Companies filing H-1B cap petitions for fiscal year 2023 are reminded that the 90-day filing period closes June 30.

Key Points:

  • U.S. Citizenship and Immigration Services (USCIS) conducted the FY 2023 H-1B lottery in late March.
  • USCIS opened the 90-day H-1B cap filing period for selected registrants on April 1.
  • Petitioners who have not yet filed a petition for candidates who were selected in the lottery must do so by June 30 in order for the petition to be considered.

Additional Information: USCIS received 483,927 registrations this year, a 56.8% increase over the 308,613 from last year. In each of the last two fiscal years, USCIS has conducted more than one lottery; however, the agency selected more registrations in the initial lottery this year and it is not clear that there will be a second lottery for FY 2023.

BAL Analysis: Companies should work with their BAL professional to ensure that their H-1B cap petitions are filed before the June 30 deadline. Employers may also wish to work with their BAL attorney to consider alternatives for registrations that were not selected in March’s lottery. BAL will continue to monitor whether USCIS will invite more registrants to submit H-1B petitions for FY 2023.

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. Supreme Court dismissed an appeal by a group of states seeking to defend the Trump-era public charge rule, leaving in place a lower court ruling that they could not intervene in the case. U.S. Citizenship and Immigration Services (USCIS) will continue to enforce its pre-Trump public charge rules and pursue rulemaking to formalize longstanding policy.

Key Points:

  • In August 2019, the Department of Homeland Security (DHS) published a final rule to redefine the public charge ground of inadmissibility in a way that could have significantly restricted immigration to the U.S., particularly among lower income applicants.
  • The rule faced a number of lawsuits, and several courts ruled to block or vacate the rule in 2020.
  • In March 2021, the Biden administration announced it would no longer defend the rule in court. USCIS then released updated guidance confirming that applicants would no longer need to provide documentation required under the 2019 rule.
  • In February 2022, USCIS proposed a regulation that largely formalizes this guidance, in an effort to “return to the historical understanding of the term ‘public charge.
  • A group of states, led by Arizona, attempted to intervene to defend the 2019 rule. The Supreme Court ruled Wednesday that it had “improvidently granted” the states’ appeal, which means the states will not be able to defend the rule.

BAL Analysis: The Supreme Court’s ruling maintains the status quo and means that USCIS will continue not enforcing the 2019 public charge rule. It is important to note that the Court did not weigh in on the legality of the Trump-era rule. In a concurring opinion, Chief Justice John Roberts emphasized that the Court was not ruling on the merits and the decision has no bearing on how the Court will treat any pending or future litigation on this issue. USCIS continues to conduct public charge inadmissibility determinations consistent with its 1999 Interim Field Guidance. BAL will continue to provide updates on developments relating to the public charge ground of inadmissibility.

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) and the U.S. State Department have announced new exemptions to ensure Afghans who would otherwise be eligible for the benefit or protection they are seeking are not automatically denied.

Adjudicating officers will apply these exemptions on a case-by-case, discretionary basis. The new exemptions may apply to the following individuals:

  • Afghans who supported U.S. military interests, specifically Afghans who fought or supported those who fought against the Taliban and those who fought against the Soviet occupation in Afghanistan.
  • Afghans employed as civil servants in Afghanistan from Sept. 27, 1996, to Dec. 22, 2001, or after Aug. 15, 2021. This group includes teachers, professors, postal workers, doctors and engineers, among others.
  • Afghans who gave insignificant or certain limited material support to a designated terrorist organization, including but not limited to cases where support was incidental or was provided in response to a reasonable threat of physical or economic harm.

Additional Information: Individuals will only qualify for the exemptions if they have undergone screening and vetting by the U.S. government and are determined to pose no risk to national security. A list of individuals who may be protected from certain automatic denials is available here.

BAL Analysis: BAL will continue to follow developments specifically affecting Afghan 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.

Employers and immigration advocates marked the 10th anniversary of Deferred Action for Childhood Arrivals (DACA) Wednesday by urging political leaders to take action to protect the program.

The Obama administration created DACA on June 15, 2012, shielding hundreds of thousands of “Dreamers” (immigrants who were brought to the U.S. unlawfully as children) from deportation and allowing them to apply for work authorization.

“As employers and business associations committed to a strong U.S. economy, we highly value the contributions of Dreamers in our workforces and communities and reiterate the urgent need to provide them with long-term certainty and stability in the only country they know as ‘home,’” said the National Immigration Forum in a letter to congressional leaders. The letter was signed by leading U.S. employers, business associations and immigration groups, including BAL.

Despite its broad popularity and importance to employers, DACA remains under threat. In July 2021, a federal judge in Texas ruled that the Department of Homeland Security (DHS) did not follow proper procedures when establishing the program. The Justice Department appealed the ruling, and the Fifth Circuit Court of Appeals will hear arguments in the case on July 6.

White House officials, including Vice President Kamala Harris, were scheduled to meet with a group of 20 Dreamers Wednesday to discuss DACA. The Biden administration has pledged to “preserve and fortify” DACA through the regulatory process. In September, DHS published a proposed DACA regulation that drew more than 16,000 comments last fall. DHS is expected to finalize the regulation in the coming months, though litigation challenging a final regulation is likely.

DACA proponents have long said that the only permanent solution for Dreamers is legislation. Business Roundtable CEO Joshua Bolten said in a statement Wednesday that it is “long past time to enact commonsense immigration reforms” including a “permanent legislative solution for DACA recipients, who were brought here as minors and now live in limbo under the temporary DACA program.”

The Coalition for the American Dream said it is “inexcusable” that Congress has not acted to end the “legal limbo” in which DACA recipients find themselves.

“Dreamers are critical members of our workforce, industries, and communities, and they have abided by the laws and regulations of our country where they have lived almost their entire lives,” the Coalition said. “The thousands of Americans businesses represented by the Coalition for the American Dream are proud to employ many of them and we are equally proud to have watched many Dreamers start their own businesses as they contribute greatly to the American economy.”

BAL Analysis: In the 10 years since it was created, DACA has shielded hundreds of thousands of beneficiaries from deportation and allowed them to work lawfully in the U.S. DACA recipients play a key role in the American workforce, and employers have repeatedly stressed the importance of protecting the program and providing long-term relief for Dreamers. 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.

The U.S. State Department recently published a Federal Register notice, removing the requirement that Diversity Visa entrants provide certain passport information.

Key Points:

  • Individuals submitting an electronic DV entry form are not required to provide a unique serial or issuance number associated with the principal entrant’s passport or claim an exemption to the passport requirement.
  • The final rule took effect on June 10, 2022.
  • Applicants will no longer be penalized for submitting inaccurate or incomplete passport information as it is no longer relevant to the applicant’s eligibility.
  • The full Federal Register notice is available here.

Background: In February 2022, a federal district court vacated the 2019 regulation that required DV entrants to submit valid passport information on their DV entry forms. The State Department removed the regulation to comply with the court’s ruling. Before the recent court ruling, entrants who submitted inaccurate or incomplete passport information would be automatically disqualified for that year’s DV selection.

BAL Analysis: BAL will continue to monitor changes to DV requirements and DV cases 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.

Countries around the world continue to lift COVID-19 entry restrictions, and many employers and employees are planning travel abroad this summer. COVID-19 continues to affect travel to the U.S., however, and BAL urges employees to take precautions, consult their BAL professional and weigh key considerations when planning international travel.

Key Considerations:

  • COVID-19 vaccination requirement. The U.S. continues to require most nonimmigrant foreign nationals entering or returning to the country by air to be fully vaccinated against COVID-19, with limited exceptions.
    • The vaccine must be recognized by the U.S. Food and Drug Administration (FDA) or the World Health Organization (WHO).
    • A similar requirement was recently extended for those entering the country by land or ferryboat.
    • Under a change that took effect on Sunday, June 12, air passengers no longer need to provide documentation of a negative test for COVID-19 or show recovery from a recent COVID-19 infection in order to board a flight to the U.S.
  • U.S. embassy and consulate delays. The pandemic continues to limit the number of visas the State Department can process and the services available at embassies and consulates abroad. Travelers should consult the appropriate embassy or consulate’s website for the most up-to-date information regarding appointment availability and requirements for expedited requests. Officials are taking steps to address the backlog, but delays should be expected throughout the summer.
  • Administrative processing. BAL has seen a recent uptick in visa applications flagged for additional administrative processing. There are a number of reasons this may happen, including if the government wants to conduct more thorough security vetting. Administrative processing often will further delay visa applications. Employers with employees who have an administrative processing case and have a particularly urgent need to be in the country should contact BAL.
  • Passport delays. U.S. passport services continue to be delayed. Routine passport services are taking eight to 11 weeks from the date on which an application is received; expedited services are taking five to seven weeks. Those in need of a passport should apply for one as soon as possible.
  • COVID-19 restrictions in other countries. Many foreign countries are still enforcing COVID-19 travel restrictions and health protocols, including pre-travel testing requirements, screening upon arrival and, in some cases, mandatory quarantines. Many countries have different policies for vaccinated and unvaccinated travelers. Employees should be aware of their destination country’s requirements and procedures and factor additional time into their travel plans.

BAL Analysis: While many countries are lifting COVID-19 travel restrictions, the U.S. continues to enforce a vaccine requirement for inbound nonimmigrant foreign nationals. Visa and passport services continue to be delayed. Employers and employees should continue to consult their BAL professional before planning any 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 State Department announced last week that it would expand its limited immigrant visa processing at the U.S. Embassy in Havana, Cuba.

Key Points:

  • Beginning in July 2022, the Embassy in Havana will begin scheduling interviews for all immediate relative immigrant visa applicants, including spouses and children under the age of 21 of U.S. citizens (IR/CR-1 and IR/CR-2).
  • IR/CR-1 and IR/CR-2 applicants who were notified on or after June 8, 2022, that their case is ready to be processed will have their interviews scheduled at the Embassy in Havana instead of the U.S. Embassy in Georgetown, Guyana.
  • The Embassy in Georgetown will remain the primary processing location for all other Cuban immigrant visa applications.
  • The Embassy in Havana will continue to provide essential American Citizens Services and limited emergency nonimmigrant visa processing.

Background: In March 2022, the State Department announced that it would resume limited immigrant visa processing at the Embassy in Cuba after it had reduced its staff and services because of the unexplained health incidents termed “Havana Syndrome.” In May, the Embassy in Havana began scheduling interviews for applicants in the IR-5 category (parents of U.S. citizens). The Embassy said last week that the expansion of limited services is “part of the broader expansion of the Embassy’s functions to facilitate diplomatic and civil society engagement and to expand the provision of consular services.” More information regarding the expansion of visa processing is available on the Embassy website.

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 Centers for Disease Control and Prevention (CDC) has lifted its COVID-19 testing requirement for inbound air travelers.

Key Points:

  • As of 12:01 a.m. ET on Sunday, June 12, air passengers are not required to test for COVID-19 or show recovery from a recent COVID-19 infection in order to board a flight to the U.S.
  • The CDC said it would continue to “evaluate the latest science and state of the pandemic and will reassess the need for a testing requirement if the situation changes.”
  • The CDC also recommends that individuals traveling to the U.S. by air test for COVID-19 as close to the time of departure as possible and not to travel if sick.
  • With limited exceptions, nonimmigrant foreign nationals are still required to be fully vaccinated against COVID-19 when traveling to the U.S. by air or crossing land borders.

Background: The White House confirmed reports early Friday that the testing requirement would be lifted. The CDC posted its official announcement later that day.

BAL Analysis: While the COVID-19 testing requirement will soon be terminated, the U.S. continues to enforce vaccine requirements for most nonimmigrant foreign nationals. Other countries continue to enforce COVID-19 entry restrictions of their own and visa services remain delayed at many U.S. consulates abroad. Employers and employees should continue to consult their BAL professional before planning any 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.

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

Final Action Dates: Key Movements

EB-1

  • All countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance one month to April 1, 2019.
  • India EB-2 will advance three months to Dec. 1, 2014.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will remain at March 22, 2018.
  • India EB-3 will remain at Jan. 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 March 22, 2018 Current Jan. 15, 2012 Current Current

Additional Information: U.S. Citizenship and Immigration Services (USCIS) confirmed Friday it would use the Final Action Dates chart to determine employment-based filing eligibility in July. 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.

Leading tech companies and immigration organizations are urging the Biden administration to take steps to protect the children of nonimmigrant visa holders who “age out” of their status while their parents wait for green cards to be processed.

In a letter to Homeland Security Secretary Alejandro Mayorkas, the group said said that current policies put more than 200,000 at risk of “falling through the cracks of the immigration system.”

“After spending years in the U.S., (children of nonimmigrant visa holders) risk losing the ability to stay in the U.S. once they turn 21,” the letter said. “This uncertainty harms families and prevents our companies from attracting and retaining critical talent in the U.S.”

The group said:

  • The administration should establish more robust “aging out” policies so that children of nonimmigrant visa holders can continue as beneficiaries of their parents’ pending green card applications after they turn 21.
  • Congress should pass bipartisan legislation that provides a long-term solution to the problem.

The Washington Post quoted a statement from a Department of Homeland Security (DHS) spokesperson saying Mayorkas “supports bipartisan legislation that offers a permanent pathway to citizenship for documented Dreamers” and that DHS is working to “maximize the number of employment-based green cards” issued this year.

BAL Analysis: The letter highlights a significant problem that limits immigration pathways for children of high-skilled immigrants and makes the recruitment and retention of high-skilled foreign nationals more difficult for employers. While proposals to offer protection to “documented Dreamers” have gained some bipartisan support, Congress has yet to take action on the issue. BAL will continue to follow the issue and will provide updates as developments occur.

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.