency consular services. The State Department suspended such services until further notice. The situation is “violent, volatile and extremely unpredictable, particularly in the capital city Khartoum,” the Department stated.

BAL Analysis: Companies with employees in the country are encouraged to follow State Department information and warnings closely. Wait times at crossing points could vary widely and change quickly. BAL will continue to monitor developments regarding the security situation in Sudan and will provide more information as it 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 has suspended operations and evacuated all U.S. employees and their family members from the U.S. Embassy in Khartoum, Sudan.

Key Points:

  • As of April 22, the U.S. Embassy in Khartoum, Sudan, is no longer offering routine or emergency consular services. The State Department suspended such services until further notice.
  • U.S. citizens in Sudan should fill out this form to receive options to leave Sudan as security conditions allow. Individuals do not need to submit this information again if they have already submitted information to the U.S. Embassy in Khartoum.
  • U.S. citizens in Sudan who are in need of assistance can call the State Department at 1-888-407-4747 or 1-202-501-4444 and enroll in the Smart Traveler Enrollment Program if they have not done so already.

Additional Information: The State Department reissued a “do not travel” warning for Sudan because of ongoing armed conflict throughout the country, including heavy fighting between various political and security groups. The situation is “violent, volatile and extremely unpredictable, particularly in the capital city Khartoum,” the Department stated.

As of April 22, the State Department has not designated another U.S. Embassy for processing immigrant visa applications for those living in Sudan. Generally, nonimmigrant (temporary) visa applicants from Sudan can apply at any U.S. embassy or consulate where they are physically present and can obtain an appointment. More information regarding the State Department’s announcement is available here.

BAL Analysis: Companies with employees in the country are encouraged to follow State Department information and warnings closely. BAL will continue to monitor developments regarding the security situation in Sudan and will provide more information as it 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.

Immigration and business organizations continue to voice their concerns about U.S. Citizenship and Immigration Services’ proposal to dramatically increase filing fees and urge the agency to improve services.

In January, USCIS published a proposed rule that would raise fees for immigration benefit requests by a weighted average of 40% — and more for most high-skilled classifications. In a joint comment submitted last month, the American Immigration Lawyers Association and the American Immigration Council objected to the proposal, saying that USCIS is failing to fulfill its promises to stakeholders.

“We believe any request to increase fees for these unkept promises must incorporate significant process improvements and specific implementation timelines that fundamentally change the existing paradigm of slow and inefficient service,” the comment said.

USCIS has said the increased fees would allow the agency “to more fully recover its operating costs, reestablish and maintain timely case processing, and prevent the accumulation of future case backlogs.”

The agency accepted comments on the proposed rule through March 13. After a delay in publishing some of the comments, the government’s rulemaking portal now shows USCIS received nearly 8,000 comments on the proposed fee hikes. Comments are available for public review here.

Groups such as Business Roundtable, Compete America, the Worldwide Employee Relocation Council (WERC) and the Society for Human Resource Management (SHRM) say they understand that, as a fee-funded agency, USCIS must adjust fees from time to time. They say, however, USCIS must be clearer about how it is calculating the proposed fees and should take additional steps to improve services.

Among the more common critiques:

  • The steep fee increases would harm U.S. businesses and hurt the country’s ability to be economically competitive.
  • USCIS has not been transparent is saying how it reached the proposed fee levels, including the $600 Asylum Program Fee surcharge on key employment-based filings, or in establishing measurable goals to show how it would improve services with the increased funding.
  • The agency could do more to reduce inefficiencies such as excessive requests for evidence and improve online filing options before raising fees by such substantial amounts.
  • USCIS should not adopt the proposal to lengthen premium-processing timelines by using business days rather than calendar days.

Opposition to the current proposal has come from throughout the business and immigration communities, including from humanitarian groups and organizations representing farmers, artists, athletes and colleges and universities.

The Presidents’ Alliance on Higher Education and Immigration said that even small fee increases can have a significant negative impact on international students, refugees, Deferred Action for Childhood Arrivals (DACA) recipients or anyone seeking to apply for naturalization. The organization called on Congress to “provide sufficient funding through annual appropriations, rather than saddling applicants seeking unrelated benefits with the responsibility of funding USCIS.”

BAL Analysis: USCIS has not raised fees since 2016, and employers and business and immigration organizations understand that fees do have to be adjusted. Stakeholders have continued to express concern, however, about the amount of the proposed increases, the $600 Asylum Program Fee surcharge and the extent to which agency services will improve with additional funding. The proposal would impose significant costs on employers; however, USCIS may make adjustments to its proposal. USCIS has also noted that fee amounts could change if Congress appropriates additional funding to the agency.

USCIS is now in the process of reviewing the nearly 8,000 comments it received, and the agency must consider them in formulating a final rule. Higher fees will not take effect for at least several months, and the possibility of litigation means implementation could be delayed even further. BAL will provide updates as information becomes available. In the meantime, companies can use BAL’s fee calculator to estimate the impact of the proposed fees on their programs.

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 extended the temporary suspension of the biometrics submission requirement for certain Form I-539 applicants.

Key Points:

  • The previously announced suspension, which was initially in place until May 17, 2023, has been extended through Sept. 30, 2023.
  • This suspension applies to applicants filing Form I-539 requesting:
    • Extension of stay in or change of status to H-4 nonimmigrant status.
    • Extension of stay in or change of status to L-2 nonimmigrant status.
    • Extension of stay in or change of status to E-1 nonimmigrant status.
    • Extension of stay in or change of status to E-2 nonimmigrant status (including E-2C (E-2 CNMI Investor)).
    • Extension of stay in or change of status to E-3 nonimmigrant status (including those selecting E-3D).
  • Form I-539 applicants who have already received a biometric services appointment notice should attend their scheduled appointment. The agency reiterated that it retains the right to request biometrics and schedule appointments on a case-by-case basis.
  • Form I-539 applicants who meet the biometrics suspension criteria do not need to submit the $85 biometric services fee for Form I-539 during the suspension period.

Additional Information: USCIS stated that it plans to establish a permanent biometrics exemption for all Form I-539 applicants in the coming months. More information regarding this plan is available in the USCIS Fiscal Year 2022 Progress Report.

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 White House announced a plan last week to extend Medicaid and Affordable Care Act healthcare coverage to Deferred Action for Childhood Arrival recipients.

Key Points:

  • In a statement, the White House said the Department of Health and Human Services will soon propose a rule amending the definition of “lawful presence,” for purposes of Medicaid and Affordable Care Act coverage, to include DACA recipients.
  • The proposed rule is expected by the end of April and, if finalized, would make DACA recipients eligible for Medicaid and Affordable Care Act coverage for the first time.
  • Under the proposed rule, DACA recipients would be able to apply for coverage through the Health Insurance Marketplace, where they would be able to qualify for financial assistance based on income, and through their state Medicaid agency.
  • In a fact sheet posted online, the White House reiterated its support for DACA, calling on Congress to pass legislation to protect Dreamers and providing DACA recipients a list of available resources, including social services, educational resources, job opportunities and tax credits.

Background: The Biden administration published a regulation to “preserve and fortify” DACA in August. The Fifth Circuit Court of Appeals is weighing the legality of the regulation after it ruled in October that the Obama administration did not follow proper procedures in creating DACA in 2012.

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. 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 possible.

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.

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

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 Jan. 1, 2011.
  • All other countries under EB-2 will retrogress over four months to Feb. 15, 2022.

EB-3

  • China EB-3 will advance five months to April 1, 2019.
  • India EB-3 will remain at June 15, 2012.
  • All other countries under EB-3 will change from current to 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 must 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.

The State Department released the May Visa Bulletin, showing advancement for China EB-3 and no movement for other China and India categories under Final Action Dates and Dates for Filing. All other countries under EB-3 will no longer be current under Final Action Dates and Dates for Filing, and all other countries under EB-2 will retrogress under Final Action Dates.

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 Jan. 1, 2011.
  • All other countries under EB-2 will retrogress over four months to Feb. 15, 2022.

EB-3

  • China EB-3 will advance five months to April 1, 2019.
  • India EB-3 will remain at June 15, 2012.
  • All other countries under EB-3 will change from current to 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: 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 advance four months to June 1, 2019.
  • India EB-3 will remain at Aug. 1, 2012.
  • All other countries under EB-3 will change from current to 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 May. 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 March 31, 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 July and earlier.

Determinations January 2023 February 2023 March 2023
Adjudication 264 days 264 days 271 days
Audit Review 383 days 383 days 402 days

PWD Processing: As of March 31, 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 July and earlier for H-1B cases, and June 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 October 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 waived and modified Exchange Visitor Program regulations for some Ukrainian students on J-1 visas.

Key Points:

  • Eligible Ukrainian students are now exempt from the “full course of study” requirement. And are now allowed to work on- or off-campus for more than 20 hours a week and for longer than twelve months.
  • Degree-seeking Ukrainian students can limit their course work to half of their academic institutions’ definition of a full-course of study; non-degree-seeking Ukrainian students can reduce participation in their academic programs from full- to part-time.
  • Sponsors can grant advanced, written employment approval to last beyond the twelve months that the provision currently allows.
  • Individuals eligible for Special Student Relief must have continuously resided in the United States since April 11, 2022.

Additional Information: Special Student Relief with respect to program status and employment for J-1 Ukrainian students does not apply to Federal Work-Study jobs. The waived and modified regulations will remain in effect until at least Oct. 23, 2023, unless the U.S. government ends the arrangement early or both the U.S. and Ukrainian governments extend its end date. The full Federal Register notice is available here.

BAL Analysis: The temporary changes of the Exchange Visitor Program regulations only address conditions that eligible Ukrainian exchange visitors must meet to be in status and comply with Exchange Visitor Program eligibility requirements. The State Department modified the requirements so that it can extend Special Student Relief to eligible Ukrainian J-1 students in the U.S. to mitigate the impact of Russia’s invasions of Ukraine has on them.

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.