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Policy Recommendations

The path forward

These recommendations from the published July 2026 report address immediate harms and structural issues driving instability among highly skilled immigrants affected by the pause.

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1

Ensure genuine, verifiable compliance with the Dorcas vacatur.

  • Issue operational guidance to every field office, service center, and contact center confirming vacated policies may no longer be cited.
  • Retrain contact center staff and publish recurring compliance reports on previously held cases.
2

Expedite EAD adjudications for applicants facing employment disruption.

  • Prioritize applicants whose current authorization has expired or will expire within 90 days.
  • Loss of work authorization is the strongest predictor of financial hardship in the survey evidence.
3

Establish and publish a transparent processing timeline for affected applications.

  • Report reactivated case counts, backlog size, and monthly throughput against published targets.
  • Reduce the compounding psychological cost of open-ended uncertainty.
4

Treat Form I-131 advance parole as a humanitarian adjudication priority.

  • Apply expedite criteria liberally for medical emergencies, bereavement, and separation from minor children.
  • Do not queue time-sensitive travel documents behind non-urgent filings.
5

Provide targeted relief for OPT and STEM-OPT participants.

  • Retroactively toll grace periods and cap-gap extensions for timely-filed applications affected by the pause.
  • Adjust EAD validity periods so applicants receive the full work authorization period they were entitled to.
6

Automatically refund premium processing fees that did not deliver promised adjudication.

  • Identify every premium request affected by the pause and issue refunds without requiring separate requests.
  • Move affected premium cases to the front of the post-vacatur queue.
7

Protect job recovery by excluding pause-related delay from unemployment-day limits.

  • Issue guidance excluding agency-caused adjudication delay from OPT and STEM-OPT unemployment counts.
  • Support rapid re-hiring for workers whose employment was interrupted solely by the processing freeze.
8

Establish congressional oversight of future categorical adjudication pauses.

  • Require public justification and review before broad holds on adjudications take effect.
  • Prevent retrospective litigation from being the only mechanism to unwind harmful administrative freezes.