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

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

Average PERM processing times:

  • Adjudication – 182 days.
  • Audit review – 283 days.

PWD Processing: As of March 31, the National Prevailing Wage Center was processing PWD requests filed in October and earlier for H-1B (OES) cases, September and earlier for H-1B (non-OES) cases, October and earlier for PERM (OES) cases and August and earlier for PERM (non-OES) cases, according to the Labor Department. Redeterminations were being considered on appeals filed February and earlier for H-1B cases and PERM cases. Center director reviews were being conducted for PERM cases filed in February 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 September and earlier and is starting to see PWDs for requests filed in October and earlier for H-1B (OES) cases, September and earlier for H-1B (non-OES) cases, October and earlier for PERM (OES) cases and August 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.

April 1 marked the beginning of the 90-day filing period for petitioners whose registrations were selected in this year’s H-1B lottery.

High demand and strict numerical quotas, however, mean that tens of thousands of qualified registrants were not invited to file H-1B petitions. Depending on an employee’s particular circumstances, alternative visa routes may be available. Employers are encouraged to consider alternatives for those who were not selected in the lottery. These alternatives may include:

  • F-1 Optional Practical Training. Newly graduated foreign students may extend their F-1 student status through Optional Practical Training (OPT) if they seek to perform work directly related to their area of study. A 2016 regulation allows F-1 student visa holders who have degrees in science, technology, engineering or mathematics (STEM) fields to apply for a 24-month extension of their one-year OPT period.
  • J-1 exchange visas. Companies may bring foreign students and graduates of foreign universities to the U.S. as trainees for up to 18 months or as interns for up to 12 months. One of the limitations to this visa category is that employers may not hire a J-1 visitor for a position that is filled or would be filled by a full- or part-time employee. Exchange visitors also must prove their intent to return to their home country and in some cases must return to their home country for two years at the end of their J-1 status.
  • H-3 Trainee visas. Trainee visas are available for individuals engaged in job-related training that is not available in their home country. These visas are not intended for U.S. employment and are intended to train the individual for a job they will perform outside the U.S.; therefore, H-3 trainees are restricted in the type of employment and cannot perform work in the normal operation of the business in which U.S. workers are regularly employed.
  • L-1 intracompany transfer visas. The L-1 category allows companies with international offices to transfer employees in managerial or specialized knowledge positions from a foreign branch, affiliate, parent or subsidiary office to their U.S. offices. Only employees with at least one year of experience in the company’s foreign operations in the last three years are eligible. Some companies may consider longer-term strategies of employing select candidates in their overseas office for a year and applying for L-1 status thereafter. L-1B visas for individuals with “specialized knowledge” are valid for up to five years, while L-1A visas for managerial workers are valid for seven years.
  • O-1 “extraordinary ability” visas. Individuals demonstrating extraordinary ability in business, science, education, art or athletics may qualify for an O-1 visa. This category requires evidence of distinguished achievements such as published articles, peer-reviewed activities, major awards, high salaries or employment in a critical capacity for a well-known organization.
  • E-2 Treaty Investor visas. Employees who are nationals of a country holding a treaty with the U.S. may qualify for E-2 visas. Although this route has traditionally been used by individual investors and smaller employers, in recent years, large established companies have started to leverage E-2 visas to hire and retain executives, managers and other essential employees in the U.S. The list of treaty countries is available here.
  • Country-specific nonimmigrant visas. Under bilateral agreements, certain nationalities are eligible for temporary nonimmigrant visas. These visas include H-1B1 specialty occupation visas for citizens of Chile and Singapore, E-3 specialty occupation status for Australian citizens, and TN classification for citizens of Canada and Mexico in designated professional categories. The TN classification was created by the North America Free Trade Agreement (NAFTA) and continued in the United States-Canada-Mexico Agreement (USMCA).

BAL Analysis: Employers are encouraged to work with their BAL attorney to explore H-1B alternatives for their current job candidates as well as to map out long-term options for their workforce.

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. will begin accepting applications for gender-neutral passports beginning April 11, the State Department announced.

Key Points: 

  • Beginning April 11, U.S. citizens will be able to select an X as their gender marker on their U.S. passport application if they are applying for a U.S. passport book and selecting routine service.
  • Beginning in late 2023, applicants will be able to select X when applying for a passport card or selecting expedited service.
  • The State Department also anticipates that by late 2023 applicants will be able to select X when applying for:
    • Emergency passports printed at U.S. embassies and consulates.
    • Expedited and emergency passports issued at passport agencies or centers.
    • Consular Reports of Birth Abroad (CRBAs).

Additional Information: Information on how to apply can be found here. General information about passports and processing times 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.

Immigrant and nonimmigrant visa issuance remained well below pre-pandemic levels in the 2021 fiscal year, according to U.S. State Department data.

The recently released “Report of the Visa Office 2021” showed that immigrant visa issuance ticked up slightly in FY 2021 after dropping by nearly 50 percent in FY 2020. Nonimmigrant visa issuance continued to decline after falling by more than 50 percent in FY 2020.

Fiscal Year Immigrant Visas Issued Globally
2017 575,902
2018 550,930
2019 462,422
2020 240,526
2021 285,069

 

Fiscal Year Nonimmigrant Visas Issued Globally
2017 9,681,913
2018 9,028,026
2019 8,742,068
2020 4,013,210
2021 2,792,083

A full breakdown of immigrant visa issuance globally in FY 2021 is available here. Information about nonimmigrant visa issuance is available here.

State Department data also shows that immigrant visa issuance has remained relatively even in recent months, while nonimmigrant visa issuance has started to pick up.

Month Immigrant Visas Issued Globally
October 2021 36,245
November 2021 35,647
December 2021 38,397
January 2022 33,039
February 2022 35,942

 

Month Nonimmigrant Visas Issued Globally
October 2021 296,442
November 2021 391,022
December 2021 435,665
January 2022 414,383
February 2022 484,571

More information on monthly visa issuance globally is available here.

BAL Analysis: The COVID-19 pandemic and related staffing and funding issues have slowed visa issuance globally, and many embassies and consulates continue to operate at a reduced capacity. The State Department has made reducing backlogs a priority, and the increase in nonimmigrant visa issuance in recent months is a positive sign. Applicants should continue to expect delays in the months ahead. 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) has extended an exemption that allows certain nonimmigrants traveling from Ukraine to enter the U.S. without showing proof of a COVID-19 vaccination.

Key Points:

  • Nonimmigrants can enter the U.S. without showing proof that they are fully vaccinated against COVID-19 through April 30, 2022, if they:
    • Are traveling with a U.S. citizen or lawful permanent resident.
    • Were physically present in Ukraine as of Feb. 10.
    • Have valid travel documents allowing them to travel to the U.S.
  • Individuals who meet these requirements must agree to:
    • Take a COVID-19 test within three to five days after entering the U.S.
    • Quarantine for seven days and self-isolate if they receive a positive COVID-19 test or develop COVID-19 symptoms.
    • Become fully vaccinated against COVID-19 within 60 days after entering the U.S. if they are staying in the country for longer than 60 days.

Additional Information: The Centers for Disease Control and Prevention (CDC) extended its waiver on the pre-departure COVID-19 testing requirement through May 1 for some individuals physically present in Ukraine as of Feb. 10, including U.S. citizens, lawful permanent residents and nonimmigrant foreign nationals traveling with a U.S. citizen or lawful permanent resident. 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.

U.S. Citizenship and Immigration Services (USCIS) has proposed a new version of the Form I-9, aiming to streamline the verification of employment eligibility.

Key Points:

  • USCIS published its proposal for an updated version of the Form I-9 in the Federal Register today. The agency will accept comments on the proposal until May 31 and will review the comments before finalizing a new form.
  • The current form is scheduled to expire on Oct. 31. USCIS will announce the date employers are required to begin using the new version of the form.
  • USCIS estimates that the proposed changes will reduce the time required to complete the form from 35 to 34 minutes if completing on paper, and 26 to 25 minutes if completing electronically. These estimates include the time required to review instructions and complete and retain the form.
  • 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.
  • The proposed form, instructions and tables explaining the changes are available here. Officials also posted updated information on the e-Verify website here.

Additional Information: BAL will follow developments related to the proposed new Form I-9. Besides the changes described above, DHS has indicated it plans to publish a notice of proposed rulemaking to provide an optional alternative to physical examination for certain employers. Temporary measures that allow for remote document verification in some cases remain in effect through April 30. BAL has urged USCIS to modernize the I-9 process. This week, BAL attorneys discussed upcoming I-9 changes at the SHRM Employment Law & Compliance Conference in a panel called “Form I-9 & E-Verify Compliance: What’s in Store for Employers in 2022.” 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.

U.S. Citizenship and Immigration Services (USCIS) announced today that it has conducted the H-1B lottery after having received enough registrations for its H-1B quotas during the electronic pre-registration period.

Key Points:

  • Registrants’ online accounts will now show one of the following statuses for each registration.
    • Selected. The registration was selected to file an H-1B cap petition.
    • Submitted. The registration was not selected in the initial lottery but remains eligible for possible later selection.
    • Denied. Multiple registrations were submitted by or on behalf of the same registrant for the same beneficiary and the registration is invalid for this fiscal year.
  • Petitioners may begin to file H-1B cap-subject petitions for selected candidates April 1. The filing period is expected to last 90 days.
  • In each of the last two years, USCIS conducted more than one lottery, but there is no guarantee this will happen again this year. Several factors will determine whether there are subsequent lotteries, including the number of H-1B petitions filed from the selected registrations.
  • USCIS has not yet said how many registrations it received, only that it received enough to reach the H-1B cap, including the advanced degree exemption (master’s cap).

BAL Analysis: Employers should begin preparing to file full petitions for selected candidates. While the filing period will remain open for 90 days, employers should prioritize time-sensitive candidates such as F-1 students on cap-gap and others whose status may expire soon. BAL will continue to follow developments related to the H-1B cap season 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) posted its new premium processing regulation for public inspection today, unveiling a plan to make additional benefit categories eligible for the service in the coming months and years.

Key Points:

  • Benefit Categories. The following benefit categories will be eligible for premium processing under the new rule.
    • Form I-140 for EB-1 multinational executive or manager and EB-2 advanced degree or exceptional ability seeking national interest waiver (NIW). The premium processing fee for this category will be $2,500; the processing time frame will be 45 days.
    • Form I-539 change of status to F-1, F-2, J-1, J-2, M-1, or M-2 NIV status, or change of status to or extension of stay in E-1, E-2, E-3, H-4, L-2, O-3, P-4, R-2 NIV status. The fee for this category will be $1,750; the processing time frame will be 30 days.
    • Form I-765 Employment Authorization Document (EAD) application. The fee will be $1,500; the processing time frame will be 30 days.
  • Implementation. The regulation is expected to take effect on May 31, but USCIS will gradually phase in the service for the new request types. USCIS plans to expand premium processing to the two I-140 classifications and certain Form I-539 and I-765 categories this fiscal year. The agency estimates it will not be able to expand to the additional Form I-539 and I-765 categories until FY 2025. USCIS will post announcements on its website about the availability of premium processing as it becomes available for newly designated immigration benefit requests.
  • Publication. The rule is scheduled to be published in the Federal Register tomorrow, March 30. A pre-publication version is available here.

Additional Information: USCIS announced the premium processing rule as part of a broader package of initiatives to reduce backlogs and provide relief to foreign nationals affected by processing delays. USCIS recently sent a final rule for White House review that would temporarily increase the automatic extension period for certain EAD renewal applicants. The text of this rule is not yet available. USCIS is also working on hiring more officers and improving case processing technology, with the goal of shorter adjudication time frames. The COVID-19 pandemic and funding and staffing issues have exacerbated backlogs across visa categories, and USCIS officials have said reducing wait times is one of the agency’s top priorities.

BAL Analysis: The extension of premium processing to additional benefit categories will shorten processing times for eligible applicants who pay the applicable fee. USCIS will begin extending premium processing this year; however, some benefit categories will not have premium processing until FY 2025. This is because under law, USCIS must ensure that its implementation or expansion of premium processing does not result in an increase in processing times for other immigration benefit requests. BAL will continue monitoring the implementation of the premium processing regulation and other initiatives to ease immigration processing and will update clients 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 U.S. State Department has extended a temporary policy that allows some U.S. citizens to return to the U.S. on an expired passport. The policy was set to expire on March 31, 2022, and will be extended until June 30, 2022.

Key Points:

  • Under the policy, U.S. citizens currently abroad whose passports expired on or after Jan. 1, 2020, may be able to return to the U.S. using their expired passport.
  • Certain criteria apply, and travelers are encouraged to confirm their eligibility on this website before finalizing travel plans.
  • Travelers cannot use expired passports to travel from the U.S. to a foreign country or from one foreign country to another for any length of stay longer than an airport connection in route to the U.S. or a U.S. territory.

Additional Information: U.S. citizens are reminded that all air travelers, regardless of their vaccination status, must have proof of a negative COVID-19 test taken within one day of their flight’s departure to the U.S. Individuals wishing to renew their expired passport can find processing times and instructions here.

BAL Analysis: While the extension will ease travel procedures for some U.S. citizens returning to the U.S., it only applies to a limited number of travelers. BAL continues to urge individuals to consult their BAL professional before planning international travel, as policies may change with little notice and could affect travelers’ ability to re-enter or return to the U.S.

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) recently announced that it would end a temporary policy allowing employers to accept expired List B identity documents when completing Form I-9 Employment Eligibility Verification.

Key Points:

  • Beginning May 1, 2022, employers will only be permitted to accept List B documents that are not expired.
  • Employers can continue to accept expired List B documents from now through April 30, 2022.
  • Employers are required to update their I-9 forms by July 31, 2022, for any employees who presented an expired List B document between May 1, 2020, and April 30, 2022.
  • To comply with Form I-9 requirements, employees must present a List B identity document along with an acceptable List C document evidencing employment authorization or a List A document that demonstrates both identity and work authorization. Information about acceptable documents can be found on the U.S. Citizenship and Immigration Services (USCIS) website.

Additional Information: DHS adopted the temporary policy in May 2020 in response to the challenges people were facing getting List B documents renewed during the COVID-19 pandemic. DHS said that it was ending the temporary policy now that “document‑issuing authorities have reopened and/or provided alternatives to in‑person renewals.” For more information on the updated requirements, please see the table in the DHS announcement, available here.

BAL will be presenting with a USCIS representative about “Form I-9 & E-Verify Compliance: What’s in Store for Employers in 2022” at the SHRM Employment Law & Compliance Conference. For details and to register for the conference, click 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.