Below is the first of 2 comments that we are submitting to U.S.C.I.S. on the new H-1B proposed regulation. Hopefully it will be of interest to the readers.
December 31, 2018
Samantha Deshommes, Chief,
Regulatory Coordination Division
Office of Policy and Strategy
U. S. Citizenship and Immigration Services
Department Of Homeland Security
20 Massachusetts Ave. Nw.,
Washington, DC 20529
Re: DHS Docket number USCIS-2008-0014 – Comment on Flipping Selection Process of
Regular and U. S. Masters or Higher Graduates
Dear Ms. Deshommes,
The proposed revision to the H-1B rules attempts to change the present selection process by flipping the order of random selection to favor those with U. S. Masters degrees or higher. This is highly unwise as it is not merely a question of Bachelors versus Masters degree, but the potential exclusion of many with bachelor’s degrees who have years of experience that those with U. S. masters degrees do not have. Many with bachelor’s degrees from other countries have acquired overseas skills over the years in the STEM fields which are heavily in demand in the U. S. and other countries.
The proposed change in regulation mainly applies to those who have just acquired U. S. Masters degrees, many of whom have no other relevant experience than internships or externships. While they are desirable for the advanced knowledge that they have acquired, those with bachelor’s degrees and years of working in a particular field are oftimes more essential to petitioning organizations as they do not have as much of a learning curve as U. S. Masters graduates with little or no real life experience.
As such, U.S.C.I.S. should keep the random selection process as it now is.
Thank you for your courtesy and kind consideration.
Very Truly Yours,
Alan Lee, Esq.