Restriction on Entry of Certain Nonimmigrant Workers

9/19/2025

Proclamations

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Action Summary

Program Abuse Concerns: Highlights the systemic abuse of the H-1B visa program where American workers are replaced by lower-paid, less-skilled foreign labor, particularly affecting IT, STEM fields, and American wage integrity.
Economic and National Security Impact: Notes that the misuse of the H-1B program undermines the labor market, depresses wages for American workers, and poses a national security threat by discouraging domestic participation in critical science and technology sectors.
New Entry Restrictions: Imposes a restriction on the entry of H-1B nonimmigrant workers unless a payment of $100,000 accompanies their petition. This measure is effective from September 21, 2025, for a period of 12 months.
Compliance and Verification: Requires employers to document the required payment before filing H-1B petitions. The Secretary of State and Homeland Security are tasked with verifying payments and coordinating enforcement to deny entry to non-compliant petitions.
Exemptions for National Interest: Provides exemptions if the Secretary of Homeland Security determines that the hiring of certain aliens is in the national interest and poses no security or welfare threat.
Review and Future Extensions: Mandates a joint review by top officials (Secretary of State, Attorney General, Secretary of Labor, and Secretary of Homeland Security) within 30 days after the next H-1B lottery to advise on extending or renewing the restriction.
Wage Level Adjustments and Prioritization: Instructs the Secretary of Labor to revise prevailing wage levels and the Secretary of Homeland Security to prioritize admission of high-skilled, high-paid workers.
General Provisions: Clarifies that the proclamation does not create enforceable rights against the U.S. government, and it will be implemented in compliance with applicable law and available appropriations.

Risks & Considerations

The restriction on H-1B visas could significantly impact Vanderbilt University’s ability to attract and retain international talent, particularly in STEM fields. This may affect research capabilities and the diversity of academic staff and students.
There is a potential risk of reduced collaboration opportunities with international researchers and institutions, which could hinder the university’s global engagement and innovation efforts.
The increased costs associated with H-1B visa applications may deter departments from hiring international faculty and researchers, potentially leading to a talent gap in critical areas.
Vanderbilt may need to reassess its hiring strategies and explore alternative visa options or focus on domestic talent to mitigate the impact of these restrictions.
The proclamation’s emphasis on prioritizing high-skilled and high-paid aliens could lead to increased competition for top international talent, necessitating adjustments in recruitment and compensation strategies.

Impacted Programs

School of Engineering and College of Arts and Science may face challenges in recruiting international faculty and researchers, impacting their research output and academic offerings.
The Office of International Student and Scholar Services will need to provide additional support and guidance to affected students and staff navigating the new visa restrictions.
Vanderbilt’s Research Centers may experience disruptions in ongoing projects that rely on international expertise, potentially affecting grant funding and project timelines.
The Human Resources Department will need to update its policies and procedures to comply with the new H-1B visa requirements and ensure legal compliance.

Financial Impact

The increased costs associated with H-1B visa applications could lead to higher operational expenses for departments relying on international talent, impacting budget allocations.
Potential delays or disruptions in research projects due to visa restrictions could affect grant funding and financial planning for research initiatives.
Vanderbilt may need to invest in alternative recruitment strategies or domestic talent development programs to offset the impact of reduced international hiring.
The university might face financial implications if it needs to increase compensation packages to remain competitive in attracting high-skilled international talent.

Relevance Score: 4 (The order presents a need for potential major changes or transformations of programs.)

Key Actions

Vanderbilt’s Office of International Student and Scholar Services should prepare for potential impacts on international students and scholars, particularly those in STEM fields, by providing guidance and support for navigating changes in H-1B visa policies. This includes advising on alternative visa options and ensuring compliance with new regulations.
The Career Center should develop strategies to support students in computer science and engineering fields who may face increased competition for jobs due to changes in the H-1B visa program. This could involve enhancing career counseling services, expanding internship opportunities, and fostering partnerships with companies that prioritize hiring American graduates.
Vanderbilt’s Research and Innovation Office should assess the potential impact of H-1B visa restrictions on research collaborations and staffing. By identifying alternative funding sources and exploring partnerships with domestic institutions, the university can mitigate potential disruptions to research projects.
The Department of Political Science should conduct research on the broader implications of H-1B visa restrictions on the U.S. labor market and national security. This research can provide valuable insights for policymakers and contribute to the national conversation on immigration and labor policies.
Vanderbilt’s Human Resources should review and update hiring practices to ensure compliance with new H-1B visa regulations. This includes evaluating the potential financial impact of the $100,000 payment requirement and exploring alternative recruitment strategies to attract top talent.

Opportunities

The executive order presents an opportunity for Vanderbilt’s School of Engineering to strengthen its focus on developing domestic talent in STEM fields. By expanding outreach and recruitment efforts, the school can attract a diverse pool of American students and enhance its reputation as a leader in engineering education.
Vanderbilt can capitalize on the increased focus on hiring American workers by developing new programs and partnerships with companies that prioritize domestic talent. This could include joint research initiatives, student exchange programs, and collaborative curriculum development, enhancing Vanderbilt’s reputation and reach in the technology sector.
The emphasis on supporting American workers offers an opportunity for Vanderbilt’s Center for Technology and Innovation to engage in policy analysis and advocacy. By providing evidence-based recommendations, the center can influence how these policies are implemented and support the development of a competitive American workforce.
By engaging with the broader educational and business community, Vanderbilt can position itself as a leader in the national conversation on immigration and labor policies. Hosting conferences, workshops, and public forums on the implications of H-1B visa restrictions can further establish Vanderbilt as a hub for innovative thought and practice.

Relevance Score: 4 (The order presents the potential for major process changes required for Vanderbilt’s programs due to impacts on international students and research collaborations.)

Average Relevance Score: 3.8

Timeline for Implementation

Effective Date and Expiration: The restriction takes effect at 12:01 a.m. EDT on September 21, 2025, and will expire 12 months later.
Recommendation Submission: No later than 30 days following the completion of the H‑1B lottery immediately after the proclamation, key officials must submit a recommendation on whether to extend or renew the restriction.
B Visa Guidance: Guidance must be issued for H‑1B petitions with an employment start date before October 1, 2026, though no specific deadline is provided.

The shortest timeline mentioned is 30 days following the H‑1B lottery, which places the directive in the 30–59 days compliance window.

Relevance Score: 4

Impacted Government Organizations

Department of Homeland Security: Tasked with enforcing the restriction on entry for H-1B nonimmigrant workers and coordinating with the Department of State to ensure compliance with the new payment requirement.
Department of State: Responsible for issuing guidance on visa petitions, verifying the necessary payment for H-1B petitions, and preventing misuse of B visas in connection with the H-1B program.
Department of Labor: Charged with initiating rulemaking to revise prevailing wage levels to align with the policy goals of this proclamation, thereby influencing labor market practices and wage standards.
Department of Justice (Attorney General): Required to join other key secretaries in submitting a recommendation on whether an extension or renewal of the entry restrictions is in the national interest.

Relevance Score: 2 (This proclamation significantly impacts 3-5 key Federal Agencies tasked with immigration, labor, and national security functions.)

Responsible Officials

Secretary of Homeland Security – Responsible for restricting decisions on H-1B petitions that lack the required $100,000 payment, coordinating with the Department of State to implement the proclamation, and initiating rulemaking to prioritize high-skilled, high-paid aliens.
Secretary of State – Tasked with issuing guidance to prevent misuse of B visas, verifying the receipt of the required payment during the H-1B visa petition process, and working with the Department of Homeland Security to implement the proclamation.
Secretary of Labor – Charged with initiating a rulemaking process to revise prevailing wage levels and contributing to the joint recommendation on whether to extend or renew the entry restrictions.
Attorney General – Required to participate in the joint submission of recommendations regarding the extension or renewal of the entry restrictions.
Assistant to the President and Homeland Security Advisor – Designated as the recipient of the joint recommendations submitted by the Secretary of State, Attorney General, Secretary of Labor, and Secretary of Homeland Security.

Relevance Score: 5 (Directives impact Cabinet-level officials and high-level decision-makers with broad policy and national security implications.)