The cost of running an immigration program at a U.S. company just went up — a lot.

On Jan. 31, U.S. Citizenship and Immigration Services published a final regulation to raise immigration filing fees — and high-skilled categories saw some of the biggest increases. On April 1, the fee for an H-1B petition increased from $460 to $780 (70%), and the fee for an L-1 intracompany transfer petition increased from $460 to $1,385 (201%). All of that is before a new $600 Asylum Program Fee ($300 for small employers) is added on for each employment-based nonimmigrant or immigrant filing. Analysis from the BAL Government Strategies team shows that a typical small- or medium-sized company may see the amount they spend on filing fees more than double.

None of this is good news.

At the same time, the fee increases present an opportunity for companies to take stock of their immigration programs and reassess whether they are doing everything they can to take advantage of policy improvements that the Biden administration has made.

The fee increases are the first since 2016, and USCIS has said it will put the additional revenue to good use — not only by helping them meet the challenge of expanded humanitarian programs but also by improving processing times and reducing backlogs for employment-based filings. While the business community was clear that it would have liked to see USCIS implement additional efficiencies before raising fees, the administration has shown good faith by working to streamline programs with its current funding level. Consider:

  • Improvements to the H-1B program: Just days after it published the regulation to raise fees, USCIS published a separate regulation to overhaul the H-1B registration and selection process. The big change is a switch from a petitioner- to a beneficiary-centric lottery, so that each H-1B beneficiary may be selected only once, no matter how many registrations are submitted on his or her behalf. This change is designed to eliminate incentives for bad actors to submit multiple H-1B registrations for the same individual — and has the potential to reduce the overall number of registrations and boost the H-1B selection rate. The change enjoys broad support in the business community. So do the introduction of online H-1B filings and a new pilot program that allows some H-1B holders to renew their visas in the U.S. without going abroad.
  • Extended employment authorization: In September 2023, USCIS increased the maximum validity of Employment Authorization Documents (along with Advance Parole travel documents) to five years for employees with pending green card applications. This change did not draw as much attention as the H-1B overhaul but has proved to be a boon to employers. Previously, green card applicants had to renew their employment authorization every two years. The longer validity saves not only time and money but also adds predictability. Improved EAD processing times are an additional benefit.
  • Flexibility in the green card process: With the labor certification process (PERM) becoming increasingly difficult, employers continue to turn toward national interest waivers as a green card strategy. This trend is due in part to the increased difficulty of the PERM process when employers have had layoffs. The administration published new guidance on national interest waivers for EB-2 visas in January 2022 and made EB-2 visas a priority in an executive order on intelligence published last fall. The Department of Labor has also asked for public input on whether to revise its list of Schedule A job classifications that do not require labor certification. This list has not been updated since 2004.
  • Improved visa processing abroad: The U.S. State Department issued more than 10.4 million nonimmigrant visas in the last fiscal year. This figure was nearly a record and the highest total since 2015. It also highlights a marked turnaround in visa processing efficiency at U.S. embassies in consulates following years of reduced staffing and delayed wait times. State Department fees also went up last spring. And while the State Department and USCIS are different agencies with different challenges, the success in improving visa processing abroad is consistent with the Biden administration’s broader overall efforts to improve immigration services.

Understandably, we have heard plenty at BAL from employers frustrated with how dramatically fees increased. What we have not heard, however, is that employers plan on dramatically cutting back their immigration programs. This is good news — and not only because it means companies will continue to recruit top workers to help keep them competitive.

Despite higher fees, there is ample evidence that it is a good idea to invest in foreign workers now, at a time of generally favorable policies. Take the H-1B program as one example. The H-1B registration fee has increased from $10 to $215 for next year’s cap registration, which gave employers an incentive to put eligible employees in the lottery this year if they were able to do so. On top of that, for beneficiaries that were not selected, employers have more favorable options for H-1B alternatives now than they previously did. The administration has added new qualifying fields of study to its STEM Designated Degree Program List, making more recent graduates eligible for extended Optional Practical Training. Officials also provided clarifying guidance on O-1 “extraordinary ability” visa criteria, making this category an increasingly common option.

None of the administration’s immigration programs are ensured to continue under future administrations. In the current political environment, there is no telling how long they will last.

Donald Trump has emerged as the Republican Party’s presumptive nominee for president. Whatever you think of Trump’s politics, it is plainly true that when he was in office, it was harder to recruit and retain high-skilled foreign workers. H-1B denial rates skyrocketed and processing backlogs ballooned at understaffed agencies. COVID-19 only made the problems worse.

Nobody knows what Trump may do if he wins this year’s election, but it certainly seems unlikely he would decrease immigration fees. Employers could be stuck with higher rates for reduced services.

The adage “never let a crisis go to waste” is instructive as employers face higher costs and uncertainty about the future of favorable immigration policies. While no one enjoys paying higher fees, employers should review their immigration strategies to take advantage of easier processes now before it’s too late.

John is a partner and head of BAL’s New York office focused on corporate clients with a range of immigration-specific issues and challenges. This article originally appeared in the most recent edition of Mobility Magazine. 

H-1B registration has closed and petition filing begins next week.

The government opens an H-2B cap for returning workers.

And a look at how employers have been preparing for major USCIS filing fee increases.

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.

On Jan. 30, the Department of Homeland Security published the long-anticipated and final U.S. Citizenship and Immigration Services fee rule. Under the final rule, immigration filing fees will see their most dramatic increases in years. The new fee schedule is set to take effect April 1, 2024.

We’re breaking down the new rule to help you understand how these fee increases could impact your business and its immigration program.

Highlights from the rule

A chart summarizing the fee increases is available on page 5 of the final rule that was officially published in the Federal Register on Wednesday, Jan. 31.

H-1Bs

The fee for an H-1B petition will increase from $460 to $780, an increase of 70%.

The H-1B registration fee will also increase from $10 to $215, though the higher rate will not be in effect for this year’s H-1B registration period, which runs from March 6-22. USCIS does, however, plan to charge the higher fee for H-1B petitions once cap filing begins April 1. According to the rule, any benefit request postmarked on or after the April 1 effective date must be accompanied with the higher fee.

Other petition fees

  • The fee for an L-1 petition will increase from $460 to $1,385.
  • The I-140 petition fee will increase from $700 to $715.
  • The I-485 petition fee will increase from $1,225 to $1,440, and the fees for the adjustment of status bundle (I-485, I-131, I-765) will increase from $1,225 to $2,330.

Asylum program fee

The final rule also includes a $600 asylum program fee that will be charged for each Form I-129 and Form I-140 filing. This fee will come on top of increases to base filing fees. However, the fee will be reduced to $300 for small employers (25 or fewer employees) and nonprofit organizations are exempt from the fee.

Premium processing

Finally, the rule will also change premium processing timeframes from calendar days to business days, potentially extending the processing window.

 

Breakdown of proposed USCIS fee increases by petition type

Potential impact to businesses

We’ve crunched the numbers to illustrate the impact to hypothetical small- and mid-size programs.

Illustrative impact for small programs

ABC Company completed 54 filings in 2023 that will be impacted by the fee increases.

ABC Company’s 2023 filings impacted by the new fees

Form or Type Description # of Petitions
H-1B Registration H-1B Registration 6
I-129 Petition for Nonimmigrant Worker – H-1 17
I-129 Petition for Nonimmigrant Worker – H-2A (named) 6
I-129 Petition for Nonimmigrant Worker – Other 1
I-131 Application for Travel Document – Reentry Permit or Advance Parole 3
I-140 Immigrant Petition for Alien Worker 3
I-485 Application to Register Permanent Residence or Adjust Status (includes I-131 & I-765) 2
I-539 Application to Extend/Change Nonimmigrant Status 8
I-765 Application for Employment Authorization 8
Total number of relevant filings 54

In 2023, the total filing fees the company paid was $23,445.

With the new fees applied, ABC Company’s total fees will increase by 134% to $54,920, an increase of $31,475.

Illustrative impact for medium programs

XYZ Company completed 259 filings in 2023 that will be impacted by the fee increases.

XYZ Company’s 2023 filings impacted by the new fees

Form or Type Description # of Petitions
H-1B Registration H-1B Registration 47
I-129 Petition for Nonimmigrant Worker – H-1 71
I-129 Petition for Nonimmigrant Worker – L 2
I-129 Petition for Nonimmigrant Worker – O 5
I-129 Petition for Nonimmigrant Worker – Other 9
I-130 Petition for Alien Relative 2
I-131 Application for Travel Document – Reentry Permit or Advanced Parole 16
I-140 Immigrant Petition for Alien Worker 28
I-485 Application to Register Permanent Residence or Adjust Status (Includes I-131 & I-765) 9
I-539 Application to Extend/Change Nonimmigrant Status 25
I-751 Petition to Remove Conditions on Residence 1
I-765 Application for Employment Authorization 43
N-400 Application for Naturalization 1
Total number of relevant filings 259

In 2023, the total filing fees the company paid was $108,735.

With the new fees applied, XYZ Company’s total fees will increase by 120% to $239,705, an increase of $130,970.

Fee calculator

So what will the increases mean for YOUR business?

Our USCIS fee calculator allows you to calculate the filing fees for your program.

BAL and BAL Community continue to review the final rule and will provide updated information and resources in the coming days and weeks. Subscribe to our newsletter and join BAL Community for access to upcoming focus groups, webinars and additional expert analysis on the USCIS fee increases.

The State Department publishes a proposal on allowing third parties at interviews for U.S. citizen services. Foreign musicians and artists express concern about proposed filing fee increases. And a look at how passport applications have swamped the State Department — and what that means for business.

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.

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.

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.

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.

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.

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.