The Department of Homeland Security (DHS) has posted the text of a rule to “preserve and fortify” Deferred Action for Childhood Arrivals (DACA).

Key Points:

  • The rule is scheduled to be published in the Federal Register Aug. 30 and take effect 60 days later. A prepublication version is available here.
  • DACA shields hundreds of thousands of individuals who were brought to the U.S. unlawfully as children from deportation and allows them to apply for work authorization.
  • While the program has strong support from employers, it has been the subject of extensive litigation. A three-judge panel with the Fifth Circuit Court of Appeals heard arguments last month in the U.S. Justice Department’s appeal of a 2021 district court ruling that DHS did not follow proper procedures when establishing DACA.
  • The district court partially stayed its order in 2021, allowing DACA beneficiaries to continue to renew their DACA grants and work authorization. DHS may not adjudicate initial DACA applications.
  • The DHS regulation was crafted to protect DACA from legal challenges; however, additional litigation is likely after the regulation is published.

Background: The Obama administration created DACA in 2012. Upon taking office, President Joe Biden directed DHS to “preserve and fortify” the program. DHS proposed the DACA regulation in September 2021 and received more than 16,000 comments on the proposal last fall. The final version of the rule cleared White House review last week.

BAL Analysis: While the Biden administration has taken steps to protect DACA, the publication of the rule will not immediately change the status quo. Currently, DHS continues to adjudicate only renewal applications (DACA and employment authorization) and advance parole requests for existing DACA recipients. For more information, please visit BAL’s DACA Resource Center here. BAL continues to review the rule and will provide updates on important developments in the ongoing litigation.

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

Copyright © 2022 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 is urging U.S. citizens to leave Ukraine immediately as Russia increases its efforts to strike civilian and government facilities.

Key Points:

  • The State Department said it has information that indicates Russia may increase strikes on Ukraine’s civilian infrastructure and government facilities in the coming days.
  • U.S. citizens are advised to leave Ukraine immediately using privately available ground transportation if it is safe to do so.
  • The State Department continues to ask U.S. citizens in Ukraine to complete an online form to make it easier for U.S. officials to communicate with them directly. More information regarding what the U.S. can do to assist its citizens in a crisis overseas is available here.
  • Those who need immediate assistance can call +1 (888) 407-4747 (from the U.S.), +1 (202) 501-4444 (from overseas) or email KyivACS@state.gov.

Additional Information: More information regarding actions U.S. citizens can take to increase their safety is available here.

BAL Analysis: The situation in Ukraine may change with little or no notice and companies with employees in the country are encouraged to follow State Department information and warnings closely.

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

Copyright © 2022 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 (USICS) will hold a webinar next week on “Operation Allies Welcome” (OAW) and ongoing immigration support available to Afghan nationals.

Key Points:

  • The webinar will be held on Sept. 1 from 3 to 4 p.m. EST.
  • USCIS Director Ur M. Jaddou will give opening remarks on the work in support of OAW, and USCIS officials will provide more information regarding immigration pathways available to Afghan nationals in the U.S.
  • To register for the webinar, visit the USCIS public engagement page.
  • Once registered, individuals will receive a confirmation email with additional details, including how to submit questions in advance by Aug. 23.

Additional Information: President Joe Biden announced the creation of “Operation Allies Welcome” on Aug. 29, 2021, framing it as a key part of the U.S.’s efforts to support vulnerable Afghans. Since OAW’s creation, the Department of Homeland Security (DHS) has led the effort to help Afghan nationals, including those who worked alongside the U.S. in Afghanistan for the past two decades, to immigrate to the U.S. legally. Recent reporting indicates that the Biden administration is developing a portal to streamline the reunification process for Afghans and their families left behind in Afghanistan. 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 © 2022 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.

United States Citizenship and Immigration Services (USCIS) announced today that it has received a sufficient number of petitions to reach the congressionally mandated cap for H-1B visas for the 2023 fiscal year. The agency will not conduct a second H-1B registration lottery.

Key Points:

  • USCIS conducted the H-1B registration lottery on March 29, selecting 127,600 registrations from a pool of 483,927.
  • USCIS said Tuesday that it has completed sending non-selection notifications to registrants’ online accounts. Accounts for those who were not selected will show: “Not Selected: Not selected – not eligible to file an H-1B cap petition based on this registration.”
  • USCIS will continue to accept cap-exempt H-1B petitions, including petitions to:
    • Extend the amount of time a current H-1B worker may remain in the U.S.
    • Change the terms of employment for current H-1B workers.
    • Allow current H-1B workers to change employers.
    • Allow current H-1B workers to work concurrently in additional H-1B positions.

BAL Analysis: USCIS’s announcement confirms that there will not be a second FY 2023 lottery. The agency received a record number of registrations in March, a sign of the ongoing popularity of the H-1B program and the high demand for a limited number of visas. BAL will continue to follow developments related to the H-1B program 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 © 2022 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 rule to “preserve and fortify” Deferred Action for Childhood Arrivals (DACA) has cleared White House review.

Key Points:

  • The text of the rule is not yet available.
  • The White House Office of Management and Budget (OMB) completed its review of the rule last week. This is the final step in the regulatory process before publication in the Federal Register.
  • The Department of Homeland Security (DHS) will post the text of the regulation for public inspection at least one day before publishing it.
  • The rule will likely have a 60-day delayed effective date.
  • DHS proposed the regulation in September 2021 and received more than 16,000 comments on the proposal last fall.

Background: The Obama administration created DACA in 2012. While the program has strong support from employers, it has been the subject of extensive litigation. DHS crafted the regulation in part to protect the program from legal challenges; however; additional litigation is likely after the regulation is published.

BAL Analysis: Currently, DHS is adjudicating only renewal applications (DACA and employment authorization) and advance parole requests for existing DACA recipients. BAL continues to monitor developments related to DACA and will provide updates as information becomes available. For more information, please 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 © 2022 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.

In a recent briefing, Julie Stufft, the Deputy Assistant Secretary for Visa Services in the State Department’s Bureau of Consular Affairs, provided an update on visa services, indicating that visa processing times abroad are improving, but that progress varies across visa-adjudicating posts. “The bottom line is that we’re recovering faster than we projected after a near-complete shutdown and freezing of our consular operations overseas during the pandemic,” Stufft said. “But this progress is still uneven across many of our posts overseas and we will need some additional time and tools to resolve wait times everywhere worldwide, which is our goal.”

Key Points:

  • State Department posts overseas have adjudicated about 70 percent more nonimmigrant visas than last year.
  • Each month, posts overseas are adjudicating about 800,000 nonimmigrant visa applications—about 80% of pre-pandemic levels.
  • Immigrant visa processing is at about 95% of pre-pandemic levels at posts overseas.
  • The State Department is actively engaged in increasing the number of consular officers who are overseas adjudicating visas. Officials have doubled consular officer hiring this year from last year’s numbers.
  • The State Department has a growing team of adjudicators who are supporting high-demand posts by remotely adjudicating visa applications when possible.”

Background: The COVID-19 pandemic and related staffing issues limited the number of visas the State Department could process at embassies and consulates abroad. This led to a backlog of visa applications, delaying adjudication across visa categories. Early this year, the State Department announced that it would increase hiring to help address the problem.

BAL Analysis: While the State Department is working to address visa backlogs, continued processing delays should be expected. Service levels vary from post to post, and some applicants continue to face extensive delays in scheduling interviews or obtaining their visas.

Strategies for obtaining visas in a timely manner will vary from case to case. For example, the State Department has said that foreign nationals who face delays at their home consulate may be able to travel to a consulate in a third country to obtain services. In practice, this has proved challenging—especially for B1/B2 visa applicants—and third-country nationals often face difficulty getting an appointment. Wait times online may not be reflective of actual wait times for third-country nationals. Expedited services may be available in some cases involving business, medical or humanitarian travel; however, the availability of these services has also varied from post to post.

BAL will continue to monitor efforts to address processing delays and will provide more information as it becomes available. Employers and employees should continue to consult their BAL professional before planning international travel.

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

Copyright © 2022 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 (DHS) will publish a proposed rule tomorrow that would allow the agency to provide optional alternatives to physical document examination in some scenarios in the Form I-9 process.

Key Points:

  • The proposal would not make immediate changes to the Form I-9 process.
  • The proposal would give DHS formal authority to allow alternatives to in-person review of physical Form I-9 documents:
    • As part of a pilot program.
    • Upon DHS’ determination that such procedures offer an equivalent level of security.
    • As a temporary measure to address a public health or national emergency.
  • The proposed rule will be published in the Federal Register tomorrow, Aug. 18. A prepublication version is available here. Once the proposal is published, DHS will accept comments from the public for 60 days.
  • DHS will also propose changes to the Form I-9 and instructions to allow employers to indicate when they rely on alternative document examination procedures.
  • DHS will seek input from the public on ways to reduce risks to the integrity of any alternative procedure, avoid discrimination and protect privacy interests.

Background: U.S. Immigration and Customs Enforcement (ICE) has provided temporary Form I-9 flexibilities that allow for remote document verification in some cases for eligible employers who are operating remotely because of COVID-19. The temporary flexibilities are currently scheduled to expire on Oct. 31. U.S. employers and business coalitionsincluding BAL, have urged DHS to make remote verification available permanently.

BAL Analysis: While the DHS proposal does not directly authorize remote document examination, it would create a legal structure that would allow the government to use alternative processes in the future. DHS also said it is “exploring alternative options” including making some of the COVID-19 measures permanent. BAL will continue to follow the possible changes on the Form I-9 process 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 © 2022 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 (DHS) has updated its COVID-19 vaccination requirements for individuals paroled into the U.S. through the “United for Ukraine” program.

Key Points:

  • Before traveling to the U.S., “United for Ukraine” beneficiaries who are six months and older must submit an attestation that they received at least one dose of an COVID-19 vaccine approved by the Food and Drug Administration or World Health Organization.
  • After entering the U.S., beneficiaries who are six months and older must submit another attestation that they have or will be fully vaccinated within 90 days after arrival or within 90 days after turning six months old.
  • Previously, beneficiaries younger than 5 years old qualified for an exception to the COVID-19 vaccination requirement because the vaccine was not approved for use in that age group.
  • Beneficiaries must submit their attestations through their USCIS online account. More information regarding the “Uniting for Ukraine” attestation requirements is available here.

Additional Information: Individuals will not be required to submit an attestation if they qualify for a vaccination exception. More information regarding “Uniting for Ukraine” is available on this DHS website. BAL will continue to follow developments specifically affecting Ukrainian nationals and will provide updates on important immigration 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 © 2022 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.

Priority-date cutoffs will remain the same in key employment-based categories next month, according to the Final Action Dates published in State Department’s September Visa Bulletin.

Key Final Action Dates:

EB-1

  • All countries under EB-1 will remain current.

EB-2

  • China EB-2 will remain at April 1, 2019.
  • India EB-2 will remain at Dec. 1, 2014.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will remain at April 22, 2018.
  • India EB-3 will remain at Feb. 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 Current Current Current Current Current
EB-2 Current April 1, 2019 Current Dec. 1, 2014 Current Current
EB-3 Current April 22, 2018 Current Feb. 15, 2012 Current Current

Additional Information: U.S. Citizenship and Immigration Services (USCIS) confirmed it would use the Final Action Dates chart to determine employment-based filing eligibility in September. The Dates for Filing chart will not apply.
This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2022 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 proposed rule that would allow the Department of Homeland Security (DHS) to provide optional alternatives to physical document examination in the Form I-9 process has cleared White House Office of Management and Budget (OMB) review.

Key Points:

  • The text of the proposed rule is not yet available, but the DHS has said it would “allow the Secretary (of Homeland Security) to authorize alternative document examination procedures in certain circumstances or with respect to certain employers.”
  • OMB review is the last step in the rulemaking process before the agency can publish the proposal. DHS will post the text for public inspection at least a day before the proposed rule is officially published.
  • The proposal will go through a notice-and-comment period, during which any member of the public may submit feedback, before being finalized.
  • U.S. Immigration and Customs Enforcement (ICE) has provided temporary Form I-9 flexibilities that allow for remote document verification in some cases for eligible employers who are operating remotely because of COVID-19. The temporary flexibilities are currently scheduled to expire on Oct. 31.

BAL Analysis: DHS said that the proposed rule would “reduce burdens on employers and employees while maintaining the integrity of the employment verification process.” U.S. employers and business coalitions, including BAL, have urged USCIS to make remote verification available permanently. BAL will continue following the proposal through the regulatory process 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 © 2022 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.