The Centers for Disease Control and Prevention (CDC) will soon require green card and immigrant visa applicants to be vaccinated against COVID-19.

Key Points:

  • Beginning Oct. 1, applicants for lawful permanent residence will be required to provide documentation of COVID-19 vaccination before the completion of their medical exam.
  • Applicants will be required to provide either an official vaccination record or a copy of a medical chart with entries from a physician or other appropriate medical personnel showing that the applicant has received the complete COVID-19 vaccination series.
  • Waivers will be available to applicants who are “not age-appropriate” to receive a vaccination; have a “contraindication or precaution” indicating that a person might have an adverse reaction to the vaccination; or are seen by a civil surgeon or panel physician in a jurisdiction where the vaccinations are “not routinely available.” Applicants will also be able to request a waiver from U.S. Citizenship and Immigration Services (USCIS) on moral or religious grounds.
  • Previous COVID-19 infections or laboratory tests showing immunity will not be permissible bases for a vaccination waiver.
  • USCIS has not yet issued guidance or specific instructions on the new requirement.

BAL Analysis: BAL continues to review CDC guidance on the new 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.

U.S. Citizenship and Immigration Services (USCIS) published an advanced notice of proposed rulemaking (ANPRM) regarding its administration of the public charge ground of inadmissibility.

Key Points:

  • USCIS is seeking broad public feedback on the public charge ground of inadmissibility for the next 60 days that will help the agency develop a future regulatory proposal.
  • The notice states that USCIS “intends to propose a rule that will be fully consistent with law; that will reflect empirical evidence to the extent relevant and available; that will be clear, fair, and comprehensible for officers as well as for noncitizens and their families; that will lead to fair and consistent adjudications and thus avoid unequal treatment of the similarly situated; and that will not otherwise unduly impose barriers on noncitizens seeking admission to or adjustment of status in the United States.”
  • The 2019 public charge rule is still not in effect, and the notice does not change eligibility requirements for immigration benefits.

Additional Information: Individuals may provide oral comments during two virtual public listening sessions if they register by noon EST on the Sunday before the listening session in question. The two sessions will take place on Sept. 14 at 2 p.m. EST and Oct. 5 at 2 p.m. EST. Further registration instructions can be found within the published notice. Written comments are due by Oct. 22.

More information about the public charge ground of inadmissibility is available on this USCIS page, where the agency recently added FAQs to reduce confusion about what standards are in place.

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 Monday, Aug. 23.

Key Points:

  • The land border restrictions will remain in effect until 11:59 p.m. EDT on Sept. 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 U.S. Chamber of Commerce recently filed a brief in its litigation challenging the Department of Homeland Security’s (DHS’) H-1B lottery prioritization rule, calling the rule “unlawful three times over.”

The rule, announced in October 2020, would do away with the random H-1B lottery and use a system that prioritizes individuals with the highest offered salaries. The U.S. Chamber of Commerce, National Association of Manufacturers, Presidents’ Alliance on Higher Education and Immigration and other plaintiffs argued in their recent brief, however, the rule is unlawful because:

  • It conflicts with the Immigration and Nationality Act (INA).
  • It was issued under Chad Wolf, whom courts have said was not lawfully appointed as Acting Secretary of Homeland Security.
  • It is “arbitrary and capricious” because DHS did not adequately respond to certain public comments or properly weigh implicated reliance interests.

“The government cannot resuscitate this fatally flawed and ill-advised rulemaking,” the brief said. “The Court should thus set aside the Lottery Rule.”

The litigation has a complicated procedural history. In December 2020, the judge overseeing the case set aside the Department of Labor’s prevailing wage regulation and the DHS “H-1B strengthening” rule. In June, the court vacated the updated version of the DOL wage rule, which was also challenged in the case. The judge allowed the claims related to the lottery rule to continue.

The lawsuit drew the backing of some of the country’s largest companies, 46 of whom signed an amicus brief last year in support of the litigation.

“The H-1B visa program provides tremendous benefits to the U.S. economy and U.S. workers,” the amicus brief said. “Numerous economic studies demonstrate that the presence in the United States of these high-skilled employees fuels innovation, increases productivity and the size of the U.S. economy, and—most important—creates additional jobs and higher wages for U.S. workers.”

Additional information on the lawsuit, Chamber of Commerce v. U.S. Department of Homeland Security, is available here.

BAL Analysis: The H-1B lottery prioritization rule would have a dramatic effect on the way H-1B visas are allocated, but it remains subject to litigation. A hearing will take place in September, and the plaintiffs have urged the court to rule quickly to provide clarity to companies on what rules will be in place next cap season. BAL will continue to follow the litigation 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 © 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.

A federal court has ordered the State Department to issue an additional 9,095 immigrant visas to winners of the 2020 Diversity Visa Lottery.

Key Points:

  • In a ruling last year, the court ordered the State Department to reserve 9,095 diversity immigrant visas to be issued after the normal Sept. 30 deadline. The court has now ordered the agency adjudicate applications for those visas.
  • The court found that the State Department incorrectly used former President Trump’s immigrant travel ban restrictions to stop processing visas for lottery winners.

Additional Information: The ruling requires the Department to process diversity visas randomly until the reserved 9,095 visas have been issued; however, the court left it to the parties to negotiate a reasonable timeframe within which the Department must issue the reserved visas.

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.

Priority-date cutoffs will advance in most key employment-based categories next month, according to the State Department’s September Visa Bulletin. U.S. Citizenship and Immigration Services (USCIS) confirmed that the Final Action Dates chart will control filing eligibility.

Key movements in Final Action Dates in September: 

EB-1

  • All countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance three months to July 1, 2018.
  • India EB-2 will advance three months to Sept. 1, 2011.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will remain at Jan. 8, 2019.
  • India EB-3 will advance six months to Jan 1, 2014.
  • 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 Vietnam
EB-1 Current Current Current Current Current Current Current
EB-2 Current July 1, 2018 Current Sept. 1, 2011 Current Current Current
EB-3 Current Jan. 8, 2019 Current Jan. 1, 2014 Current Current Current

Additional Information: September will mark the ninth time this fiscal year that USCIS will use Final Action Dates for employment-based adjustment-of-status applications. Family-based applicants may use the applicable Dates for Filing chart, except for F2A category applicants, who may use Final Action Dates.

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 extend the validity period of required medical exams for Green Card applicants.

Key Points:

Background: USCIS cited the COVID-19 pandemic and related delays in announcing the extension. Previously, a completed Form I-693 remained valid for two years from the date of the signature from a USCIS-authorized physician (also known as a “civil surgeon”), provided the date of the signature was no more than 60 days before the applicant filed for adjustment of status.

Additional Information: USCIS requested in its announcement that those applying for adjustment of status to lawful permanent residence (i.e., applying for a Green Card) file Form I-693, Report of Medical Examination and Vaccination Record, together with Form I-485, Application to Register Permanent Residence or Adjust Status. The agency said this may eliminate the need to issue a Request for Evidence (RFE) and would help alleviate delays. More information on the extension is available here.

This alert has been provided by 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.

A proposed rule that would “preserve and fortify” Deferred Action for Childhood Arrivals (DACA) is under final White House review. The text of the rule is not yet available.

Key Points:

  • Review by the Office of Management and Budget (OMB) is one of the last steps in the rulemaking process before the proposed rule is published. After the proposed rule clears review, the Department of Homeland Security (DHS) will post the text of the regulation for public inspection and officially publish it in the Federal Register shortly after. The agency will then accept comments from the public and must review and consider them before finalizing the regulation.
  • Last month, a federal judge in Texas ruled that the DACA program was unlawful and enjoined the agency from continuing to implement it for new applicants.

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: The rule is likely to take at least a few months to become a final rule, 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 legislative, regulatory and judicial 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.

U.S. Citizenship and Immigration Services (USCIS) announced today that permanent resident applicants may now apply for a Social Security number (SSN) or replacement card as part of the green-card application process.

Key Points:

  • Previously, applicants had to apply for a SSN at a Social Security office; individuals may now apply for a SSN or replacement card within the permanent resident application.
  • USCIS is revising the Form I-485, Application to Register Permanent Resident or Adjust Status, to include the additional questions needed to apply for a SSN or replacement card.
  • The Social Security Administration will automatically assign an individual a SSN as they receive requests from USCIS; applicants will not have to take any further action to receive their SSN.

Additional Information: USCIS Director Ur Jaddou, who was recently confirmed, stated that the agency’s decision to expand its partnership with the Social Security Administration intends to eliminate unnecessary bureaucracy and help make the immigration system more efficient.

BAL Analysis: This is a welcome change that will eliminate the additional step of applicants having to apply separately with the SSA for a social security number, which confers proof of a noncitizen’s eligibility for employment, social security benefits and other government services. BAL will continue to monitor these developments and will provide updates as they become 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.

The U.S. State Department published a proposed rule today that would give qualified applicants the option of renewing their U.S. passports online.

Key Points:

  • Eligible applicants would have the option to apply online via MyTravelGov by filling out the application online, uploading a photo and paying the government fee via pay.gov.
  • Applicants must meet all eligibility requirements to use the Online Passport Renewal (OPR) system; otherwise, they must use the mail-in application process.
  • The OPR system will initially apply to individuals in the U.S., and later be rolled out to those applying from abroad.
  • The proposed rule is open to public comments until Oct. 8.

Additional Information: Currently, U.S. passport renewal applicants typically use the mail-in process, requiring applications to be initially processed through a lockbox and then sent to a passport agency or center for further processing. The proposed rule seeks to provide more flexibility for the renewal applicant; eliminate the physical application and lockbox processing times; and increase data quality, protection and traceability.

BAL Analysis: The rule should help streamline the renewal process for eligible U.S. passport holders. The State Department indicated that after the public comment period closes, it intends to publish the final rule “as expeditiously as possible.” Passport applicants are reminded that the Department is still seeing extended processing delays and should apply at least six months before planned travel. BAL will continue to monitor these developments and will provide updates as they become 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.