Doug Rand Profile picture
Personal account. @FundMobility Co-Director. Previously @USCIS senior advisor, @WHOSTP assistant director, @chooseboundless & @playscripts co-founder

Oct 17, 2018, 14 tweets

Winter is coming...preceded by the Fall 2018 Unified Regulatory Agenda from @DHSgov. Once again, semi-annually, it's time to see what new #immigration actions we might find buried in this list of rulemaking plans that's hiding in plain sight? 1/ reginfo.gov/public/do/eAge…

Let's start with @DHSgov proposals that didn't appear in the prior regulatory agenda this past spring. (These are all draft rules that haven't been published yet, and won't take effect for months or years, after a full public notice-and-comment process.) 2/

Two new actions affecting #asylum-seekers, tightening "credible fear" determinations and eligibility for work permits, both in the name of deterrence... 3/
reginfo.gov/public/do/eAge…
reginfo.gov/public/do/eAge…

Working with @USDOL to modernize #H2B recruitment requirements, "including proposing to eliminate print newspaper advertisements." (At first glance, that last part sounds long overdue.) 4/
reginfo.gov/public/do/eAge…

For #GreenCard applicants applying within the US ("adjustment of status"), @DHSgov wants to "reduce processing times...promote efficient usage of available immigrant visas, and discourage fraudulent or frivolous filings." Sounds great! But wait... 5/
reginfo.gov/public/do/eAge…

...@DHSgov also wants "to eliminate the concurrent filing of visa petitions and Form I-485 for all applicants seeking an immigrant visa in a preference category." That sounds quite bad, likely adding many months to the #GreenCard process. Background: 6/
boundless.com/immigration-re…

Here's another big one, for international students (F-1 & similar visas): changing the period of authorized stay from open-ended to a specific deadline. The stated goal is to reduce visa "overstays," but this change could further deter int'l students. 7/
reginfo.gov/public/do/eAge…

Plus tightening up @ICEgov monitoring of schools that enroll international students. 8/
reginfo.gov/public/do/eAge…

And a new proposal "to improve the efficiency of @USCIS processing of Medical Certification for Disability Exceptions (Form N-648) by improving customer service and responding to concerns of possible fraud and abuse." Good gov't or making things harder? 9/
reginfo.gov/public/do/eAge…

Plus a call for fresh ideas about the scandal-plagued #EB5 investor visa program, to "increase monitoring and oversight...as well as encourage investment in rural areas." Not a bad idea on its face. 10/
reginfo.gov/public/do/eAge…

Finally, there are a bunch of new @DHSgov technical privacy provisions I won't get into here, plus implementation of a recent act of Congress affecting the Northern Mariana Islands' special visa provisions. 11/
reginfo.gov/public/do/eAge…

All of the above is just the never-before-seen stuff that came out in the new regulatory agenda. There is a whole raft of previously announced @DHSgov regs still in the pipeline. For a summary, see this springtime tweetstorm: 12/

And it's still true this administration continues to find ways to dramatically change the legal #immigration system *without* issuing regulations (which take a long time to finalize). For example, @USCIS policy memos and increasing backlogs overall. 13/13
boundless.com/blog/insider-a…

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