Compliance Management

The Congressional Review Act

Under the Congressional Review Act (CRA), Congress can review and overturn certain regulations promulgated by an executive agency, such as the Department of Homeland Security, the Department of Labor, the Department of State, etc. Congress can use the CRA only to invalidate an agency final rule in
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OFLC Stakeholder Engagements

Links to summaries and key takeaways from public stakeholder meetings conducted by the Department of Labor Office of Foreign Labor Certification (OFLC), prepared by the NAFSA ISSRP EB subcommittee.
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NAFSA Comment Letter on DHS Proposed OPT Fee Rule

In comments submitted on November 3, 2026, NAFSA strongly opposes the Department of Homeland Security’s (DHS) proposed rule imposing fees of $70,000 for an initial Optional Practical Training (OPT) recommendation and $30,000 for subsequent recommendations, urging DHS to withdraw the proposal. Read
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IssueNet Quarterly Summary - Third Quarter 2026

July, August, September, 2026 Thank you to the membership for reporting the Duration of Status impact this summer as requested by NAFSA. Highlighting the top issues reported through NAFSA IssueNet. Prepared by Helen Leonard of New York University, Brian Groves of the University of California San
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DHS Proposal Would Eliminate I-129 Deference Policy

A proposed rule published in the Federal Register on October 14, 2026 would remove language in the current regulations that instructs USCIS adjudicators to give deference to prior I-129 determinations involving the same parties and the same underlying facts. Form I-129 petitions are used for common
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Elimination of D/S: Special Issues for Community Colleges

On September 10, NAFSA colleagues from community colleges held a collegial conversation to discuss how the elimination of "duration of status" (D/S) is impacting their institutions and offices and how they are adapting their operations to address the changes. The presenters were not able to answer
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DOL Rulemaking on PERM

Modernizing the PERM Program On October 23, 2026, OMB/OIRA concluded its review of a proposed rule package on the PERM permanent labor certification program. DOL had submitted the package to OMB/OIRA for review on September 14, 2026. The next step will be for DOL to publish the proposed rule in the
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