The Department of Homeland Security (DHS) has sent a proposed rule to update Form I-9 employment eligibility procedures to the White House Office of Management and Budget.

Key Points:

  • The text of the proposal is not yet available, but DHS said it would “propose to revise employment eligibility verification regulations to 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 text for public inspection at least a day before officially publishing it in the Federal Register.
  • The proposal is classified as a “proposed rule,” meaning it would go through a notice-and-comment period 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 certain employers who are operating remotely because of COVID-19. The temporary flexibilities will remain in place through at least Oct. 31.

Additional Information: U.S. Citizenship and Immigration Services (USCIS) is working on a separate rule to provide a new version of the Form I-9. The agency proposed a revised form in March and accepted comments on it through May 31. Officials must review the comments before finalizing revisions. The agency may make additional changes in response to comments, and will announce when a new form version will become mandatory.

BAL Analysis: DHS said that the proposal it sent to OMB may “reduce burdens on employers and employees while maintaining the integrity of the employment verification process.” BAL has welcomed the temporary flexibilities and has 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.

The Department of Homeland Security (DHS) announced that it would open registration for Temporary Protected Status (TPS) for Cameroon on June 7. It will remain open through Dec. 7, 2023.

Key Points:

  • To be eligible for TPS, nationals of Cameroon (or those without a nationality who last resided in Cameroon) must demonstrate they have resided in the U.S. continuously since April 14, 2022, and continuously physically present since June 7.
  • Applicants have 18 months, from June 7, 2022, through Dec. 7, 2023, to register and complete Form I-821, Application for Temporary Protected Status. They may also request an Employment Authorization Document by submitting Form I-765.
  • Those who traveled to the U.S. after April 14 will not be eligible for TPS.
  • The full Federal Register notice is available here.

Additional Information: DHS made the decision to add Cameroon under TPS due to the extreme violence between government forces and armed separatist and the widespread destruction of civilian infrastructure resulting in economic instability, food insecurity and several hundred thousand displaced Cameroonians.

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 Labor Department has posted updated processing times for permanent labor certification (PERM) applications and prevailing wage determination (PWD) requests.

PERM Processing: As of May 31, the department was adjudicating applications filed in November and earlier, conducting audit reviews on applications filed in September and earlier, and reviewing appeals for reconsideration filed in January and earlier.

Average PERM processing times:

  • Adjudication – 191 days.
  • Audit review – 278 days.

PWD Processing: As of May 31, the National Prevailing Wage Center was processing PWD requests filed in November and earlier for H-1B (OES and non-OES) and PERM (OES and non-OES) cases. Redeterminations were being considered on appeals filed March and earlier for H-1B cases and PERM cases. Center director reviews were being conducted for PERM cases filed in April and earlier.

BAL Analysis: BAL’s internal case tracking is consistent with the Labor Department’s published processing times. BAL is seeing approvals for PERM applications filed in November and earlier and is starting to see PWDs for requests filed in November and earlier for H-1B and PERM cases.

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.

BAL has submitted a public comment in support of U.S. Citizenship and Immigration Services (USCIS) efforts to streamline the Form I-9 and reduce burdens on employers and employees. The comment came in response to an agency proposal to revise the Form I-9 in an effort to simplify the verification of employment eligibility.

BAL urged USCIS to:

  • Implement its proposal to simplify the Form I-9 and provide more clarity to employers and employees.
  • Update its Lists of Acceptable Documents to include electronic documents.
  • Modernize the Form I-9 process by transitioning to an electronic environment.

The full comment is available here.

Background: USCIS published its proposal for the revised Form I-9 on March 29, opening a public comment period that closed May 31. The proposed changes to the form include:

  • Condensing Sections 1 and 2 on a one-page “Main Form.”
  • Designating Section 3 the “Reverification and Rehire Supplement to the Form I-9.”
  • Adding information about the M-274 handbook and acceptable receipts to the “Lists of Acceptable Documents.”
  • Shortening the form instructions from 15 pages to seven.

USCIS received more than 180 comments on the proposal. The agency will now review the comments before finalizing the revised form and may make further changes in response to comments. The current Form I-9 is scheduled to expire on Oct. 31, and USCIS will announce the date on which employers will be required to begin using the new form.

In its comment, BAL also expressed support for guidance that temporarily allows certain employers operating remotely due to COVID-19 to conduct verification of employee documents virtually, e.g., by using fax, email or video link. The measures are currently in place through Oct. 31. BAL has urged USCIS to make remote verification available permanently.

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 (USCIS) has expanded premium processing to certain previously filed Form I-140 petitions for executives and managers.

Key Points:

  • Under a change that took effect June 1, USCIS is now accepting Form I-907 premium processing requests for E13 multinational executive and manager petitions received on or before Jan. 1, 2021.
  • Beginning July 1, USCIS will accept Form I-907 premium processing requests for E21 national interest waiver (NIW) petitions received on or before June 1, 2021, and E13 multinational executive and manager petitions received on or before March 1, 2021.
  • USCIS will take up to 45 days to complete premium processing for these newly included Form I-140 classifications, the agency said last week.

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 published a new version of the Form I-907 last month. The new form is dated May 31, 2022, but the agency will accept both the old and new versions in the month of June. Beginning July 1, it will only accept the new version. BAL will continue to follow the expansion of premium processing 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.

U.S. Citizenship and Immigration Services (USCIS) has reminded the public of special services made available to those affected by extreme situations such as the shooting in Uvalde, Texas.

On a case-by-case basis, individuals impacted by extreme situations and certain other unforeseen circumstances may request:

  • To change nonimmigrant status or extend nonimmigrant stay for an individual currently in the U.S.
  • Re-parole for those who have previously received parole by USCIS.
  • Expedited processing of advanced parole requests.
  • Expedited adjudication of off-campus employment authorization for F-1 students experiencing economic hardship and employment authorization applications.
  • Expedited replacement of lost or damaged immigration or travel documents issued by USCIS.
  • Consideration of fee waiver requests because the individual cannot pay.
  • Flexibility for those unable to submit evidence or respond in a timely manner to a Request for Evidence or Notice of Intent to Deny and for those unable to attend a scheduled interview with USCIS.
  • To reschedule a biometrics appointment.

Additional Information: Individuals who are making a request listed above should explain how the shooting in Uvalde, Texas, created the need for such a request. Those who lost evidence should include an explanation and a copy of a police report, insurance claim or other report as supporting information.

Employers and individuals are reminded that all Form I-9 requirements remain in place and should review instructions on how to verify employment eligibility of employees whose documents are lost or damaged. Individuals are reminded to update their addresses with USCIS to avoid possible delays in processing. More information regarding the special measures is available 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.

U.S. Customs and Border Protection (CBP) announced yesterday that it will increase the fees for travelers with an approved Electronic System for Travel Authorization (ESTA) to enter the U.S.

Key Points:

  • Beginning May 26, foreign nationals must pay $21 instead of $14 to travel to the U.S. with an approved ESTA.
  • The $21 fee consists of a $17 ESTA travel promotion fee and a $4 operational fee.
  • Those who have an approved ESTA do not need to reapply due to the fee increase; ESTAs are valid for up to two years.
  • The full Federal Register notice is available here.

Additional Information: ESTA is the online system through which nonimmigrant visitors intending to enter the U.S. under the Visa Waiver Program (VWP) at air or sea ports of entry must obtain an electronic travel authorization before traveling to the U.S. A list of countries eligible for the VWP is available 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.

U.S. Citizenship and Immigration Services (USCIS) announced Tuesday that it would make premium processing available to certain petitioners with pending Form I-140 applications under the EB-1 and EB-2 classifications.

The expansion will apply to certain previously filed Form I-140 petitions under (1) an E13 multinational executive and manager classification or (2) an E21 classification as a member of professions with advanced degrees or exceptional ability seeking a national interest waiver (NIW).

Key Points:

  • Beginning June 1, 2022, USCIS will accept Form I-907 premium processing requests for E13 multinational executive and manager petitions received on or before Jan. 1, 2021.
  • Beginning July 1, 2022, USCIS will accept Form I-907 premium processing requests for E21 NIW petitions received on or before June 1, 2021, and E13 multinational executive and manager petitions received on or before March 1, 2021.

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. At this time, USCIS will not accept initial Forms I-140 with a premium processing request for the classifications listed above. It will also reject premium processing requests that are filed before the applicable start date.

USCIS published a new version of the Form I-907 this week. The new form is dated May 31, 2022, but the agency will accept both the current and new versions in the month of June. Beginning July 1, it will only accept the new version.

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 National Visa Center (NVC) has indefinitely suspended its public inquiry telephone number to address critical backlogs.

Key Points:

  • The State Department said the suspension of the public inquiry will not affect the NVC’s essential functions.
  • IV applicants can use the Public Inquiry Form if they cannot find an answer to a question on https://nvc.state.gov or https://ceac.state.gov/ceac/.
  • The Department said individuals should not submit repeat inquiries on a single topic; doing so will delay the NVC’s response time.
  • The NVC’s processing timeframes for inquiries and cases are available on this website. People should not submit follow-up inquiries while a case is within the time frame listed on that website.

Additional Information: Individuals can find information regarding common inquiries for Immigrant Visas here and Nonimmigrant Visas (NIV) here. More information regarding the NVC’s suspension of its public inquiry telephone number is available 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 Department of Homeland Security (DHS) has announced that it will open registration for Temporary Protected Status (TPS) for Afghanistan on Friday, May 20. Registration will remain open through Nov. 20, 2023. DHS also temporarily suspended employment authorization requirements for certain F-1 students from Afghanistan.

Key Points:

  • To be eligible for TPS, Afghan nationals (or those without a nationality who last resided in Afghanistan) must demonstrate they have resided in the U.S. continuously since March 15, 2022, and have been continuously physically present since May 20.
  • Applicants have 18 months, from May 20, 2022, through Nov. 20, 2023, to register and complete Form I-821, Application for Temporary Protected Status. They may also request an Employment Authorization Document by submitting Form I-765.
  • Those who traveled to the U.S. after March 15 will not be eligible for TPS.
  • Afghan nationals (or those without a nationality who last resided in Afghanistan) who are nonimmigrant F-1 students and are “experiencing severe economic hardship as a direct result of the current situation in Afghanistan” can now:
    • Request employment authorization from May 20, 2022, through Nov. 20, 2023.
    • Work an increased number of hours while school is in session.
    • Reduce their course load while continuing to maintain their F-1 nonimmigrant status.
  • DHS will consider F-1 nonimmigrant students who gain employment authorization engaged in a “full course of study” for the duration of their employment authorization if the nonimmigrant student satisfies the minimum course load requirement described here.

Additional Information: The decision to designate Afghanistan for TPS was made due to the ongoing armed conflict and threat posed on civilians lives. DHS cited the same reasons in its decision to provide relief for nonimmigrant F-1 students. More information can be found 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.