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.

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.