Alej andro N. Mayorkas, Director
Denise A.Venison. Polic}' and Strategy
Roxana Bacon, Office of the Chief Counsel
Debra A . Rogers. Field Operations
Donald Neufeld, Service Center Operations
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SUBJECT: Administrat ivc Alternatives to Comprehensive Immigrat ion Reform
This memorandum offers administrative relief opt ions to promote family un ity. fOSler economic
growth, ach ieve sign i (jcant process improvements and reduce the threat of remova l for certain
individuals present in the Un ited Slates without authorization. It includes recommendations
regarding implementation timeframes and required resources.
In the absence of Comprehensive immigration Reform, USCIS can extend benefits and/or
protections to many individuals and groups by issuing new gu idance and regulations, exercising
discretion with regard to parole-in-place. deferred action and the issuance of Notices to Appear
(NTA), and adopting signifICant process improvements.
To promote family unity, USCIS could reinterpret lwO 1990 General Counsel Opinions
regarding the ability of Temporary Protected Status (TPS) applicants who entered the Uni ted
Slates (U.S.) without inspection to adjust or change status. Th is would enable thousands of
individuals ill TPS status to become lawfu l permanent residents. Simi larly. where non· TPS
applicants have been deemed inadmissible under section 212(a)(6)(AXi) of the Immigration and
Nationality Act ("the Act") for having enlered without inspection, USCIS could grant "parole· in·
place" (PIP) in the exercise of discretion to create II basis for adjustment in the lj.S.
DRAFr -- Immigration Administrative Relief Options
To fosler economic growth. USC/S could work more aggressively with the Department