BAL joined a group of more than 40 companies this week in urging a federal appeals court to preserve Deferred Action for Childhood Arrivals (DACA).

Texas and a group of other states are challenging DACA’s legality in a case now before the Fifth Circuit Court of Appeals. In a friend-of-the-court brief, the companies said that DACA is lawful and that invalidating it would harm U.S. businesses and the economy.

“DACA recipients have helped to drive and sustain the American economy by filling crucial labor shortages, creating new businesses, spending their incomes on American products and services, and paying taxes,” the brief said.

The case is before the Fifth Circuit after a district judge ruled in July that the Department of Homeland Security (DHS) did not follow proper procedures when it created DACA in 2012. The Justice Department appealed the ruling in September.

On a separate track, the Biden administration has taken steps to “preserve and fortify” DACA through the regulatory process. A proposed regulation drew more than 16,000 public comments, including strong support from the business community. DHS will now review the comments before publishing a final regulation.

BAL Analysis: BAL will continue to follow the DACA litigation as it moves through the appeals process. Under the July ruling, DHS cannot approve any first-time DACA grants, but DACA recipients are able to file renewal requests and for employment authorization. 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 © 2021 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. Immigration and Customs Enforcement (ICE) announced today that it would extend Form I-9 flexible procedures for employers.

Key Points:

  • ICE extended the temporary measures until April 30, 2022. The guidance had been scheduled to expire Dec. 31.
  • Since March 2020, the guidance has allowed employers that are operating remotely due to COVID-19 to conduct verification of employee documents virtually, e.g., by using fax, email or video link, for the purpose of Form I-9 employment eligibility verification procedures. Employers that follow the virtual procedures must comply with certain guidelines when “normal operations” resume, including conducting physical inspection of documents that were viewed remotely within three business days.
  • The agency will continue to apply the guidance previously issued for employees hired on or after April 1, 2021, who work exclusively in a remote setting due to COVID-19-related precautions. The guidance exempts these employees from physical inspection requirements until they undertake non-remote employment on a “regular, consistent, or predictable basis” or until the extension of I-9 flexibilities ends, whichever is earlier.
  • Employers should consult the original March 2020 ICE guidance for eligibility requirements and information on how to obtain, remotely inspect and retain copies of identity and employment eligibility documents. U.S. Citizenship and Immigration Services (USCIS) has also provided guidance on how to properly complete and annotate the Form I-9.
  • Employers should monitor the Department of Homeland Security (DHS) and ICE websites for additional updates regarding when the extensions will be terminated and normal operations will resume.

Additional Information: ICE introduced the temporary measures in March 2020 and has extended them numerous times since, most recently in August.

USCIS is currently collecting input from the public on possible “alternative options to physical document examination” in the I-9 process. In the recently published regulatory agenda, DHS indicated that it plans to publish a notice of proposed rulemaking next year on “alternative document examination procedures under certain circumstances or with respect to certain employers.” BAL will provide updates as information becomes available.

This alert has been provided by the BAL Global Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 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 recent tornadoes in Kentucky and nearby states.

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

  • A 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 server weather in Kentucky and surrounding states 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 © 2021 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 FY 2023 H-1B cap season is getting underway amid economic conditions that could increase demand for high-skilled foreign workers.

Employers are encouraged to begin H-1B planning now and should expect heavy competition for workers who may have multiple employment offers. The number of registrations regularly eclipses the number of cap-subject H-1B visas available, both for bachelor’s and advanced degree holders. Next year will almost surely be no exception.

Here is some of the key information for those new to the process or in need of a refresher:

  • Petitioners for cap-subject H-1B visas must submit an electronic registration in the weeks before April 1 for each prospective H-1B candidate.
  • USCIS has yet to announce the dates on which registrations will be accepted. In each of the last two years, the registration period has been in March.
  • No priority is given to early submissions (i.e., those submitted at the beginning of the registration period).
  • Following the registration period, USCIS will conduct a random lottery if there are more registrations than visas available. Caps are set at 65,000 visas plus an additional 20,000 exclusively for advanced degree holders.
  • Petitioners whose registrations are selected in the lottery will be invited to file full H-1B petitions in the 90-day period beginning April 1.

Background: This will be the third cap season in which USCIS will use the H-1B electronic registration process. USCIS received 308,613 registrations last year and 274,237 the year before. In each of the last two years, USCIS has conducted more than one lottery. Whether this happens again will depend on several factors, including how many petitions are submitted for the registrations that are selected in the initial lottery.

BAL Analysis: Demand for H-1B visas will likely be high again this cap season, and employers should expect candidates to have multiple job offers. Employers are encouraged to work closely with BAL regarding the immigration benefits employers can offer (e.g., immediate green card sponsorship), which petitions should be fully prepped before the registration lottery, and possible H-1B alternatives for registrations that are not selected.

BAL attorneys will be hosting a webinar on Tuesday, Dec. 14 entitled, “Developments Affecting H-1B Cap Season: Planning & Strategies for Your H-1B Program.”  To attend, register here.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 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. government has published its semi-annual regulatory agenda, offering an indication of the Biden administration’s top immigration priorities in the coming months.

  • H-1B program. The U.S. Department of Homeland Security (DHS) plans to publish a notice of proposed rulemaking to “modernize” H-1B requirements and oversight and provide additional flexibility in the F-1 program. The regulatory agenda indicates the agency is targeting May 2022 to publish the proposal. The previous DHS agenda had targeted December 2021 for publication. According to DHS, the rule will:
    • Revise regulations related to the employer-employee relationship.
    • Implement new guidelines for site visits.
    • Provide flexibility on start dates in limited circumstances.
    • Address “cap-gap” issues.
    • Strengthen the registration process to reduce the possibility of misuse and fraud.
    • Clarify the requirement that an amended or new petition be filed if there are material changes.
  • Prevailing Wage Requirements. The U.S. Department of Labor (DOL) is planning to publish a notice of proposed rulemaking to strengthen wage protections for the temporary and permanent employment of certain foreign nationals. According to the DOL, the rule will establish a new wage methodology for setting prevailing wage levels for the H-1B/H-1B1/E-3 and PERM programs. The agency is restarting the process to amend wage obligations after a federal court vacated the rule that was scheduled to take effect in November. The agenda indicates the DOL is targeting March 2022 to publish the proposal.
  • Entry-Exit Fees. DHS intends to publish a notice of proposed rulemaking to provide that 9-11 Response Fees will apply to all H-1B and L-1 extension petitions filed by certain employers, in addition to all previously covered H-1B and L-1 petitions. The agency is aiming to publish the proposal in May 2022.
  • USCIS fees. DHS plans to adjust fees that U.S. Citizenship and Immigration Services (USCIS) charges for immigration services. The agency published a regulation to increase filing fees on Aug. 3, 2020, but a court blocked the fees from taking effect. DHS is aiming to publish a notice of proposed rulemaking in March 2022 to rescind and replace the Aug. 3 rule and “establish new USCIS fees to recover USCIS operating costs.”
  • Form I-9 Physical Examination. DHS plans to publish a notice of proposed rulemaking to provide an optional alternative to physical examination in the Form I-9 employment eligibility verification process. According to DHS, the rule will allow the authorization of “alternative document examination procedures under certain circumstances or with respect to certain employers” in hopes of reducing burdens on employers and employees while preserving the integrity of the employment verification process. The agenda indicates DHS is targeting June 2022 to publish the proposal.
  • B-1/B-2 visas. The State Department plans to publish a final rule that will eliminate language from the regulations that allow consular officers to issue a B-1, business visitor visa to certain applicants who are classifiable as H-1B or H-3 nonimmigrants. In its proposed rule, the State Department confirmed that B-1 visas will continue to be issued to foreign nationals seeking to engage in permissible business activities, irrespective of whether the applicant might qualify for an H visa. The publication of the rule is currently slated for January 2022.

Additional Information: The full regulatory agenda is available here.

BAL Analysis: While the regulations would have significant impact on immigration programs, they are at different stages in the rulemaking process, and policies are still being formulated. Proposed regulations are subject to a public notice-and-comment period during which members of the public may submit feedback. BAL continues to monitor the regulatory agenda and will provide clients with updates on individual regulations as they move through the rulemaking process.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 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 published a temporary rule Monday that will allow consular officers to waive the personal appearance and interview requirements for certain replacement immigrant visa applicants.

Under the rule, immigrant visa applicants will not need to make an in-person appearance for an interview, execution of their applications and oath, if:

  • Their visa was issued on or after Aug. 4, 2019;
  • They did not travel to the U.S. on the immigrant visa; and
  • They are seeking and remain qualified for an immigrant visa in the same classification as the expired immigrant visa or in certain automatic category conversions, pursuant to the same approved petition.

The rule will take effect immediately and will expire in two years, on Dec. 13, 2023.

Applicants who meet the criteria listed above may wish to contact the embassy or consulate that issued their prior visa to ask about their eligibility. Even for applicants who meet all the criteria, waivers will be granted at the discretion of consular officials. Applicants may be required to submit new DS-260 applications, provide any required updated documents, submit medical exams, and pay the application processing fees.

More information on the personal appearance waiver is available here.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 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 is no longer requiring 2022 diversity visa (DV) selectees to submit their supporting documents to the Kentucky Consular Center (KCC).

Key Points:

  • Foreign nationals who were selected to participate in the DV-2022 program only need to submit the DS-260 immigrant visa application form for themselves and accompanying family members to the KCC.
  • Supporting documents for DV-2022 selectees and their family members will be collected during the in-person interview and evaluated at the embassy or consulate where the visa application was made.
  • A full list of required supporting documents can be found here. DV applicants should also check the embassy or consulate’s website prior to their visa interview.
  • The State Department will refuse all DV-2022 applications that do not have all supporting documents; in case of a refusal, selectees will have the option to provide missing documents to the consular section.
  • The State Department strongly encourages applicants to have all required documents at the time of the interview to demonstrate their visa eligibility.

Additional Information: The State Department has changed the process for DV-2022 selectees to help fill all available DV appointments. As of Dec. 9, the Department is treating the document processing change as a pilot program and will analyze the costs and benefits of the change later in the program year.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 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 has temporarily eased certain regulatory requirements for some F-1 students from Hong Kong.

Key Points:

  • Hong Kong residents who are F-1 nonimmigrant students and are “experiencing severe economic hardship as a direct result of the emergent circumstances in Hong Kong” can now:
    • Request employment authorization from Nov. 26, 2021, through Feb. 5, 2023.
    • Work an increased number of hours while in school is in session.
    • Reduce their course load while continuing to maintain their F-1 student status.
  • To be eligible, individuals must have been lawfully present in the United States in an F-1 nonimmigrant status on Nov. 26, 2021.
  • 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:
    • An undergraduate student is registered for a minimum of six semester or quarter hours per academic term.
    • A graduate level student is registered for a minimum of three semester or quarter hours per academic term.

Background: In August, President Biden issued a memorandum to defer the removal of certain Hong Kong residents who are in the U.S. for 18 months because of the current circumstances in Hong Kong. DHS has now taken action to help F-1 nonimmigrant students who are Hong Kong residents facing economic hardships, regardless of their country of birth. 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 © 2021 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 Thursday that it would temporarily waive a requirement that civil surgeons sign a mandatory medical report no more than 60 days before applicants submit adjustment of status applications.

Key Points:

  • USCIS will accept applications for an underlying immigration benefit even if the civil surgeon signed the Form I-693, Report of Medical Examination and Vaccination Record more than 60 days earlier, including the Form I-485, Application to Register Permanent Residence or Adjust Status.
  • This waiver will remain in place until Sept. 30, 2022.
  • USCIS said the waiver would help applicants who have been impacted by the COVID-19 pandemic and related processing delays. The agency said the waiver would benefit a number of applicants, including Afghan nationals who were evacuated from Afghanistan and completed medical examinations but were not able to apply for adjustment of status within 60 days.

Additional Information: USCIS’s policy alert on this change is available here.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 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 sent a rule that will expand premium processing to additional benefit request types to the Office of Management and Budget (OMB) for review. The text of the rule is not yet available.

Key Points:

  • OMB review is the last step in the rulemaking process before the agency can publish the rule.
  • USCIS will post the text for public inspection at least a day before officially publishing the rule in the Federal Register.
  • The rule is classified as a “Final Rule,” which means a full notice-and-comment period is not expected. It is not yet known when the rule will take effect.

Background: In October 2020, Congress passed a funding bill that contained changes to premium processing, including increasing fees and giving USCIS authority to expand premium processing to additional petition types designated in the law. BAL will continue monitoring the USCIS rule and will provide updated 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 © 2021 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.