In this week’s spotlight, BAL’s Josiah Curtis and Shane Andrews discuss hot topics from this year’s SHRM conference, from a potential H-1B second lottery to Kelly Clarkson.

Top immigration news clips include the Supreme Court’s overturn of the Chevron doctrine and Ireland’s new Employment Permits Act 2024.

Get these insights and more in the latest episode of BAL’s podcast, the BAL Immigration Report, available on Apple, Spotify and the BAL news site.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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.

Featuring Emily M. Dickens, Chief of Staff and Head of Public Affairs, the Society for Human Resource Management (SHRM).

Certain Ukrainian citizens in the United States are now eligible to apply for re-parole.

H-1B denial rates rose slightly in 2023.

And the Society for Human Resource Management pushes for much-needed reforms to employment-based immigration.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on Apple, Spotify and Google Podcasts or on the BAL news site.

This alert has been provided by the BAL U.S. Practice Group.

Copyright © 2024 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 proposal to modify the H-1B and F-1 visa programs clears White House review. The U.S. halts visa services in Israel. And an interview with BAL CEO Jeremy Fudge.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify and Google Podcasts or on the BAL news site.

‌This alert has been provided by the BAL U.S. Practice group.

Copyright ©2023 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.

Passport wait times begin to improve. Domestic Visa Renewal could be a game-changer but will take time and resources. And a look at the impact artificial intelligence may have on immigration law.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify and Google Podcasts or on the BAL news site.

‌This alert has been provided by the BAL U.S. Practice group.

Copyright ©2023 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 government is open—for now. The Supreme Court declines to hear a case challenging Optional Practical Training. And employers turn an eye toward the upcoming H-1B cap season.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify and Google Podcasts or on the BAL news site.

‌This alert has been provided by the BAL U.S. Practice group.

Copyright ©2023 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 government is on the verge of shutting down. The Biden administration announces new immigration measures, including extended Employment Authorization Documents. And analysis from the head of BAL’s Government Strategies team on why immigration is important to national security and global competitiveness.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify and Google Podcasts or on the BAL news site.

‌This alert has been provided by the BAL U.S. Practice group.

Copyright ©2023 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.

Learn how BAL’s H-2 legal team can help

H-2 visas enable U.S. businesses to hire foreign nationals for temporary or seasonal employment. Learn more about the different H-2 visa types and how BAL legal experts deliver a proven approach to support temporary staffing opportunities.


H-2A Visas

What is an H-2A visa?


The H-2A visa program allows a U.S. employer or agent to bring foreign nationals to the United States for temporary or seasonal agricultural jobs. The foreign national must have a standing offer of employment to qualify for an H-2A visa, and their prospective employer must meet certain regulatory requirements. If all legal requirements are met, the employer may petition the U.S. government to initiate the H-2Aprocess for the foreign national worker.

What are the requirements for H-2A nonimmigrant classification?


To qualify for H-2A nonimmigrant classification, an employer must:

• Offer a job that is temporary or seasonal in nature.
• Show that there are not enough U.S. workers able, willing, qualified, or available to do the temporary work.
• Demonstrate that employing the H-2A worker will not negatively impact the wages and working conditions of similarly-employed U.S. workers.
• Prove that the visa holder intends to return to their home country after the visa expiration date.
• Submit a valid temporary labor certification from the U.S. Department of Labor.

How long are H-2A workers allowed to stay in the U.S.?


A worker with an H-2A visa may be granted a stay for up to the period of time authorized on the temporary labor certification submitted by their employer to the U.S. government. H-2A classification stays may be extended in increments of up to 1 year. The maximum period an H-2A classification stay permission is 3 years.

Can a spouse enter the U.S. on an H-2A visa?


Whenever possible, BAL helps keep families together by assisting employees’ spouses and minor children to qualify for H-4 visas. Additionally, qualifying spouses and dependents of an H-2A worker may be allowed to enter the United States during the duration of their spouse’s H-2A visa, and the worker is given the unrestricted permission to travel into and outside of the U.S. during their visa period as well. Family members of H-2A workers are ineligible for employment in the U.S. under this program but may be able to personally qualify for a work visa.

What benefits and protections are H-2A workers provided?

H-2A visa holders are entitled to protection under U.S. wage and labor laws, workers’ compensation benefits, transportation, and certain housing and education benefits for themselves and their family.

Wages for H-2B workers must be the highest of the adverse effect wage rate (AEWR), the applicable prevailing wage, the agreed-upon collective bargaining rate, or the Federal or State statutory minimum wage.

H-2A employers are required to guarantee a minimum number of work hours to H-2A workers and offer employment for at least three-fourths of the total workdays in the contract period. Workers have the right to report any violations without fear of retaliation and be represented by an attorney in matters related to their employment. Terms and conditions of employment must be provided in a written contract by the employer in a language the worker understands.

Can H-2A visas be extended?


H-2A classifications may be extended in increments of up to 1 year each. The maximum extension permitted under the H-2A program is 3 years. With certain exceptions, after 3 years an H-2A worker must leave the U.S. for 3 consecutive months before seeking readmission.

How can BAL help?


Learn more about how BAL’s temporary workforce immigration experts can help your business.

H-2B Visas

What is an H-2B visa?


An H-2B nonimmigrant visa allows a U.S. employer or U.S. agent to bring foreign nationals to the U.S. for temporary, non-agricultural jobs.

Which industries use H-2B visas?


Many employers, such as seafood processors and the forestry industry, use the H-2B visa program to retain temporary, seasonal foreign national workers.

How can my business qualify to hire temporary, seasonal workers under the H-2B program?


To qualify for H-2B nonimmigrant visa classification, an employer must:

• Show that there are not enough U.S. workers able, willing, qualified, or available to do the temporary, non-agricultural work.
• Demonstrate that employing the H-2B worker will not negatively impact the wages and working conditions of similarly-employed U.S. workers.
• Show that the need for labor is temporary in duration. Work placement and temporary agencies are not eligible for the H-2B visa program.
• Submit a valid temporary labor certification from the U.S. Department of Labor.


How can my company establish an H-2B program temporary need for labor?


In order to demonstrate an H-2B program temporary need for labor, an employer must show that the labor is:

A one-time occurrence: An employment situation that is usually permanent has created the need for a temporary worker, the employer has not employed workers for the services or labor in the past, and the employer will not need to hire workers to perform the services or labor in the future.
Seasonal: The employer’s need for services or labor is tied to a season of the year by an event or pattern, and is of a recurring nature.
Peak load: The employer routinely employs permanent workers to perform the services or labor, needs to supplement its permanent staff due to a seasonal or short-term demand, and the temporary staff additions will not become part of the employer’s regular operation.
Intermittent: The employer has not hired permanent or full-time workers to perform the services or labor, and occasionally or intermittently needs workers for short periods.


Can an H-2B visa lead to a green card?

The H-2B visa is a nonimmigrant visa that does not directly lead to a green card, but H-2B visa holders can apply for an adjustment of status through employment-based preference categories.

The steps for employers when sponsoring a foreign worker for permanent residence generally include filing a prevailing wage determination with the U.S. Department of Labor, submitting an application for permanent labor certification (PERM), filing a Form I-140 with U.S. Citizenship and Immigration Services.

BAL is available to help companies navigate the green card process for H-2 and other eligible workers.

How can BAL help?


Learn more about how BAL’s temporary workforce immigration experts can help your business.

What is the Form I-9?

The Form I-9, Employment Eligibility Verification, is the form employers are required by law to use to verify that new hires are authorized to work in the United States. Employers must also “re-verify” the employment authorization of employees who have temporary forms of work authorization (i.e., with an expiration date). The Form I-9 is available free of charge on the U.S. Citizenship and Immigration Services (USCIS) website: www.uscis.gov/I-9.

Check out this video made by USCIS regarding the Form I-9.

Are there deadlines to complete the form?

Yes, the law imposes strict timeframes. The employee must complete Section 1 of the form no later than the first day of employment, which is the date that employment for wages or other remuneration begins. The earliest time an employee may complete Section 1 is after accepting a job offer from the employer.

Within three business days of the first day of employment, the employee must present documentation deemed acceptable by the government to demonstrate both identity and authorization to work in the U.S. The employer must physically review the employee’s original document or combination of documents, and complete Section 2 of the Form I-9 within three business days of the employee’s first day of employment. If the employee will work for the company for fewer than three days, both Section 1 and Section 2 of the Form I-9 must be completed no later than the first day of employment.

A previously established 30-day grace period (that was imposed due to COVID restrictions) is ending on July 31. Listen to the full update implications on BAL’s Immigration Report, episode 23, available here.

When does an employer need to complete a Form I-9?

All employers must complete and retain Form I-9 Employment Eligibility Verification for every person they hire for employment after Nov. 6, 1986, in the U.S., as long as the person works for pay or other type of payment.

In the Commonwealth of the Northern Mariana Islands (CNMI), employers have had to complete Form I-9 CNMI for every employee hired for employment in the CNMI from Nov. 28, 2009, to Nov. 27, 2011. The standard Form I-9 must be used for employees hired on or after Nov. 28, 2011.

What Employers Should Expect of the I-9 Audit?

In the event of an I-9 audit, either Immigration Customs Enforcement (ICE) or Homeland Security Investigations (HIS) will issue the employer a Notice of Inspection at least three days ahead of the intended audit. The Notice of Inspection will indicate whether the officials will ask for documentation to be sent in or whether the officials will visit the employer’s workplace.

Why Do You Need an Internal I-9 Audit?

Employers should proactively conduct internal I-9 audits to ensure they are compliant with all I-9 requirements and prepared in the event of an official audit. Failing an audit could result in fines and penalties on the employer including, but not limited to, criminal penalties (where there are repeat offenses), possible debarment from government contracts, as well as negative impacts on business reputation. The Department of Homeland Security recently increased fines for I-9 paperwork violations. As of 2022, fines range from $252 to $2,507 per I-9 form. Therefore, it is crucial that you prepare in advance to ensure appropriate I-9 maintenance.

BAL has an entire team of professionals who can assist companies in running I-9 compliance and E-Verify programs, as well as assist with complicated I-9 audit preparation. Contact us  for more information!

I-9 Compliance Guidance for Certain Employees That Fall Into Special Categories:

  • Employees in the Commonwealth of the Northern Mariana Islands: Individuals hired for employment in the Commonwealth of the Northern Mariana Islands.
  • Employees from the Federated States of Micronesia, the Republic of the Marshall Islands, and Palau: Individuals hired for employment who are from the Federated States of Micronesia, the Republic of the Marshall Islands, and Palau.
  • Domestic workers: Individuals who perform child care, household tasks, and/or upkeep of a home or surrounding yard on a regular basis in return for wages or other benefits, and who are not independent contractors or providing services on a sporadic basis or for independent contractors or separate businesses.
  • Minors: Individuals under the age of 18.
  • Employees with disabilities: Individuals with physical or mental impairments that significantly limits one or more major life activities and are placed in a job by a nonprofit organization or association, or as part of a rehabilitation program.
  • Temporary Protected Status (TPS) beneficiaries: Certain individuals from specific foreign countries beset by extraordinary and temporary conditions such as natural disasters and civil wars.
  • Asylees and refugees: Non-U.S. citizens who typically have left their own country and are unable or unwilling to return because of persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.
  • Foreign students: Individuals traveling temporarily to the U.S. to pursue a full course of study in an approved program in either an academic or vocational institution, or a recognized nonacademic institution. Academic institutions include colleges, universities, seminary, conservatories, academic high schools, elementary schools, other institutions, and language training programs.
  • Exchange visitors: Individuals traveling temporarily to the U.S as participants in exchange programs administered by the U.S. Department of State.
  • E-Visa holders: Treaty traders and investors who are citizens or nationals of a country that has a treaty of commerce and navigation with the U.S. and who travel to the U.S. under such treaty. This category also includes Australian specialty occupation workers.
  • NAFTA (TN) workers: Professionals and other workers from Canada and Mexico traveling temporarily under the North American Free Trade Agreement (NAFTA), which created special economic and trade relationships for the U.S., Canada, and Mexico.
  • Temporary nonimmigrant workers: Individuals traveling to the U.S. lawfully as nonimmigrants to work temporarily in the U.S.
  • Mergers and acquisitions: Employers’ Form I-9 responsibilities may be affected when they are acquired by or merge with another company.
  • Employees resuming their job after a temporary break in employment: Individuals may be considered to be continuing in employment (with no new Form I-9 required) if, for example, they return to work after taking approved paid or unpaid leave or being laid off.

Exceptions for Completing and Retaining Form I-9

In some cases, employers are not required to complete or keep a Form I-9. Employers are required to complete and retain a Form I-9 for every employee they hire for employment in the United States, except for:

  1. Individuals not physically working in the U.S.
  2. Individuals hired on or before Nov. 6, 1986, who are continuing in their employment and have a reasonable expectation of employment at all times (some limitations to this exception apply); and individuals hired for employment in the CNMI on or before Nov. 27, 2009.
  3. Individuals employed for casual domestic work in a private home on a sporadic, irregular, or intermittent basis.
  4. Independent contractors or individuals providing labor if they are employed by a contractor providing contract services (for example, employee leasing or temporary agencies).

Employers can find more information about the Form I-9 requirements in the USCIS Handbook for Employers on the USCIS website.

BAL can help!

BAL has an entire team of professionals who can assist companies in running I-9 compliance and E-Verify programs. Contact us  for more information!

Getting it right from the start.

Over the past 43 years BAL has helped thousands of clients create an immigration program or enhance their existing one. Based on our experience and expertise, here are some considerations as you get started.

  • What business needs are driving your U.S. immigration policy? Will hiring foreign talent fill those needs? Your company’s immigration program should be aligned with your company’s business goals, recruiting norms, and internal culture to accomplish the objectives specific to your organization.
  • What factors will determine if a role or person will meet sponsorship eligibility? Consider eligibility factors such as whether the role qualifies for visa sponsorship when you want to initiate the sponsorship process for a new hire.
  • Will sponsorship include both nonimmigrant and immigrant categories? Registering for the H-1B lottery requires little from the employer, while sponsoring an employee for a green card requires a greater commitment. Consider the scope of your green card sponsorship.
  • Will your company sponsor international students in the F-1 OPT/STEM OPT or J-1 Intern/Trainee programs? Offering jobs to students gives you the chance to evaluate their skills and fit within your company before you enter a long-term sponsorship commitment. However, these programs do have specific limitations and obligations.
  • Will your company support dependents/family members? In competitive recruitment environments, many employers are offering incentives, such as supporting the immigration process for dependents and family members.
  • Will the policy have a different approach for high-level executives or certain emergency business needs? Companies often want or need to provide expedited immigration service for high-level executives or emergency staffing needs.

We’re sure you’ll have more questions as your program takes shape, and BAL would be happy to help you with proven, real-world answers.

Get this news and more in the new episode of BAL’s podcast, the BAL Immigration Report, available on AppleSpotify and Google Podcasts or on the BAL news site.

‌This alert has been provided by the BAL U.S. Practice Group.

Copyright ©2023 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.