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USCIS Clarifies $100,000 H-1B Fee Scope as Lawsuits Mount and Employers Pivot

The charge now targets new overseas petitions after Sept. 21 under guidance that spares most in-country changes of status.

Overview

  • USCIS says the six-figure fee applies to new H-1B petitions for beneficiaries outside the U.S., including consular, port-of-entry, or preflight inspection cases, with payment due at filing.
  • Extensions, amendments, and changes of status filed inside the U.S. are generally exempt if the worker maintains lawful status and does not depart before adjudication, though travel or a status lapse can trigger the fee.
  • National interest waivers are described as “extraordinarily rare,” must be requested from DHS before filing, and petitions lacking a precleared exception risk denial.
  • New implementation steps require employers to notify existing workers within 90 days of filing and to document efforts to recruit U.S. workers first.
  • Two lawsuits—including a challenge by the U.S. Chamber of Commerce—are pending, as universities, arts institutions, and tech advocates report disrupted hiring and press for narrow exemptions.