What You Missed In Immigration: $100K Fees, Fast Lanes & the September 15 Scramble

Trump Administration Considers $100,000 OPT Fee

If $100,000 for an H-1B petition wasn't enough, the administration is now floating the same price tag for Optional Practical Training. OPT, the program that allows international students to work in the U.S. after graduation, could become prohibitively expensive if the proposal moves forward. Nothing has been formally announced yet, and the idea is still under discussion, but the signal alone is enough to rattle the pipeline. A six-figure fee for post-graduation work authorization would fundamentally change the calculus for international students choosing where to study and for employers who recruit from American universities.

The PERM Takeaway: OPT is where the PERM pipeline begins for thousands of employers. It's the bridge between graduation and H-1B sponsorship, and for many workers, it's their first step toward labor certification and a green card. If OPT becomes a $100,000 proposition, fewer students will use it. Fewer will stay in the U.S. after graduation. And the talent pool that employers draw from for PERM sponsorship will shrink dramatically. Even as a proposal, this should trigger workforce planning conversations at every company that recruits international graduates. If your future PERM candidates can't afford to start working in the U.S. in the first place, the rest of the sponsorship pathway becomes irrelevant. Employers who want to protect their pipeline should be identifying high-value candidates earlier and exploring whether sponsorship commitments can be made before graduation, not after OPT pricing prices them out.

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Court Keeps $100,000 H-1B Fee on Hold

The First Circuit denied the government's request to temporarily reinstate the $100,000 H-1B filing fee while the appeal moves forward, keeping the fee blocked for now. The ruling leaves a lower court decision in place that struck down the fee, which would have applied to certain H-1B petitions involving workers outside the United States. The litigation isn't over. The government can continue its appeal or seek emergency relief from the Supreme Court. But for the moment, employers filing H-1B petitions are not required to pay the six-figure surcharge.

The PERM Takeaway: Good news, but temporary good news. The $100,000 fee is blocked today, not dead. Employers should take advantage of the current cost structure while it lasts, but plan as though the fee could return at any time. For companies weighing whether to file H-1B petitions or accelerate PERM cases instead, the math still favors long-term thinking. A green card through PERM eliminates the need for future H-1B renewals entirely, and if the $100,000 fee is eventually reinstated, every renewal becomes a six-figure expense. The cost case for PERM sponsorship as a permanent solution has never been stronger, even with the fee temporarily off the table.

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Universities Tell International Students: Get Back Before September 15

Universities across the country are urging international students to return to the U.S. before September 15, when the new DHS rule replacing "duration of status" with a four-year fixed admission period takes effect. Students who arrive before the deadline may avoid some of the uncertainty that comes with being processed under the new system. Those who need more than four years to complete their programs will need to apply for extensions through USCIS before their authorized stay expires. Schools are treating September 15 as a hard line and advising students to plan accordingly.

The PERM Takeaway: September 15 is six weeks away, and the ripple effects will be felt in hiring pipelines for years. Employers who recruit from university programs should be coordinating with campus career offices and international student advisors now, not next semester. Students who don't make it back before the cutoff, or who get tangled in extension paperwork mid-program, may become harder to hire on OPT and ultimately harder to sponsor through PERM. The employers who maintain strong university relationships and early engagement with potential hires will be the ones who still have access to this talent pool once the new rules take hold. Everyone else will be scrambling.

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State Department Launches Pay-to-Play Visa Interview Pilot in Mexico

The State Department rolled out a pilot program allowing some B-1/B-2 visitor visa applicants in Mexico to pay an extra $750 for an expedited interview appointment within 10 business days. The program launched July 21 and runs through December 31, 2026, with possible expansion to other locations. Applicants still need to pay the standard $185 application fee and schedule a regular interview first. The $750 buys a faster appointment, not a faster decision, and doesn't guarantee approval.

The PERM Takeaway: This pilot doesn't directly touch employment-based visas, but it's worth watching for two reasons. First, it signals that the State Department is willing to monetize speed, and that model could eventually expand to other visa categories, including immigrant visa interviews for PERM-sponsored workers. Second, any program that shifts consular resources toward paid expedited appointments could slow down the regular appointment queue, potentially affecting wait times for employment-based interviews at the same posts. Employers with sponsored workers awaiting consular processing in Mexico should monitor whether this pilot affects regular scheduling availability. And more broadly, the precedent of paying for faster government service is one the immigration system may be heading toward across the board.

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Stay sharp, stay compliant, and we'll see you next week.