Practice Resources, Featured Issues

Featured Issue: Resources for H-2A Practice at DOL, USCIS, and DOS

11/14/24 AILA Doc. No. 24111402. Business Immigration, H-2A Agricultural Worker

The AILA Department of Labor (DOL) Liaison Committee provides a resource page with links to legal authorities, agency guidance and publications, and AILA resources and publications helpful for H-2A practice.

Legal Authorities

  • INA 101(a)(15)(H) Noncitizens coming temporarily to the United States to perform services
  • 8 CFR 214.2(h) Temporary employees

DOL-OFLC Guidance

Farmworker Protection Rule

Litigation To Block Farmworker Protection Rule

DOL-WHD

USCIS/DHS Guidance

US DOS Guidance

  • Foreign Affairs Manual
    9 FAM 402.10-4(D) H-2A Nonimmigrants
    9 FAM 402.10-8(D) Effect of DOL Revocation for H-2A Beneficiaries
    9 FAM 402.10-12 Length and Extension of Stay
    9 FAM 402.10-13(B) H-2A, H-2B Nonimmigrants Maximum Allowable Time

AILA Publications:

  • The Seasonal Visas: H-2A and H-2B: Temporary Yet Essential Workers Immigration Practice Pointers, 2024-25 Ed. (AILA 2024) by Loan T. Huynh, L.J. D’Arrigo, Ashley Foret Dees, and Ed White (AILA 2024)
  • H-2A and H-2B Practice: What Are We So Afraid Of? Immigration Practice Pointers, 2021-22 Ed. (AILA 2021), by Loan T. Huynh, L.J. D’Arrigo, Ashley Foret Dees, and Sujata Ajmera

Alerts

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Federal Agencies, Agency Memos & Announcements

USCIS Changes to Direct Filing Addresses for Form I-129 Petitions

USCIS changed direct filing addresses for certain petitioners of Form I-129, Petition for Nonimmigrant Worker, with petitioners now filing according to the state where the company or organization’s primary office is located. Starting 11/11/17, USCIS may reject forms filed at wrong service centers.

Federal Agencies, Agency Memos & Announcements

DOJ and DOS Partner to Protect U.S. Workers from Discrimination and Combat Fraud

DOJ and DOS signed an MOU for the Civil Rights Division and the Bureau of Consular Affairs to share information about employers that may be unlawfully discriminating, committing fraud, or making other misrepresentations in their use of employment-based visas, such as H-1B, H-2A, and H-2B visas.

Federal Agencies, Agency Memos & Announcements

iCERT Visa Portal System Quick Start Guide for H-2A Mandatory Documents Upload

DOL issued a Quick Start Guide to help employers, or if applicable, their authorized attorneys or agents, understand how to navigate the new mandatory documents upload function for preparing H-2A applications.

10/6/17 AILA Doc. No. 17100670. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

DOL Announces Changes to its iCERT System for H-2A and H-2B Programs

DOL’s OFLC announced that it updated the iCERT system's application filing module that will help employers or, if applicable, their authorized attorneys or agents, identify and upload required documentation supporting their applications. Guides for both H-2A and H-2B applications area available.

Federal Agencies

DOL Statistics on PWDs from Fourth Quarter of FY2017

DOL’s OFLC statistics from the National Prevailing Wage Center on prevailing wage determinations (PWD) as of 9/30/17, including number of applications received, top employers and occupations for PERM, H-1B, and H-2B, as well as number of determined, withdrawn, and pending prevailing wage actions.

Federal Agencies

DOL Statistics on H-2As from Fourth Quarter of FY2017

DOL’s OFLC statistics on H-2As, as of 9/30/17, including number of applications received; statistics on top states, employers, and occupations; as well as the status of applications processed.

9/30/17 AILA Doc. No. 17102335. Business Immigration, H-2A Agricultural Worker
Federal Agencies

USCIS Performance Data on H-2A Petitions for Fourth Quarter of FY2017

USCIS statistics on I-129 H-2A petitions, broken down by case status (received, approved, denied, or pending) and petitioner location (by state and company) for the fourth quarter of FY2017.

9/30/17 AILA Doc. No. 17121248. Business Immigration, H-2A Agricultural Worker
Cases & Decisions, DOJ/EOIR Cases

Justice Department Files Lawsuit Against Crop Production Services Alleging Discrimination Against U.S. Workers

The DOJ filed a lawsuit again Crop Production Services Inc., headquartered in Loveland, CO, alleging that in 2016, it discriminated against at least three United States citizens by refusing to employ them as seasonal technicians in El Campo, Texas, because it preferred to hire H-2A workers.

Federal Agencies, Agency Memos & Announcements

DOL Issues OFLC Accommodations for Those Impacted by Hurricane Harvey and Irma

DOL provided guidance in light of damage done by Hurricane Harvey and Hurricane Irma, including information on extensions of response deadlines and other reasonable case-accommodations, mail delivery to zip codes in the affected regions, advising OFLC of new contact information, and due dates.

Federal Agencies, Practice Resources

DOL Practice Alert: OFLC Accommodations for Those Impacted by Hurricane Irma

AILA's DOL Liaison Committee provides a practice alert that OFLC has confirmed it is working on releasing guidance for attorneys and employers impacted by Hurricane Irma.

Federal Agencies, Liaison Minutes

Minutes from DOL H-2 Stakeholder Meeting (9/12/17)

AILA’s DOL Liaison Committee’s minutes from the 9/12/17 OFLC H-2 stakeholder meeting with DOL. Some topics include: productivity standards and NODs, anticipated hours per week, piece rate wages, sensitive documents uploaded on iCERT, top dos and don’ts for H-2B filings, and NOAE responses by email.

Federal Agencies, Agency Memos & Announcements

DOL Provides Guidance In Light of Hurricane Harvey

DOL provided guidance in light of damage done by Hurricane Harvey, including information on extensions of response deadlines and other reasonable case-accommodations, mail delivery to zip codes in the affected regions, email delivery, advising OFLC of new contact information, and due dates.

DOL Provides OFLC Annual Report for FY2016

DOL provides an annual report from the Office of Foreign Labor Certification (OFLC) for FY2016, that presents employment-based foreign labor certification program data drawn from applications submitted to and adjudicated by DOL from employers who sought labor certifications in FY2016.

Federal Agencies, Practice Resources

DOL Practice Alert: OFLC Accommodations for Those Impacted by Hurricane Harvey

The DOL Liaison Committee provides a practice alert that OFLC has confirmed it is looking into the possibility of making accommodations for attorneys and employers impacted by Hurricane Harvey.

Federal Agencies

DOL Statistics on H-2As from Third Quarter of FY2017

DOL’s OFLC statistics on H-2As, as of 6/30/17, including number of applications received; statistics on top states, employers, and occupations; as well as the status of applications processed.

6/30/17 AILA Doc. No. 17072034. Business Immigration, H-2A Agricultural Worker
Federal Agencies

USCIS Performance Data on H-2A Petitions for Third Quarter of FY2017

USCIS statistics on I-129 H-2A petitions, broken down by case status (received, approved, denied, or pending) and petitioner location (by state and company) for the third quarter of FY2017 (4/1/17-6/30/17)

6/30/17 AILA Doc. No. 18081772. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Liaison Minutes

Minutes from DOL Wage and Hour Division Meeting (6/16/17)

AILA’s DOL Liaison Committee minutes from a meeting with DOL’s Wage and Hour Division (WHD) on 6/16/17. Topics include: WHD LCA Field Operations Handbook, electronic document storage, H-1B portability, H-1B return transportation, voluntary loans, H-2B deductions and fees, and H-2B worksites.

Federal Agencies, Agency Memos & Announcements

DOL FAQs on Job Offers, Assurances, and Obligations for the H-2A Program

DOL Round 12 FAQs to help H-2A employers understand the filing and documentation requirements that are necessary for an employer to demonstrate that the housing being offered to accommodate H-2A foreign workers complies with applicable housing standards for rental housing and public accommodations.

6/16/17 AILA Doc. No. 17061630. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Liaison Minutes

Minutes from OFLC H-2 Stakeholder Meeting (6/6/17)

AILA’s DOL Liaison Committee minutes from the 6/6/17 OFLC H-2 stakeholder meeting. Topics discussed focused primarily on prevailing wage determinations and the H-2B and H-2A programs.

Federal Agencies, Agency Memos & Announcements

Secretary of Labor Directs Agencies to Aggressively Confront Visa Program Fraud and Abuse

The Secretary of Labor determined that it is now the policy of DOL to “enforce vigorously all laws within its jurisdiction governing the administration and enforcement of nonimmigrant visa programs.” Notice outlines steps that DOL will take to investigate and detect visa program fraud and abuse.

Cases & Decisions, DOJ/EOIR Cases

OSC Announced Settlement Agreement with New Mexico Farm

OSC reached a settlement agreement with Carrillo Farm Labor, LLC, an onion farm in New Mexico. The settlement resolves the department’s investigation of complaints that Carrillo Farm discriminated against U.S. citizens due to a hiring preference for H-2A foreign visa workers.

Federal Agencies, FR Regulations & Notices

DOL Notice on Allowable Charges for H-2A Workers and Meal Reimbursements for H-2A and H-2B Workers

DOL notice for 2017 on the allowable charges that employers may charge H-2A agricultural workers when the employer provides three meals a day, as well as the maximum travel subsistence meal reimbursement that an H-2A or H-2B worker may claim. (82 FR 17881, 4/13/17)

Federal Agencies

DOL Statistics on H-2As from Second Quarter of FY2017

DOL’s OFLC statistics on H-2As, as of 3/31/17, including number of applications received; statistics on top states, employers, and occupations; as well as the status of applications processed.

3/31/17 AILA Doc. No. 17041936. Business Immigration, H-2A Agricultural Worker
Federal Agencies

USCIS Performance Data on H-2A Petitions for Second Quarter of FY2017

USCIS statistics on Form I-129, Petition for Nonimmigrant Temporary Agricultural Worker (H-2A), broken down by status (received, approved, denied, or pending) and petitioner location (by state and company) for the second quarter of FY2017.

3/31/17 AILA Doc. No. 17061565. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Liaison Minutes

Minutes from DOL H-2 Stakeholder Meeting (3/7/17)

The AILA DOL Liaison Committee’s minutes from the OFLC H-2 stakeholder meeting with DOL on 3/7/17. Some topics include: processing of H-2B filings, Notices of Deficiency, minor start date of need changes, H-2A post certification amendments, and staggered dates of need.