The U.S. Embassy in Havana has announced that it will fully resume immigrant visas services in Cuba beginning in early 2023.

Key Points:

  • The U.S. Embassy in Havana plans to resume full immigrant visa processing in early 2023 for the first time since 2017. No exact date has been announced.
  • Once full immigrant visa processing resumes, Cuban nationals will no longer need to travel outside of Cuba to Georgetown, Guyana, for their interviews.
  • During the transition to full immigrant visa processing at the U.S. Embassy in Havana, the National Visa Center (NVC) will continue to schedule family preference visa applicants for appointments at the U.S. Embassy in Georgetown.
  • The NVC will start scheduling all immediate relative and family preference immigrant visa applicants at the U.S. Embassy in Havana for appointments at the beginning of 2023. Visa applicants do not need to contact the embassies in Havana or in Georgetown or the National Visa Center (NVC); they will be notified directly with their appointment information.
  • The U.S. Embassy in Havana’s consular section will continue to provide essential American Citizens Services, immigrant visa services to those applying in the Immediate Relative categories 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 upcoming resumption of full immigrant visa services for Cuban nationals is welcome news as these services have been suspended since 2017 and the resumption will simplify visa procedures for some applicants. BAL will continue to monitor these developments 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 © 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 natural disasters such as the flooding in Pakistan and Hurricane Fiona in Puerto Rico.

On a case-by-case basis, individuals impacted by natural disasters 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.
  • Expedited adjudication of petitions or applications, including 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 flooding in Pakistan or Hurricane Fiona in Puerto rico 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 to support a request.

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. Citizenship and Immigration Services (USICS) will hold a national stakeholder engagement on the Deferred Action for Childhood Arrivals (DACA) final rule.

Key Points:

  • The engagement will be held Thursday, Sept. 22 from 3:30 to 4 p.m. EST.
  • USCIS officials will provide an overview of the DACA final rule and respond to stakeholder questions; USCIS reiterated it will not address questions related to specific cases, topics outside the scope of the engagement or issues under active litigation.
  • To register for the webinar, visit the USCIS public engagement page.

Additional Information: The Department of Homeland Security (DHS) published the final DACA regulation in the Federal Register in late August. The regulation was designed to “preserve and fortify” DACA, which 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. It is scheduled to take effect Oct. 31; however, litigation over DACA continues and immigration advocates have stressed that litigation could delay the regulation’s Oct. 31 effective date. Individuals in need of renewals should submit applications as early as they are eligible, given the uncertainty around the 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 has provided updated processing times for routine and expedited passport services.

Key Points:

  • The State Department is advising applicants to apply at least four to six months before planned travel.
  • As of Sept. 14, routine services can take seven to 10 weeks from the day an application is submitted to the day the new passport is received.
  • Expedited services can take four to six weeks from the day an application is submitted to the day the applicant receives the new passport.
  • Urgent travel appointments and in-person services at passport agencies or centers cannot be guaranteed. More information on specific passport centers’ services is available on the Passport Agency and Center page.

Additional Information: Processing times do not begin the day an application is mailed but when the State Department receives the application. It may take two to four weeks from the day the application is mailed for the status of the application to state “In Process.”

Some applications may be delayed because the State Department requests additional information. Applicants must respond to such requests in order for processing to resume. More information regarding requests for more information is available here.

BAL Analysis: U.S. citizens intending to travel abroad and in need of a new passport should renew their passport as soon as possible to avoid delays and complications. Employers and employees should continue to consult their BAL professional before planning international travel.

This alert has been provided by 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 estimates that roughly 200,000 employment-based immigrant visas (green cards) will be available in the upcoming fiscal year, officials said in a recently updated FAQ.

The 200,000 limit would be higher than in a typical pre-pandemic year but lower than in the previous two fiscal years. USCIS said the government remains committed “to using all the available employment-based visas in FY 2023.” The 2023 fiscal year begins Oct. 1.

The employment-based green card limit is calculated by adding the number of unused family-based green cards from the previous year to the annual baseline of 140,000 employment-based green cards. The limits have been high in the past two years because beginning in 2020, COVID-19 delays slowed down issuance of family-based green cards.

Fiscal Year Employment-based Green Card Limit
2018 140,292
2019 141,918
2020 156,253
2021 262,288
2022 281,507
2023 Roughly 200,000

BAL Analysis: While the State Department will make more green cards available than in a typical year, the limit will be lower than it has been in each of the past two fiscal years. Efforts by the State Department and USCIS to issue as many green cards as possible this year have garnered commendation; however, rapid forward movement in India EB-2 in the current fiscal year led to significant retrogression for October. The State Department said it would monitor the situation and make adjustments as necessary. 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.

U.S. Citizenship and Immigration Services (USCIS) announced today that it is starting the next phase of its premium processing expansion. As with the first and second phase, this phase will apply to certain previously filed Form I-140 petitions under the EB-1 and EB-2 classifications.

Petitioners who wish to request a premium processing upgrade must file Form I-907, Request for Premium Processing Service. Beginning today, USICS will accept Form I-907 requests for:

  • E13 multinational executive and manager petitions received on or before Jan. 1, 2022.
  • E21 NIW petitions received on or before Feb. 1, 2022.

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 will take up to 45 days to complete premium processing for the newly included Form I-140 classifications. 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 © 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 Aug. 31, the department was adjudicating applications filed in January and earlier, conducting audit reviews on applications filed in November and earlier, and reviewing appeals for reconsideration filed in April and earlier.

Average PERM processing times:

  • Adjudication – 234 days.
  • Audit review – 319 days.

PWD Processing: As of Aug. 31, the National Prevailing Wage Center was processing PWD requests filed in January and earlier for H-1B (OES and non-OES) and PERM (OES) cases and December and earlier for PERM (non-OES) cases, according to the Labor Department. Redeterminations were being considered on appeals filed April and earlier for H-1B cases and PERM cases. Center director reviews were being conducted for PERM cases filed in July and earlier.

BAL Analysis: BAL’s internal case tracking mostly consistent with the Labor Department’s published processing times. BAL is seeing slightly faster PWD issuance for in some PERM (OES) cases. BAL is seeing approvals for PERM applications filed in January and earlier and is starting to see PWDs for requests filed in January and earlier for H-1B (OES and non-OES), March and earlier for PERM (OES) cases and December and earlier for PERM (non-OES) 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.

U.S. Citizenship and Immigration Services (USCIS) has provided updated information on how Liberian residents covered by Deferred Enforced Departure (DED) can apply for employment authorization.

Key Points:

  • Liberian DED-related Employment Authorization Documents (EADs) have been automatically extended through June 30, 2024, for those with an A-11 Category Code whose card expiration date is March 30, 2020, Jan. 10, 2021, or June 30, 2022.
  • Eligible Liberian nationals covered by DED as of June 30, 2022, can remain in the U.S. through June 30, 2024.
  • Liberian nationals (or those without nationality who last resided in Liberia) who have been continuously physically present in the U.S. since May 20, 2017, and meet DED eligibility requirements are protected from removal from the U.S.
  • Liberian residents can apply for an Employment Authorization Document (EAD) by submitting a completed Form I-765, Application for Employment Authorization and can apply for travel authorization by submitting Form I-131, Application for Travel Document.

Additional information: Eligibility requirements for Liberian residents who are covered by DED are based on the terms described in a June 27 White House directive and any relevant requirements established by the Department of Homeland Security. A Federal Register notice published last week 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 State Department released the October Visa Bulletin, showing significant retrogression in India EB-2 and modest advancement in other key employment-based categories. U.S. Citizenship and Immigration Services (USCIS) announced it would use the Dates for Filing chart for employment-based filings.

Key Movements in Dates for Filing:

EB-1

  • All countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance more than two months to July 8, 2019.
  • India EB-2 will retrogress by more than 2½ years to May 1, 2012.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will advance almost two months to July 15, 2018.
  • India EB-3 will advance more than four months to July 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 Current Current Current Current Current
EB-2 Current July 8, 2019 Current May 1, 2012 Current Current
EB-3 Current July 15, 2018 Current July 1, 2012 Current Current


Additional Information: 
USCIS announced it would use the Dates for Filing chart for employment-based filings in October, the first month of the new fiscal year. While Dates for Filing are generally more progressive than Final Action Dates, the movement in India EB-2 is so dramatic that the priority-date cutoff in this category will retrogress beyond September’s Final Action Date of Dec. 1, 2014. BAL will continue following the Visa Bulletin 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.

The Department of Homeland Security (DHS) is poised to publish a final rule to codify pre-Trump guidance related to the “public charge” ground of inadmissibility.

Key Points:

  • The rule will formalize long-standing guidance that is applied today. This guidance was in place from 1999 until the Trump administration published a regulation in 2019 that sought to expand “public charge” to include certain non-cash benefits. DHS said the rule “restores the historical understanding of a ‘public charge.’”
  • When making a public charge determination, DHS will not consider receipt of food and nutrition assistance (SNAP); the Children’s Health Insurance Program (CHIP); most Medicaid benefits; housing benefits and transportation vouchers; COVID-19 assistance; or tax credits, deductions and other earned benefits. DHS will also not consider benefits received by an applicant’s family members.
  • DHS will not apply the public charge determination to applications to change or extend nonimmigrant status.
  • DHS is scheduled to publish the regulation in the Federal Register tomorrow, Sept. 9. A prepublication version is available here.
  • The rule is scheduled to take effect 105 days from the date of publication. DHS said that between now and then, it will “conduct necessary public outreach to minimize the risk of confusion or chilling effects among both noncitizens and U.S. citizens.” The agency may also provide additional guidance to inform how immigration officers should consider the “totality of the circumstances” when making public charge determinations.

Additional Information: In publishing the 2019 regulation, the Trump administration sought to significantly expand the grounds by which applicants could be denied lawful permanent residence (green cards) under the Immigration and Nationality Act’s public charge ground of inadmissibility. The 2019 regulation faced multiple lawsuits and was ultimately vacated in court. The Biden administration declined to enforce the regulation and withdrew appeals that were pending in the U.S. Supreme Court and other appellate courts. In February, DHS published a proposed rule to restore the previous public charge guidance. The agency accepted comments from the public on the proposal and has now finalized the rule.

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.