• 22Apr

    As anticipated, USCIS announced on April 7 that it received a sufficient number of H-1B petitions to reach the statutory cap of 65,000 visas for fiscal year (FY) 2015. USCIS also received more than the limit of 20,000 H-1B petitions filed under the advanced degree exemption.

    In the first 5 business days of filing, USCIS reported to receive a record 172,500 H-1B petitions, including petitions filed for the advanced degree exemption.  This represents a nearly 30% increase from last year’s cap filings when 124,000 H-1B petitions were received within the first week of the filing period.

    On that basis, on April 10, 2014, USCIS announced that it deployed a computer-generated random selection process (i.e., a “lottery”) to select a sufficient number of petitions needed to meet the quotas.

    For those cap-subject petitions not randomly selected, USCIS will reject and return the petition with filing fees, unless it is found to be a duplicate filing.

    Given the exhaustion of H-1B visa numbers for fiscal year 2015, absent immigration reform legislation, the next time U.S. employers will be eligible to file an H-1B petition under the cap will be April 1, 2015, for a start date of October 2015.  Until then, employers are left with no choice but to consider alternative visa options for employing qualified foreign-born professionals. While there are a limited number of options available, there are, indeed, viable options for potential hires for whom you cannot (or will not) wait until October 1, 2015 to employ.

    Of course, USCIS will continue to accept and process petitions that are otherwise exempt from the cap.

    If you have any questions about the H-1B visa cap or would like to discuss appropriate alternatives to the H-1B category, please do not hesitate to contact us.

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  • 29Jan

    This is a reminder of the quickly approaching April 1, 2014 “deadline” for the filing of H-1B for Fiscal Year 2015 which starts on October 1, 2014.

    Given pent-up demand for H-1B numbers, we fully expect the cap to be reached on the first day of April.  USCIS will, however, accept petitions during the first five (5) business days; i.e., through April 7, 2014. Once the H-1B cap has been reached, employers will be ineligible to file new cap-subject H-1B petitions for a full year, until April 1, 2015. As such, we strongly encourage you to identify employees who may require H-1B sponsorship and contact us as soon as possible to begin preparing your H-1B petitions for a timely April 1 filing.

    Assess Your Company’s H-1B Cap-Subject Needs:

    The H-1B visa is, by far, the most sought-after temporary work visa in the United States for foreign-born, professional workers. The H-1B category requires sponsorship by a U.S. employer and is limited to specialty occupations which generally require the candidates hold at least a bachelor’s degree or the equivalent in a relevant discipline.  For current or transferring employees, employers should consider who might need to file an H-1B on April 1, 2014 for Fiscal Year 2015:

    • Identify F-1 (student) employees working pursuant to Optional Practical Training who will need to file a change of status to H-1B to continue working beyond the expiration of their current Employment Authorization Document (EAD);
    • Determine whether any TN employees (NAFTA professionals) will need to file a change of status to H-1B to be eligible to apply for adjustment of status to a lawful permanent resident;
    • Consider employees in L-1B status (intra-company transferees with specialized knowledge) who will need to file a change of status to an H-1B to gain an additional year of work authorization  (and for whom a change of status is a necessary component for a longer-term strategy of pursuing lawful permanent residence for that employee);
    • Consider employees in O-1 status (which O-1’s  are renewable in only one year increments) as compared to a full three (3) year validity period offered by the initial approval of the H-1B classification; and
    • Identify potential candidates who are currently abroad and have not been previously counted against the H-1B cap.

    PLEASE NOTE: the H-1B cap applies only to “new” H-1B petitions. As such, current H-1B nonimmigrant professionals seeking to file an extension of stay or a transfer petition are not subject to the cap.

    Any cap-subject petitions filed after the cap has been met will be returned to the sender who will not be eligible to re-file until April 1, 2015.

    If you have any questions about the H-1B visa cap, or would like to discuss appropriate alternatives to the H-1B category, please do not hesitate to contact us.

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  • 09Apr

    U.S. Citizenship and Immigration Services (”USCIS”) announced on April 5 that it had received a sufficient number of H-1B petitions to reach the statutory cap of 65,000 for fiscal year (”FY”) 2014. USCIS also announced that it received more than 20,000 H-1B petitions filed on behalf of persons exempt from the cap under the advanced U.S. degree cap. As such, Friday, April 5, was the final receipt date for new cap-subject H-1B petitions requesting an employment start date of October 1, 2013.

    The following Monday, April 8, USCIS followed up with an announcement that it received an astounding 124,000 H-1B petitions within the first week of the filing period, including petitions filed under the advanced degree exemption.

    As such, as it has done in the past, USCIS deployed a computer-generated random selection process (more commonly known as a “lottery”) to select a sufficient number of petitions needed to meet the caps.  For cap-subject petitions not randomly selected, USCIS will reject and return the petition with filing fees, unless it is found to be a duplicate filing.

    It may be a few weeks before we are advised whether a particular petition has been selected for adjudication.  In the past, this was accomplished by USCIS sending the petitioning employer (or its legal representative) a receipt notice (Form I-797) of the filing.

    The fact that the cap was reached within a matter of days is evidence of the high level of demand by U.S. employers eager to hire highly skilled foreign workers.  By contrast, last year, the H-1B cap was reached in slightly more than two (2) months.  The year before that, in 2010, the H-1B cap was not reached for ten (10) months.

    Given the exhaustion of H-1B visa numbers for fiscal year 2014, absent new reform legislation, the next time U.S. employers will be eligible to file an H-1B petition under the cap will be April 1, 2014, for a start date of October 2014.  As such, employers are left with no choice but to consider alternative visa options for employing qualified foreign-born professionals. While there are a limited number of options available, there are, indeed, viable options for potential hires for whom you cannot (or will not) wait until October 1, 2014 to employ.

    Of course, USCIS will continue to accept and process petitions that are otherwise exempt from the cap.

    If you have any questions about the H-1B visa cap or would like to discuss appropriate alternatives to the H-1B category, please do not hesitate to contact us.

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  • 01Feb

    On January 29, 2013, President Obama addressed the country on his principles for comprehensive immigration reform. A major theme running through the President’s remarks was that there should not be a struggle between “us” and “them.” President Obama pointed out that most of “us” used to be “them,” reminding the country that America was built by immigrants. He urged Congress to adopt a common-sense approach to immigration issues, hoping that progressive reform could be attained in the near future.

    The President’s plan is similar to the blueprint that was released earlier this month by the bipartisan group of Senators known as the “Gang of Eight.” The members of the “Gang of Eight” are Republican Senators Marco Rubio (FL), John McCain (AZ), Jeff Flake (AZ), and Lindsey Graham (SC); and Democrats Chuck Schumer (NY), Robert Menendez (NJ), Michael Bennet (CO), and Richard Durbin (IL). The issues at the heart of the immigration debate are border security, workplace verification, a pathway to citizenship, and a revamping of our legal immigration system.

    The first steps to immigration reform have been (and will continue to be) stepped up efforts of border security and a continued expansion of prosecutions for worksite compliance violations (I-9 and H-1B compliance) against employers. Opponents of immigration reform will push hard for tougher border security before considering a pathway to citizenship for undocumented immigrants. As such, we can expect more enforcement actions against U.S. employers, and perhaps a nationwide mandate to require employers to utilize the E-Verify system. (The Department of Homeland Security’s E-Verify system cross-references the Social Security Administration database with the DHS’ Immigration database to ensure that employees are legally authorized to work in the U.S.) A reform bill will most likely call for improvements to the E-Verify system to cut down on technical errors within the system.

    The next issue is creating a pathway to citizenship for the more than 11 million undocumented immigrants in the U.S. The plan proposed by the “Gang of Eight” calls for immediate “probationary legal status” for undocumented immigrants. This will be followed by an opportunity to obtain a permanent residence conditioned on the payment of back taxes, submitting to a background check, and other requirements, including learning English, passing a civics test, paying fines, and completing community service. In addition, it has been noted that undocumented immigrants will not jump ahead of those already “in line” for U.S. lawful permanent residence. Lastly, the Senate’s proposal supports implementing the Dream Act, which will open the door to citizenship for undocumented children who, through no fault of their own, were brought to the U.S. illegally by their parents. The DREAM Act will allow such undocumented children to pursue their studies at U.S. colleges and universities as well as a pathway to U.S. lawful permanent residence that would not require the same lengthy process as other undocumented immigrants.

    Last, but certainly not least, there has been discussions on many other types of backlog and quota reforms relating to legal immigration system. The President addressed the need for reform in the Immigration Courts, judicial review, increased opportunities for entrepreneurship visas in the United States, as well as a more expansive definition of families that includes same-sex couples. These reforms were not mentioned in the original plan outlined by the “Gang of Eight,” but are meant to be expanded upon in discussion on the Senate floor. Other possible reforms include increasing the H-1B cap to over 100,000 visas per year  and increases in the quotas for immigrant visas in order to shrink the horrendous backlogs we are currently facing in the both employment-based and family-based applications for lawful permanent residence.

    It should be interesting to monitor the progress made in Congress on immigration reform over the coming months. If the President is not satisfied with the progress of comprehensive immigration reform, he may propose his own legislation ahead of the “Gang of Eight.” The ability of politicians from both sides of the aisle to compromise and work together will be critical prior to any reform bill being passed.

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  • 29Jan

    With all of the recent political debate in Washington over the expansive topic of Comprehensive Immigration Reform, it’s easy to lose sight of the fact that the H-1B filing season is rapidly approaching!

    On April 1, employers will be eligible to begin filing new H-1B petitions with the USCIS for Fiscal Year 2014, which begins October 1, 2013. The quota (more commonly referred to as the “cap”) for new H-1B petitions is currently set by Congress at 65,000 per year and, of that number, 6,800 visas are automatically set aside for qualified foreign nationals from Chile and Singapore based on Free Trade Agreements with the United States. An additional 20,000 H-1B visas are available to candidates with a U.S. Master’s Degree.

    While last year’s H-1B cap was reached in less than three (3) months (mid-June 2012), due to pent-up demand, the cap may very well be reached in a few weeks, or perhaps even a few days! So to prepare for this year’s April 1 filing date, if you have not done so already, we recommend that you identify your current (or prospective) employees who may be subject to the cap and contact qualified immigration counsel to begin preparing your H-1B petitions for a timely April 1 filing.

    To Identify Employees Subject to the H-1B cap:  New H-1B applicants generally fall under one of the following 3 categories:  (i) current employees or new hires with a nonimmigrant status that will not permit them to work continuously through the effective date of a new H-1B classification, October 1, 2013 (e.g., F-1 students working pursuant to OPT, H-3 trainees, and/or J-1 exchange visitors), (ii) potential candidates who are abroad and have not been previously counted against the H-1B cap; or (iii) those employees for whom a change of status is a necessary component to planning your business’ long-term strategy of pursuing permanent residence for that employee (e.g., TN-1 professionals, L-1B specialized knowledge employees, and/or L-1A managers who do not qualify for permanent residence as multinational managers).

    It is important to note that the H-1B cap applies only to “new” H-1B petitions. As such, current H-1B employees seeking to file an H-1B extension of stay, or an H-1B transfer petition, are not subject to the cap.  Moreover, employees seeking H-1B sponsorship with an institution of higher education, a nonprofit research organization or a qualifying government research organization are generally not subject to the cap.

    If you have any questions about the H-1B visa cap, or would like to discuss appropriate alternatives to the H-1B category, please do not hesitate to contact us.

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  • 27Jun

    The negative impact of the recent trend of heightened scrutiny of employment-based immigration benefits (as evidenced by DOL’s statistics of increased PERM audits and denials, along with USCIS’ increased requests for evidence (“RFEs”)) was thrust into the limelight by recent coverage in Bloomberg Businessweek in an article entitled “Want to Move A Worker to the U.S.?  Good Luck”.

    The article discussed the utter frustration experienced by Oracle Corporation (NASDAQ:ORCL) regarding the increasing difficulty and expense in hiring and transferring foreign technology workers.   According to Denise Rahmani, the Director of the U.S. Immigration program at Oracle, the government denied an astonishing 38% of the Oracle’s visa requests last year. In the wake of these results, Ms. Rahmani has indicated that in today’s climate of heightened scrunity, “it feels like the roll of the dice every time.”

    While these frustrations are nothing new to multinational companies, large or small, Oracle’s recent complaints bring to life the realities associated with the recent trend by both USCIS and DOL of heightened scrutiny and standards of proof for employment-based petitions and applications.  Many companies, like Oracle, assert that the denials and requests for evidence are arbitrary in nature, the results of which often cost these companies millions of dollars in unnecessary expenses.  Indeed, in one rather gleaming example of the arbitrary nature of some of these USCIS denials, Ms. Rahmani reported that an Oracle worker’s request for an extension of stay of his/her L-1B nonimmigrant classification was denied because USCIS determined that the company failed to demonstrate the particular worker’s specialized knowledge of a certain type of Oracle software when, in reality, this particular employee was responsible for writing Oracle’s training manual for that software.

    It’s easy to understand the frustrations of Oracle and other companies. The higher instances of issuance of requests for evidence and ultimate denials reflect a major policy change in the Obama Administration of the immigration policy from prior years, when the denial rate for petitions seeking the L-1B classification, for example, was in the single digits.  Since 2008, the denial rate has tripled.

    USCIS Director Alejandro Mayorkas acknowledges the criticism that his office is inconsistent in its decision-making is “in part warranted,” and that he’s working to fix the problem.

    Bloomberg Businessweek posits that perhaps there aren’t enough caseworkers to properly handle the 400,000+ petitions filed every year for nonimmigrant workers and, that further, it is probably difficult for some caseworkers at USCIS to understand certain specialized fields, or whether or not American workers would be able to perform some jobs as well as the foreign workers many companies aim to hire.

    These frustrations have resulted in large companies including Oracle, Microsoft, Starwood Hotels and 50 other companies writing a letter to the Obama Administration warning them that this practice was hurting the American economy and job growth.

    Only time will tell if such letter will result in any type of policy change or whether the government will continue the disturbing trend of increased audits, RFEs and denials.

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  • 26Jun

    In May 2012, the Department of Homeland Security (DHS) released an updated list of science, technology, engineering, and mathematics (STEM) degrees that qualify for a 17-month extension of the 12-month period of Optional Practical Training (OPT). Indeed, students whose most recent degree qualifies as one of the disciplines provided on the DHS’ recently updated list are now eligible for up to 29 months of OPT, provided all other conditions are met (described below).  This 17 month extension of the OPT period, in most cases, is good news for a qualifying employer, as such extension may postpone the need for such employer to file an H-1B petition for an OPT employee for one additional year.  It also presents an advantage to employers, when the U.S. economy is more robust and the demand for new H-1B numbers is so great that USCIS resorts to an H-1B filing-based “lottery” system.  In those years, this 17 month extension of the OPT period provides employers with two “bites at the apple” for the chance of an employee being selected in the H-1B lottery.

    This decision is part of the Obama Administration’s attempt to make the United States more competitive in the global race to attract those students whom are often referred to as our “best and the brightest”.  When taking a closer look at the updated list, one will note the addition of new disciplines, which may also suggest that the government has actually expanded its horizons, and is adjusting to the ever-changing needs of our market economy. The list now includes, among other disciplines, degrees in behavioral sciences, pharmaceutical studies, econometrics and quantitative methods studies, all of which are new disciplines to the STEM designation entirely.

    The DHS has also suggested that it may “grandfather” certain students by permitting students with STEM degrees to apply for the OPT extension even if their STEM degree is not their most recent degree. We can only hope this suggestion comes to fruition as it will allow more highly-qualified foreign students in these newly introduced disciplines to take advantage of the 17 month extension of OPT, which extension was otherwise unavailable upon their completion of that degree.

    However, until such a change is formally adopted by DHS, the requirements for the 17 month extension of the 12 month period of OPT remain as follows:

    1)    A qualifying student must apply (and be authorized for) an initial 12-month OPT authorization;

    2)    The qualifying student must be working for an employer that is registered with E-Verify;

    3)    The qualifying student must apply for the 17 month extension during the 12 month period of OPT (i.e., he/she cannot apply within the 60-day departure grace period). However, if the qualifying student timely applied for the extension and a decision remained pending at the time the initial OPT period expires; the student can extend his/her work authorization for up to 180 days.

    Also, if a sponsoring employer applies for the H-1B classification under the annual cap for an OPT candidate, that candidate may also take advantage of the “cap gap” measure, which measure allows F-1 students whose OPT expires prior to October 1 (the effective date of a cap-subject H-1B petition) to continue working for the employer (with valid work authorization) while the H-1B visa petition is pending review and/or following approval of the petition by USCIS.

    If you have any questions regarding eligibility for an OPT extension, E-Verify, or the H-1B cap gap measure, please feel free to contact us.

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  • 21Jun

    In a memorandum written to the directors of the U.S. Customs and Border Protection Agency (CBP), Citizenship and Immigration Services (USCIS), and Immigration and Customs Enforcement Agency (ICE), the Obama Administration responded to years of pressure from immigration rights activists by authorizing the use of prosecutorial discretion by these agencies. The order effectively stops the deportation of certain young immigrants in this country, better known as DREAMers.

    DREAMers get their name from the DREAM Act, or the Development, Relief, and Education for Alien Minors Act, which was first introduced as bipartisan legislation in 2001 by Senators Dick Durban (D-Ill.) and Orrin Hatch (R-Utah). Initially, it garnered significant support as a novel way to alleviate part of the illegal immigration problem. The central tenant of the act focused on young immigrants of good moral character who were illegally brought into the country by their parents. The act was to provide them with legal residency status under certain conditions, including the completion of at least two years of college or military service, and at least five years of residency in the U.S. prior to the enactment of the legislation. The DREAM Act has since seen several different revisions, but has only been met with delay due to congressional inaction.

    Support for the DREAM Act seemed to be declining with the passage of time. However, in recent months, new legislation and proposals similar to the DREAM Act have begun circulating in Congress. In January, Rep. David Rivera (R-Fla.) introduced the ARMS Act, which would require military service as a condition to obtaining permanent resident status. Rep. Rivera also introduced the STARS Act just last month, an act that would allow undocumented students to receive permanent residency status if they were under the age of 19 at the time of application and subsequently completed a four-year degree.  Meanwhile, Senator Marco Rubio (R-Fla.) has made a proposal to provide non-immigrant visas to young illegal immigrants, though he has yet to specify any details of the legislation. Sen. Rubio has, however, expressed his intent to narrowly tailor the legislation to address Republican immigration concerns with the DREAM act.

    But talks of new legislation similar to the DREAM act came to a standstill after the announcement by the Obama Administration this past Friday. The memo written by the Secretary of Homeland Security, Janet Napolitano, set forth the criteria by which the Department of Homeland Security would exercise its prosecutorial discretion in enforcing immigration laws against those young people who were illegally brought into the U.S. but knew no other country as their home. The outlined criteria mirror that of the DREAM Act to a certain degree. Specifically, the memo states that if an individual: (1) came to the United States under the age of 16; (2) has continuously resided in the U.S. for at least five years preceding the date of the memo and is present in the U.S. on the date of the memo (June 15, 2012); (3) is currently in school, has graduated from high school, has obtained a general education development certificate, or is an honorably discharged veteran of the Coast Guard or the Armed Forces of the U.S.; (4) has not been convicted of a felony offense, a significant misdemeanor offense, multiple misdemeanor offenses, or otherwise poses as threat to national security or public safety; and (5) is not above the age of thirty; he/she should be subject to prosecutorial discretion and should be prevented from being placed into removal proceeding and being removed from the United States.

    “This grant of deferred action is not immunity,” Napolitano said in an interview. “It is not amnesty. It is an exercise of discretion so that these young people are not in the removal system. It will help us to continue to streamline immigration enforcement and ensure that resources are not spent pursuing the removal of low-priority cases involving productive young people.”

    The Obama Administration has stated that the policy change is expected to affect approximately 800,000 immigrants, though a Pew Hispanic Center (a project of the Pew Research Center) study has calculated that up to 1.4 million children and young adults could benefit from the change. This number represents an estimated 12% of the unauthorized immigrant population. 70% of the potential 1.4 million beneficiaries are from Mexico.

    Determinations will be made on a case-by-case basis, suggesting that relief cannot be guaranteed to an illegal immigrant simply because they fit the initial five criteria. Further, the President emphasized the temporary nature of the order and called for Congressional action in creating permanent legislation on this issue. As it stands, the order would become ineffective in two years unless renewed by the next president. Moreover, the order does not actually confer any kind of substantive right, immigration status, or pathway to citizenship. But the Department of Homeland Security has stated that individuals who are granted the deferred action may send applications to the USCIS to determine whether they qualify for work authorization.

    While those granted deferred action in accordance with the new policy are not necessarily on a path to U.S. permanent residency, let alone U.S. citizenship, they at least now are keeping their dream alive.

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  • 20Jun

    With the U.S. Citizenship and Immigration Services (“USCIS”) reportedly receiving 6-7 million applications per year, a speedier and more efficient adjudicative process is urgently needed.  In response, USCIS recently launched the first phase of ELIS (short for Electronic Immigration System), which is a web-based system that allows qualifying foreign nationals to electronically file petitions for extending or reinstating certain nonimmigrant visa classifications (B-1, B-2, F-1 M-1 or M-2). It is meant to be more efficient and reliable and, thus, will shorten the processing time of  the above-listed petitions.

    USCIS has plans to expand the scope of ELIS to allow users to electronically file petitions and applications seeking all immigrant and nonimmigrant classifications.

    In addition to shorter processing times, there are other benefits of using ELIS.  For example,  ELIS users have the advantage of paying filing fees online, updating user profiles online, responding to requests for additional evidence electronically, receiving USCIS notifications by way of email or text message (as soon as an adjudicating officer takes action on the pending petition and/or application), and submitting and storing supporting evidence for future use.

    It’s important to note that use of the ELIS is not mandatory for the above-described petitions - the paper filing alternative is still offered along with the previous E-filing system. The difference between the previous E-filing system and ELIS is that the latter is an end-to-end electronically based system, whereas the previous E-filing system still requires applicants to mail the supporting documents to USCIS for the adjudicating officers to review the applications manually, thus increasing the processing time.

    If you have any questions regarding the ELIS, please feel free to contact us.

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  • 12Jun

    The recent statistics on PERM processing (the first step of the employment-based green card process) and USCIS adjudication rates in the employment-based visa categories confirm a trend that practitioners have observed and struggled with over the past few years: higher rates of denial, delays in adjudication and increased PERM audits and requests for evidence (”RFEs”). To some, the data suggests that the government is overreacting to the economic conditions in the country, and unnecessarily impeding employers’ ability to retain the best and brightest foreign workers. However, a closer look at the numbers also reveals that we as practitioners have been able to adapt to the heightened standards of proof and are still able to achieve positive results for our clients.

    The 2012 Department of Labor statistics reveal an increase in denial rates of PERM petitions. While the Department denied less than 20% of PERM petitions between 2008 and 2010, that number has climbed to 25% for the fiscal 2011. The same trend is apparent with H-1B, L-1A, and L-1B petitions.  The denial rate for H-1B petitions has grown from 11% in 2007 to 29% in 2009 and 21% in 2010. Although denials dropped to 17% in 2011, the rate of issuance of RFEs increased significantly: from 4% in 2004, to 26% in 2011, peaking at 35% in 2009. For L-1A petitions, the denial rate grew by 6% between 2007 and 2011, and today every second petition is subjected to an RFE. The numbers in the L-1B category are even more disheartening: denials increased by 20% between 2007 and 2011, while the RFE rate nearly quadrupled for the same period.

    These are clear examples of how the government has raised the bar for employers in an attempt to safeguard American jobs. The drop in denial and RFE rates in the H-1B category between 2009 and 2011 indicates that practitioners are responding and adjusting to the new standards of proof. The fact that the rates of denial under PERM and H-1B are only higher by 5% and 6%, respectively, suggests that despite the heightened standard of proof, the government has not gone on an exclusionary war against business immigration. The bulk of these applications and petitions are still approved, despite audits and requests for evidence. In a way, this development does not mean that the system is necessarily flawed but, to the contrary, that it has been able to adapt to the economic conditions in the country without completely barring an employer’s ability to retain qualified foreign workers that make significant contributions to the U.S. Even though the economy has not recovered completely, the relatively small difference in denial rates for PERM applications and H-1B petitions suggests that practitioners are adapting and responding accordingly.

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