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, FR Regulations & Notices

DOL Final Rule Rescinding Logging Employment Regulations

DOL final rule rescinding the regulations for employers in the logging industry utilizing foreign workers, as they became obsolete after a rulemaking in 2010 reassigned “logging employment” within the definition of “agricultural labor or services” under the H-2A program. (78 FR 69541, 11/20/13)

11/20/13 AILA Doc. No. 13112058. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

USCIS Temporary Accommodation for H-2A Petitions Expires on 11/29/13

USCIS alert that its temporary accommodation to allow H-2A petitioners to file Form I-129 with a copy of the signed, certified TLC, will expire on 11/29/13. Beginning 12/2/13, H-2A petitions filed without the certified TLC on blue security paper and original signatures will not be accepted.

11/18/13 AILA Doc. No. 13111804. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

USDA Postponed Release of 2014 H-2A AEWR Wage Data

DOL alert that the USDA postponed the release of the Farm Labor Survey until 12/5/13, which is used to establish the Adverse Effect Wage Rates (AEWR) in the H-2A program.

11/14/13 AILA Doc. No. 13111444. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Liaison Minutes

AILA/SCOPS Liaison Q&As (11/13/13)

Q&As from the 11/13/13 teleconference with SCOPS include an update on FY2014 H-1B processing and H-1B extensions, late filings post-government shutdown, EB-1(3) denials, boilerplate O-1 RFEs, translations, and OPT unpaid employment.

Federal Agencies, Agency Memos & Announcements

USCIS Interim Memo with Additional Guidance on Determining Periods of Admission for Previously Admitted H-4 Nonimmigrants

USCIS interim memo dated 11/11/13, updating Chapter 31.2(d)(2) of the AFM, clarifying that time spent as an H-4 dependent does not count against the maximum allowable periods of stay available to H-2A, H-2B, or H-3 principals. Comments accepted until 12/2/13 and memo is in effect.

Federal Agencies, Agency Memos & Announcements

USCIS Policy Memo on Determining Periods of Admission for Previously Admitted H-4 Nonimmigrants

USCIS policy memo with additional guidance regarding how Immigration Services Officers should determine periods of admission, stating that time spent as an H-4 dependent does not count against the maximum allowable periods of stay available to principals in H-2A, H-2B, or H-3 status.

Federal Agencies, Agency Memos & Announcements

DOL Handling of Applications and Responses After Government Shutdown

OFLC alert on the handling of applications/responses impacted by the shutdown, including submissions received between 10/1/13 and 10/18, filing time-sensitive recruitment or PWDs that were not submitted due to the shutdown, and responding to deadline that fell between 10/1 and 10/18.

Federal Agencies, Agency Memos & Announcements

DOL Alert that ETA Form 232 and ETA Form 232-A Have Been Revised

DOL alert that ETA Form 232, Domestic Agricultural In-Season Wage Report and ETA Form 232-A, Wage Survey Interview Report, have been revised. State Workforce Agencies should use the new forms for future H-2A program wage reporting to OFLC as of 10/28/13.

10/28/13 AILA Doc. No. 13102851. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

DOL Alert that Approved H-2A Certifications Will Be Sent Via PDF Until 11/18/13

DOL alert that the 10/21/13 OFLC temporary accommodation of sending an Adobe PDF of approved certifications to H-2A employers and authorized representatives will continue through 11/18/13.

10/28/13 AILA Doc. No. 13102850. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

USCIS Alert on Temporary Accommodations for Form I-129 H-2A Petitions

USCIS alert that beginning on 10/23/13, due to the unique time sensitivities associated with agricultural work, USCIS will temporarily accept H-2A petitions that are filed with a copy of the certified TLC and signatures on the TLC submitted to USCIS do not need to be original.

10/23/13 AILA Doc. No. 13102343. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

DOL Alert Regarding H-2A Certifications Post-Government Shutdown

DOL alert that due to the unique perishable nature of the agricultural commodities in the H-2A program, OFLC will temporarily (for a period not to exceed 30 days) implement special mailing procedures for H-2A certifications.

10/21/13 AILA Doc. No. 13102142. Business Immigration, H-2A Agricultural Worker
Federal Agencies, Agency Memos & Announcements

USCIS Alert Regarding I-129 Filings During Government Shutdown

USCIS alert that if an H-1B, H-2A or H-2B petition is submitted with evidence that the primary reason for failing to timely file an extension of stay or change of status request was the government shutdown, USCIS will excuse the late filing, if the petitioner meets all other applicable requirements.

Federal Agencies

USCIS Statistics on H-2A Receipts, Approvals, and Denials by Petitioner State and Fiscal Quarter

USCIS statistics on Form I-129 H-2A receipts, approvals, and denials by petitioner state and fiscal quarter. Data based on cases filed between October 2012 and June 2013.

10/8/13 AILA Doc. No. 14012450. Business Immigration, H-2A Agricultural Worker
Cases & Decisions, DOJ/EOIR Cases

OSC Settlement Over Allegations of Preferring to Hire H-2As Over LPRs

OSC settled with Huber Nurseries, based in Maneim, Pennsylvania, resolving allegations that Huber engaged in citizenship status discrimination by preferring to hire temporary H-2A visa holders over LPRs from Nepal.

Federal Agencies, Agency Memos & Announcements

DOL Alert on H-2A/H-2B Ombudsman Customer Service Survey

DOL alert announcing a new online survey for stakeholders to provide feedback on their experiences with the H-2A and H-2B Ombudsman Program.

Federal Agencies, Agency Memos & Announcements

DOS Cable with Revised Reciprocity Schedule for Armenia

A 9/23/13 DOS cable with a revised nonimmigrant reciprocity fee schedule for Armenia, effective 9/19/13.

AILA Public Statements, Memo & Regulatory Comments

AILA Comments on Proposed Changes to Form I-129

AILA’s comments in response to proposed revisions to Form I-129, Petition for a Nonimmigrant Worker, and accompanying instructions. Special thanks to Dagmar Butte, Steve Navarre, and Punam Rogers.

DHS Report on Nonimmigrant Admissions to the U.S. During 2012

DHS August 2013 Annual Flow Report on nonimmigrant admissions to the U.S. during 2012, including definitions and comparisons from 2010, 2011, and 2012 on admission by class, country of citizenship, port of entry, and destination state.

Federal Agencies, Practice Resources

AILA Resources on I-94 Automation (Updated 7/31/13)

AILA liaison provides a list of resources found on InfoNet and related to CBP’s automation of Form I-94.

Federal Agencies

OFLC Performance Data Website

DOL Office of Foreign Labor Certification (OFLC) program information website with annual reports, selected statistics by program, and cumulative quarterly and annual releases of program disclosure data to assist with external research and program evaluation.

Federal Agencies

DOL Statistics on H-2A Program for Third Quarter of FY2013

DOL Office of Foreign Labor Certification factsheet with statistics on the H-2A program for the third quarter of FY2013.

7/29/13 AILA Doc. No. 13072942. Business Immigration, H-2A Agricultural Worker
Federal Agencies, FR Regulations & Notices

USCIS Notice of Proposed Changes to Form I-129 (Updated 10/24/13)

USCIS notice of additional 30 days of information collection on the Petition for a Nonimmigrant Worker, Form I-129. Comments are now accepted through 11/25/13. (78 FR 63487, 10/24/13) (78 FR 40490, 7/5/13)

Federal Agencies, Agency Memos & Announcements

DOL New Online iCERT Labor Certification Registry Is Now Live

DOL announced that its new online tool called the iCERT Labor Certification Registry is now live, making available to the general public appropriately redacted copies of H–1B, H–1B1, E–3, H–2A, H–2B and permanent labor certification documents.

Federal Agencies, Practice Resources

DOL Practice Alert: Public Labor Certification Registry Is Now Live

The AILA DOL Committee alerts members to the recent DOL announcement regarding the new Labor Certification Registry (LCR). The committee provides search tips, and seeks feedback from members on their experiences searching the registry as well as their opinions on privacy concerns.