Letter to USCIS: Registration Requirement for Petitioners Seeking to File H-1B Petitions on Behalf of Cap-Subject Aliens
The Office of Advocacy submits the following comments to the U.S. Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS) regarding its proposed rule which creates an early registration process for the H-1B visa lottery for petitions subject to numerical limitations. This proposed rule would also change the order of the H-1B visa lottery to increase the number of beneficiaries with a master’s or higher degree from a U.S. institution of higher education. Advocacy appreciates USCIS’ efforts to reform the H-1B visa lottery process. Advocacy recommends that USCIS postpone the implementation of the registration program until after this H-1B application season and extend the comment period so that the agency can get more public feedback, further evaluate the impact of this rule on small businesses, and adequately test this electronic system.