U.S. Citizenship and Immigration Services (USCIS) has reminded green card applicants that they must be fully vaccinated against COVID-19 to complete the required immigration medical examination.

Key Points:

  • Beginning Oct. 1, applicants who require an immigration medical examination must be fully vaccinated before a qualifying physician can complete the exam and sign Form I-693.
  • Applicants must provide vaccination documentation to the physician before completing the immigration medical examination.
  • USCIS may grant waivers to applicants who are “not age-appropriate” to receive a vaccination; have a “contraindication due to a medical condition” indicating an adverse reaction to the vaccination; or who undergo the exam in a jurisdiction where the vaccinations are “not routinely available” or are “limited in supply.” Applicants may also request a waiver on moral or religious grounds.

Additional Information: USCIS is updating its policy manual in line with the Centers for Disease Control and Prevention’s announcement in late August.

BAL Analysis: Employers and employees should contact their BAL professional with any questions about the new requirement. BAL continues to review and monitor the new vaccination requirement and will provide additional information ahead of the Oct. 1 implementation date.

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 (DHS) announced Tuesday that Croatia would be added to the Visa Waiver Program (VWP).

Key Points:

  • Beginning no later than Dec. 1, Croatian nationals will be eligible to travel to the United States for tourism or business purposes for up to 90 days without needing to apply for a visa.
  • Visa-waived nationals must register online for an Electronic System for Travel Authorization (ESTA) before travel. The ESTA registration is generally valid for two years or upon expiration of the traveler’s passport, whichever is earlier.
  • Travelers with valid B1 or B2 visas should continue to use their visa when traveling to the U.S.

BAL Analysis: Croatian business and tourist travelers will benefit from the convenience of not having to apply for a visa at a consulate once the change takes effect later this year. Visa-waived travelers are reminded to apply for their ESTA online at least 72 hours prior to travel.

At this time, a number of restrictions on travel to the U.S. remain in place. Travelers should continue to anticipate delays or limited availability of consular services 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 © 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 (DHS) plans to publish a proposed regulation tomorrow to “preserve and fortify” Deferred Action for Childhood Arrivals (DACA).

Key Points:

  • The proposed regulation is scheduled to be published on Tuesday, Sept. 28.
  • DHS will accept comments from the public for 60 days.
  • This is the first step in the formal notice-and-comment process, and a final rule would not take effect for several months.
  • The proposed rule would “preserve and fortify DHS’s DACA policy for the issuance of deferred action to certain young people who came to the United States many years ago as children, who have no current lawful immigration status, and who are generally low enforcement priorities.”
  • In July, a federal judge in Texas ruled that the DACA program was unlawful and enjoined the agency from continuing to implement it for new applicants. The Justice Department appealed the ruling earlier this month.

Additional Information: In January, President Joe Biden issued a memorandum ordering DHS to take steps to protect DACA. Following this directive, Secretary of Homeland Security Alejandro N. Mayorkas announced that DHS would propose a regulation to preserve and fortify DACA. Secretary Mayorkas reaffirmed that while this action would be an important step in protecting the 640,000 people brought to the U.S. as children, Congress still needed to pass legislation to give Dreamers full protection and a path to citizenship. Since then, more than 100 employers and trade associations have called on Congress to protect DACA, stating that DACA recipients’ “work and commitment to our companies, their families and communities are critical to our nation’s strength, especially since there are tens of thousands of DACA recipients working as frontline doctors and nurses and in other critical industries fighting COVID-19.”

BAL Analysis: At this time, DHS continues to adjudicate only renewal applications for existing DACA recipients. DHS will accept comments from the public on the proposed rule for 60 days. The agency will need to review the comments before publishing a final regulation, and expected legal challenges could affect implementation. BAL continues to monitor developments related to DACA and will provide updates as information becomes available. 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.

The Office of the Citizenship and Immigration Services Ombudsman (CIS Ombudsman) shared DACA renewal tips this week, urging applicants to file early and double check to make sure their applications are complete.

The Department of Homeland Security (DHS) is currently enjoined from adjudicating first-time DACA requests, but continues to process renewal requests. The CIS Ombudsman recommended that renewal applicants:

  • File early. DACA renewals should be filed 120 to 150 days before the expiration date on their Form I-797, Notice of Action, and Employment Authorization Document (EAD).
  • Check that their application is complete. Applicants should make sure that they (1) are submitting the most recent versions their DACA renewal form, EAD application form and accompanying worksheet. (2) have signed all forms; and (3) are paying the appropriate fee.
  • Check processing times. USCIS processing times continue to fluctuate. Applicants can use USCIS’s Check Case Processing Times website for current timelines. Applicants should note that USCIS generally does not consider requests for expedited processing of DACA requests.

Additional Information: In July, a federal judge in Texas ruled that the DACA program was unlawful and enjoined the agency from adjudicating first-time requests, but not renewals. The Justice Department appealed the ruling earlier this month. DHS is in the process of issuing a regulation to strengthen DACA. The text of the proposed rule is not yet available.

BAL Analysis: To avoid additional delays, DACA beneficiaries are encouraged to follow the Ombudsman’s recommendations when submitting DACA renewal requests. 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.

The Department of Homeland Security will extend the bans on nonessential land travel across the U.S. borders with Canada and Mexico, according to Federal Register notices set to be published on Wednesday, Sept. 22.

Key Points:

  • The land border restrictions will remain in effect until 11:59 p.m. EDT on Oct. 21.
  • Only “essential travel” will be permitted through border crossings along the U.S.-Canada and U.S.-Mexico borders.
  • The list of individuals engaging in “essential travel” includes:
    • U.S. citizens and lawful permanent residents (LPRs) returning to the U.S.
    • Individuals traveling for medical purposes, to attend educational institutions or for public health purposes.
    • Individuals traveling for work in the U.S. (e.g., agricultural workers), engaging in lawful cross-border trade (e.g., truck drivers transporting goods), or those traveling for a limited number of other reasons.
  • The bans do not apply to air or sea travel, but do apply to passenger rail travel, passenger ferry travel and boat travel for pleasure.

Additional Information: The U.S.’s bans on nonessential travel across land borders from Canada and Mexico have been in place since March 2020 and subsequently extended for 30-day periods since then.

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 White House said Monday that the U.S. would soon lift regional entry bans for foreign nationals who are vaccinated against COVID-19 and show proof of a negative test, numerous media outlets reported.

The White House had not posted an official announcement as of Monday afternoon, but reports said the policy would take effect in November and that once it is implemented:

  • Vaccinated travelers will no longer be subject to the current bans on entry to many foreign nationals who have been physically present in Brazil, China, India, Iran, Ireland, South Africa, the United Kingdom or the Schengen Area in the past 14 days.
  • Travelers will have to test negative for COVID-19 within 72 hours of travel and provide proof of the negative result, as is currently required.
  • Officials will develop criteria regarding what it means to be “fully vaccinated” and the type of proof that must be shown in order to travel.

White House officials indicated this change will apply only to international air travel and does not affect land border travel restrictions.


BAL Analysis: 
While the announcement indicates that traveling to the U.S. may soon become easier for many foreign nationals who are fully vaccinated, the White House has yet to post the text of the new policy or provide an exact implementation date. Key details remain unknown, including which vaccines the U.S. government will deem acceptable. For now, a number of restrictions on travel to the U.S. remain in place. Travelers should continue to anticipate delays or limited availability of consular services 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 © 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 Office of Management and Budget (OMB) has completed its review of the Department of Homeland Security’s (DHS) proposed rule to “preserve and fortify” Deferred Action for Childhood Arrivals (DACA). The text of the rule is not yet available.

Key Points:

  • Now that the proposed rule has cleared OMB review, the next step is for DHS to post the text of the proposal for public inspection. The agency will officially publish it in the Federal Register shortly after.
  • DHS will then accept comments from the public and must review and consider them before finalizing the regulation.
  • In July, a federal judge in Texas ruled that the DACA program was unlawful and enjoined the agency from continuing to implement it for new applicants. The Justice Department appealed the ruling earlier this month; the case is now before the Fifth Circuit Court of Appeals.

Additional Information: In January, President Joe Biden issued a memorandum ordering DHS to take steps to protect DACA. Following this directive, Secretary of Homeland Security Alejandro N. Mayorkas announced that DHS would propose a regulation to preserve and fortify DACA. Secretary Mayorkas reaffirmed that while this action would be an important step in protecting the 640,000 people brought to the U.S. as children, Congress still needed to pass legislation to give Dreamers full protection and a path to citizenship. Since then, over 100 employers and trade associations have called on Congress to protect DACA, stating that “their work and commitment to our companies, their families and communities are critical to our nation’s strength, especially since there are tens of thousands of DACA recipients working as frontline doctors and nurses and in other critical industries fighting COVID-19.”

BAL Analysis: Official publication of the proposed rule will begin a public comment period. DHS will need to review the comments before publishing a final regulation, and expected legal challenges could further delay implementation. At this time, DHS continues to adjudicate only renewal applications for existing DACA recipients. BAL continues to monitor for developments related to DACA and will continue to provide updates as information becomes available. 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.

The House Judiciary Committee advanced a budget bill this week that would provide a pathway to permanent residence for millions of immigrants and adopt measures to reduce the green card backlog.

The committee’s action is a first step in the legislative process. The Senate parliamentarian will soon determine whether the immigration provisions can be enacted through the budget reconciliation process, which allows the Senate to pass legislation by a simple majority rather than the usual 60 votes. Any immigration provisions would be part of a larger budget reconciliation package, which would need to pass the House and Senate and be signed by President Joe Biden to become law. Provisions may change before the two chambers vote on a final version of the package, depending on the parliamentarian’s ruling and political dynamics.

The version of the bill the House Judiciary Committee advanced would:

  • Provide a path to lawful permanent residence for certain Dreamers, essential workers and Temporary Protected Status (TPS) and Deferred Enforced Departure (DED) beneficiaries.
    • Applicants would not be subject to any annual numerical limit.
    • Both legal immigrants and those who are out of status would be able to obtain the benefit, provided they meet all requirements under the bill and are not subject to the bars to eligibility.
    • Many high-skilled immigrants would qualify as “essential workers” and would be able to adjust status under this provision in lieu of the traditional employment-based green card process.
  • Adopt measures to reduce the green card backlog and wait times, including:
    • Making more than 200,000 unused employment-based green cards from prior fiscal years available and preventing green card numbers from going unused in the future.
    • Allowing applicants still subject to the green card backlog to pay a fee to file an adjustment-of-status application before their priority date is current (i.e., “early adjustment filing”).
    • Allowing certain individuals to pay a fee to request an exemption from per-country caps.

Additional Information: For additional information, please see BAL’s analysis of the key immigration provisions in the House bill, available here. BAL will continue following the budget reconciliation process and will provide updates on important developments.

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. Justice Department has appealed a federal judge’s ruling that the Department of Homeland Security (DHS) did not follow proper procedures when it created the Deferred Action for Childhood Arrivals (DACA) program in 2012.

Key Points:

  • The case, Texas v. United States, will now be heard by the Fifth Circuit Court of Appeals.
  • In July, U.S. District Court Judge Andrew Hanen ruled that DHS violated the Administrative Procedure Act (APA) by creating and operating DACA. Judge Hanen stayed the ruling as it relates to current DACA recipients.
  • Following the ruling, U.S. Citizenship and Immigration Services confirmed that:
    • Current DACA recipients remain eligible for renewal of DACA relief, employment authorization and advance parole.
    • USCIS will not approve new or pending initial DACA applications; foreign nationals can continue to submit initial applications for possible future adjudication but USCIS cannot take action on them.
  • President Joe Biden had previously indicated the department would appeal the ruling, calling it “deeply disappointing.” In addition, a proposed DHS regulation to “preserve and fortify” DACA is under final White House review.

BAL Analysis: While the July ruling prevents DHS from approving any new first-time DACA grants, current DACA recipients remain able to file renewal requests and for employment authorization at this time. BAL continues to follow developments related to DACA, including in the courts and the regulatory process. 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.

The U.S. District Court for the District of Columbia has ordered the U.S. State Department to make good-faith efforts to process Diversity Visa (DV) applications by Sept. 30.

Key Points:

  • The State Department said it would prioritize and adjudicate as many additional DV-2021 cases as possible by Sept. 30.
  • DV cases will continue to be processed in rank order as required by law, and applicants must:
    • Be documentarily qualified.
    • Have paid all requisite application fees.
    • Be able to obtain the required medical exam by a panel physician.
    • Demonstrate that they are eligible for a visa before visa issuance.
  • If a consular section has the capacity to schedule a DV-2021 case, individuals will receive a notification by email to check the Entrant Status Check site.

Background: On Sept. 9, the U.S. District Court ruled that the Department could not prohibit staff from processing, reviewing or adjudicating 2021 DV applications based on the Nov. 2020 prioritization guidance. However, the court clarified that the November 2020 prioritization guidance “does not prevent any embassy personnel, consular officer, or administrative processing center from prioritizing the processing, adjudication, or issuance of visas based on resource constraints, limitations due to the COVID-19 pandemic, or country conditions.” More information on how the Department generally prioritizes immigrant visa applications can be found here.

BAL Analysis: BAL will continue to monitor Diversity Visa updates and will provide important 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 © 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.