The U.S. Department of Homeland Security (DHS) has announced the termination of the Cuban, Haitian, Nicaraguan, and Venezuelan (CHNV) parole programs, which were introduced under the Biden administration. These programs, designed to provide temporary work authorization for nationals from these countries, will officially end 30 days after the notice is published in the Federal Register. For many workers, this will mark the conclusion of their legal status in the U.S. unless individual circumstances dictate otherwise.
Key Points About the End of the CHNV Programs
- Termination Date: The termination of these parole programs will take effect 30 days after the publication of the notice in the Federal Register, which is expected to occur on March 25, 2025. This means the programs will end on April 24, 2025.
- Possible Early Enforcement: DHS warns that CHNV nationals may be subject to enforcement actions before the official termination date.
- Employer Responsibilities: Employers are not required to proactively check or terminate the employment of CHNV employees. However, employers may be notified that the work authorization of certain employees could be revoked sooner than expected.
Detailed Overview of Program Termination
The CHNV parole programs, which provided temporary relief to nationals from Cuba, Haiti, Nicaragua, and Venezuela, are being ended by DHS in accordance with Executive Order 14165. This executive order, issued during the Trump administration, calls for the termination of parole programs that conflict with U.S. immigration policies.
With the termination notice published, the following will occur:
- Impact on Parolees: The parole status of individuals currently benefiting from the CHNV programs will expire 30 days after the publication date unless they are granted an individual extension or exemption. This means that all individuals who are in the U.S. under these programs must leave before April 24, 2025, unless they have a valid legal reason to stay.
- End of Employment Authorization: Parole-based work authorization will automatically end when:
- The expiration date on the work authorization document is reached.
- Removal proceedings are initiated.
- The individual is granted voluntary departure.
DHS will begin revoking work authorization following the termination of the parole status. This will occur in accordance with 8 C.F.R. ยง 274a.14(b), which governs employment authorization based on parole status. DHS has clarified that work authorization will end on April 24, 2025, but the revocation process may occur earlier based on specific circumstances.
What Employers Need to Know
While DHS does not mandate that employers proactively terminate the employment of CHNV nationals, employers should be aware that some workers may experience changes to their work authorization status before the official termination date. Parole-based work authorization will expire automatically under the conditions described above, but because DHS does not require employers to check the status of their employees, it is unlikely that employers will be held responsible for terminating workers ahead of the 30-day deadline.
Employers should expect to receive communication from affected workers who may inform them that their employment authorization is no longer valid. It is also important for employers to stay informed about any further guidance or clarifications from DHS.
Next Steps and Updates
We will continue to monitor developments related to the termination of the CHNV parole programs and provide updates as new information becomes available. Employers should stay proactive by ensuring they understand the implications for their workforce and remain compliant with any changes to immigration enforcement or work authorization policies.
If you have questions about how the termination of the CHNV programs may impact your business or your employees, our team is available to provide legal guidance and assist with any necessary adjustments to your employment practices.