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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FR Regulations & Notices

DOL Ratification of H-2A Rule on Range Herding and Production of Livestock

DOL published notification of the Assistant Secretary for Employment and Training's ratification of the rule published 10/16/15 titled “Temporary Agricultural Employment of H-2A Foreign Workers in the Herding or Production of Livestock on the Range in the United States.” (90 FR 3626, 1/15/25)

1/15/25 AILA Doc. No. 25011507. Business Immigration, H-2A Agricultural Worker
Agency Memos & Announcements

USCIS Issues Reminder on New H-1B Final Rule, H-2 Final Rule, and Revised Form I-129

USCIS reminds stakeholders that DHS's H-1B final rule and H-2 final rule take effect on 1/17/25. USCIS will also publish a revised Form I-129, Petition for a Nonimmigrant Worker (edition date 01/17/25) on 1/17/25. The 01/17/25 edition of Form I-129 goes into effect on 1/17/25 with no grace period.

FR Regulations & Notices

DOL Ratification of H-2A Final Rule

DOL published a notification of the Assistant Secretary for Employment and Training’s and the Administrator of the Wage and Hour Division’s ratification of the rule published 10/12/22 titled Temporary Agricultural Employment of H–2A Nonimmigrants in the United States. (90 FR 2610, 1/13/25)

1/13/25 AILA Doc. No. 25011506. Business Immigration, H-2A Agricultural Worker
Practice Resources

Practice Alert: H-2 Related Changes to the Revised Form I-129

The H-2 Subcommittee of AILA’s DOL Liaison Committee provides the following Practice Alert regarding the new H-2 related questions added to the revised Form I-129, Petition for a Nonimmigrant Worker, effective 1/17/25.

1/9/25 AILA Doc. No. 25011000. H-2A Agricultural Worker, H-2B Temporary Worker
Practice Resources

Practice Pointer: DOL OFLC Provides Updates at PLI Conference

OFLC representatives attended the Practicing Law Institute immigration law conference on December 4, 2024. AILA's DOL Liaison Committee also participated in the conference and provided OFLC's answers to questions raised during it.

Practice Resources

Practice Alert: Key Takeaways from the H-2 Modernization Final Rule

The AILA DOL Liaison H-2B subcommittee offers key takeaways from the H-2 Modernization Final Rule.

Agency Memos & Announcements

USCIS to Release Revised Form I-129

USCIS will release a revised Form I-129, Petition for a Nonimmigrant Worker, on 1/17/25, aligning with the H-1B and H-2 modernization rules. The new form will replace the 4/01/24 edition, which will be rejected after 1/17/25. No grace period is provided.

Agency Memos & Announcements

DOL Announces Additional Guidance Based on Court Orders on the 2024 Farmworker Protection Final Rule

DOL provided additional guidance after litigation in Barton v. DOL prevented DOL from implementing certain provisions of the Farmworker Protection Rule in certain states.

FR Regulations & Notices

DHS Final Rule on Modernizing the H-1B Program

DHS final rule amending its regulations to modernize the H-1B requirements, provide flexibility in the F-1 program, and program improvements affecting other nonimmigrant workers. Rule is effective 1/17/25. (89 FR 103054, 12/18/24)

FR Regulations & Notices

DHS Final Rule on Modernizing the H-2 Programs

DHS final rule amending its regulations affecting the H-2A and H-2B programs and their employees. Rule is effective 1/17/25. (89 FR 103202, 12/18/24)

12/18/24 AILA Doc. No. 24121702. H-2A Agricultural Worker, H-2B Temporary Worker
Practice Resources

Practice Alert: Barton v. DOL Injunction and its Impact on H-2As

The H-2 Subcommittee of AILA’s DOL Liaison Committee provides a practice alert regarding the filing of Forms ETA790A and ETA9142A in light of the November 25, 2024, preliminary injunction in Barton, et al. v. U.S. Department of Labor, et al.

12/18/24 AILA Doc. No. 24121832. Business Immigration, H-2A Agricultural Worker
Practice Resources

Practice Alert: H-2 Modernization Final Rule Published December 18, 2024

AILA’s DOL Liaison Committee provided a practice alert summarizing the key takeaways from the H-2 Modernization Final Rule published on December 18, 2024.

AILA Public Statements, Press Releases

Commonsense Workforce-Focused Changes as Biden Administration Wraps Up

AILA highlights three recent Biden Administration workforce-focused rules, noting they “will bolster the integrity of these programs and help both employers and employees navigate what can often be an uncertain amalgam of immigration laws and policies.”

Practice Resources

Practice Alert: H-1B Modernization Final Rule to be Published on December 18, 2024

AILA's USCIS Benefits Policy Committee provides a Practice Alert on the Publication of the H-1B Modernization Final Rule.

FR Regulations & Notices

DOL Notice of 2025 Adverse Effect Wage Rate for Range Occupations

DOL notice of the adverse effect wage rate for workers engaged in the herding or production of livestock on the range, effective 1/1/25. (89 FR 101630, 12/16/24)

12/16/24 AILA Doc. No. 24121601. Business Immigration, H-2A Agricultural Worker
FR Regulations & Notices

DOL Notice of 2025 Adverse Effect Wage Rate for Non-Range Occupations

DOL notice of the adverse effect wage rate for workers engaged in the employment of temporary or seasonal nonimmigrant workers (H–2A workers) to perform agricultural labor or services other than the herding or production of livestock on the range, effective 12/16/24. (89 FR 101628, 12/16/24)

12/16/24 AILA Doc. No. 24121602. Business Immigration, H-2A Agricultural Worker
FR Regulations & Notices

USCIS 30-Day Request for Comments on H-2 Forms

USCIS 30-day notice with request for comments on Form I-129N, H–2 Petitioner’s Employment-Related or Fee-Related Notification. Comments are due by 1/8/25. (89 FR 97647, 12/9/24)

Agency Memos & Announcements

DOL and EEOC Announce Webinar for H-2A and H-2B Filers on Anti-Discrimination Compliance

The U.S. Department of Labor, in partnership with the EEOC, will host a webinar on 12/9/24, for H-2A and H-2B filers to discuss their responsibilities under anti-discrimination laws. The session will cover federal compliance, unlawful practices, and enforcement procedures.

11/27/24 AILA Doc. No. 25112700. H-2A Agricultural Worker, H-2B Temporary Worker
Federal Court Cases

District Court Enjoins DOL from Implementing Certain Parts of New Final Rule on H-2A Program

The district court enjoined and restrained DOL from implementing, enacting, or enforcing certain parts of its 4/29/24 final rule that made numerous changes to the H-2A program. The injunction is effective in Kentucky, Alabama, Ohio, and West Virginia. (Barton, et al. v. DOL, et al., 11/25/24)

11/25/24 AILA Doc. No. 24120234. Business Immigration, H-2A Agricultural Worker
Practice Resources, Featured Issues

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

AILA’s DOL Liaison provides a resource page with links to legal authorities, agency guidance and publications, and AILA resources and publications helpful for H-2A practice.

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

DHS Notice Identifying Eligible Countries for the H-2A and H-2B Programs

DHS notice identifying foreign countries whose nationals are eligible to participate in the H-2A and H-2B nonimmigrant worker programs. Notice is effective from 11/7/24 to 11/8/25. (89 FR 88799, 11/8/24)

Practice Resources

Practice Pointer: Demystifying VIBE

AILA’s HIAA and DOL Liaison Committees provide a resource concerning the VIBE program utilized by USCIS and DOL.

Agency Memos & Announcements

OFLC Announces Annual Determination of H-2A Labor Supply States

Pursuant to 20 CFR 655.154(d), the OFLC Administrator announced the annual determination of H-2A labor supply states (LSS). LSS are additional states in which an employer’s job order will be circulated and, if appropriate, where additional recruitment may be required.

10/30/24 AILA Doc. No. 24103008. H-2A Agricultural Worker
Agency Memos & Announcements

OFLC Provides FAQs on Major Disaster Hurricane Milton Impacted Areas

DOL's OFLC provides FAQs after Hurricane Milton. Topics include communication, deadline and timeframe flexibility, impact of worksite relocations on LCAs, PERM Notice of Filings, and more.

FR Regulations & Notices

USCIS 60-Day Notice on H-2 Form I-129N

USCIS 60-day notice of request for comments on Form I-129N, H–2 Petitioner’s Employment-Related or Fee-Related Notification. Comments are due by 12/2/24. (89 FR 80589, 10/3/24)

10/3/24 AILA Doc. No. 24100324. Business Immigration, H-2A Agricultural Worker