Advocacy
Advocacy
Public comments and independent research on the policies that shape business immigration for exceptional talent.
The Record
Public Comments
Regulatory Comment
Public Comment on USCIS Mandatory Electronic Filing Interim Final Rule (Docket USCIS-2026-0232)
Joint comment of Kevin J. Andrews, Angelo A. Paparelli, and Jonathan Micale, each in an individual capacity, on USCIS's mandatory e-filing interim final rule. The comment does not oppose electronic filing; it identifies a defect that lets USCIS mandate e-filing before the electronic channel can accept filings as they actually have to be made, and recommends fixes. Filed October 12, 2026.
Filed October 12, 2026DHS Docket No. USCIS-2026-0232 · RIN 1615-AD19
Regulatory Comment
Public Comment on DOL Prevailing Wage Proposed Rule (Docket ETA-2026-0001)
Joint comment of Kevin J. Andrews and Angelo A. Paparelli opposing the Department of Labor's proposed prevailing wage methodology for H-1B, H-1B1, E-3, and PERM. Filed May 26, 2026.
Filed May 26, 2026Docket No. ETA-2026-0001 · RIN 1205-AC30