Page 145

• Management Directives and policies should realign to ensure that the workforce, while adaptable and able to handle the bulk of the USCIS mission, is not allowed to be pulled off mission work to focus on unlawful programs (DACA, mass parole for Afghans, Ukrainians, Venezuelans, etc.), which divert resources away from nuclear family and employment programs.

The regulatory agenda should include the immediate submission of notices of proposed rulemaking for the Trump Administration’s public charge rule (including aspects from its original notice of proposed rulemaking), temporary work visa reform, employment authorization reform rules, asylum bars rule, and a third-country transit rule. Ata minimum, an enhanced regulatory agenda should include rules strengthening the integrity of the asylum system, parole reform, and U visa reform that prioritizes relief for victims of heinous crimes and ensures that we protect the truest and most deserving victims of crime.

Not all policy changes require formal rulemaking, however, as internal guidance documents are generally exempt under the Administrative Procedure Act (APA).” In this subregulatory space, USCIS policy memos and operational guidance should reduce the validity of employment authorization documents and end the COVID flexibilities, including the reliance on biometrics reuse. USCIS should also enforce existing regulations by rejecting incomplete applications and petitions, ensuring both that they are completed before accepted for filing and that FDNS signs off on all approved applications and petitions before approval notices are sent to the alien or petitioner. Other efforts should be focused on adjudication standards returning to nearly 100 percent interview requirements for all appropriate cases.

The incoming Administration should spearhead an immigration legislative agenda focused on creating a merit-based immigration system that rewards highskilled aliens instead of the current system that favors extended family-based and luck-of-the-draw immigration. To that end, the diversity visa lottery should be repealed, chain migration should be ended while focusing on the nuclear family, and the existing employment visa program should be replaced with a system to award visas only to the “best and brightest.”

Internal efforts to limit employment authorization should be matched by congressional action to narrow statutory eligibility to work in the United States and mitigate unfair employment competition for U.S. citizens. The oft-abused H-1B program should be transformed into an elite program through which employers are vying to bring in only the top foreign workers at the highest wages so as not to depress American opportunities. Additionally, Congress should:

• Improve the integrity of the temporary work visa programs;

• Repeal Temporary Protected Status (TPS) designations;