This alert covers important updates with regard USCIS policies that have resulted in processing delays of various immigration applications.

USCIS Lifts Adjudication Hold for Physicians and Others

As background, beginning in December 2025, USCIS implemented policies ((PM-602-0192) and (PM-602-0194)) that froze the processing of practically all immigration applications of individuals who were from 39 countries considered to be high-risk under the Trump Administration. This meant that almost all immigration benefits, including H-1B petitions, O-1 petitions, Adjustment of Status green card applications, employment authorization applications, and asylum applications filed by citizens or individuals who were born from one of the identified countries[1] were indefinitely paused. With no updates and no timeline for adjudication, many applicants lost their permission to work and/or ability to maintain their lawful status in the United States.

As a result, these holds resulted in physicians, including those in training programs and early career physicians, being forced to stop all patient care activities, often after years of lawful presence. The impact of this USCIS policy was significant considering that 23% of licensed physicians in the U.S. are foreign-trained and 64% of foreign-trained physicians practice in underserved areas or those with shortages of health professionals. 

In response from pressure and lobbying from many medical associations and hospitals, U.S. Citizenship and Immigration Services (USCIS) recently revised its March 30 “Update on USCIS’ Strengthened Screening and Vetting” notice to indicate that physicians are no longer subject to the USCIS adjudicative processing holds. 

With the update on physicians, USCIS also announced that processing holds have also been lifted for the following types of applicants:

• Individuals vetted through Operation PARRIS;
• Certain petitions filed by U.S. citizens;
• Intercountry adoption forms;
• Some rescheduled oath ceremonies;
• Certain Special Immigrant Visa petitions;
• Some EAD applications;
• Asylum applications from non‑high‑risk countries;
• While USCIS’s policy shift to exclude physicians and other applicant types from the adjudicative hold is a welcome change, it is still unclear how USCIS will prioritize, expedite, and resume the processing of impacted applications. USCIS stated that they “continue to review all application types and lift holds for both individual and group cases as appropriate.”

Federal Courts are challenging USCIS’ Authority to Freeze the Processing of Green Card and Work Authorization Applications citing Irreparable Harm

Over the last few weeks, federal courts in Maryland and Massachusetts have issued decisions challenging USCIS’s authority to freeze the processing of immigration applications indefinitely. On April 30, 2026, a federal court in the District of Massachusetts granted a preliminary injunction in Akmurat v. Trump, finding that USCIS's adjudication hold of adjustment of status applications and work authorization applications for close to 200 plaintiffs is likely unlawful. Similarly, on April 24, 2026, the United States District Court for the District of Maryland partially granted a preliminary injunction which enjoins USCIS from pausing the processing of adjustment of status applications (Form I-485) of the 83 plaintiffs involved in the Saghafi v. Edlow lawsuit. In both decisions, the Courts reason similarly that USCIS policies are arbitrary and capricious, are contrary to law and that plaintiffs would suffer irreparable harm. While these decisions are limited to protecting and helping the specific plaintiffs involved in each lawsuit, these decisions signal that more litigation is possible and that USCIS policies could be challenged further.

Re-Vetting of Biometrics and Possible Delays

All applicants may now also see additional delays as a result of upgraded FBI security check processes. USCIS has paused adjudication of cases for which biometrics were collected prior to April 27, 2026. This applies to all cases—not just those where applicants are nationals of one of the “travel ban” countries. During the pause, previously collected fingerprints will be resubmitted for further vetting under the upgraded process. This will affect applicants with pending applications that involve background checks utilizing biometrics. Primarily, this includes:

• Adjustment of Status (green card) applications
• Naturalization applications
• Asylum applications

It is not expected that applicants will need to attend new biometrics appointments. Additionally, USCIS intends to continue scheduling interviews tied to these benefit requests, and existing interviews will be conducted as scheduled. However, cases will not be adjudicated until the new security check process is completed. USCIS suggests that case delays will be brief, but applicants should anticipate delays given the potentially vast number of impacted cases.

What This Means

While USCIS has carved out limited exceptions to the processing hold, most foreign nationals from countries identified in the “travel bans” should continue to expect delays in the adjudication. While further legal challenges are likely, the current injunctions do not benefit applicants who were not party to those lawsuits. Further, the additional vetting for applicants with biometrics submitted before April 27, 2026 will likely cause delays for all foreign nationals, regardless of home country, and may exacerbate the indefinite delays already faced by those under the country-based adjudication hold. Employers should be aware of these challenges and should proactively identify individuals who may be impacted, keeping an eye on upcoming document expiration dates.

We will continue to monitor the situation closely and employers should consult their Pryor Cashman attorney with any questions or concerns about the latest available information.