Wednesday, December 12, 2012

The importance of April 1 and October 1 for H-1B status

You may be aware that the dates October 1 and April 1 have significance for H-1B status. In this post, I will explain why they do.

Each fiscal year, Congress has a limit on the number of petitions that can get H-1B approval. This federal fiscal year runs from October 1 until September 30 of the following year. The “year” designation of a particular fiscal year is the ending, not the beginning year. Therefore, “fiscal year 2013” is that year that begins October 1, 2012 and ends September 30, 2013. If, during a particular fiscal year, the cap is reached, then the government is unable to approve any more H-1B cap-subject petitions, and therefore no cap-subject person will be able to work during that fiscal year. Rather, that person will have to wait until the beginning of the NEXT fiscal year, when a new set of H-1B approvals is available and new cap comes into existence. That next fiscal year begins on October 1.

In addition, the H-1B procedure is such that petitions can specify a requested starting date that is up to six months in the future. Therefore, because the earliest time a person can start work in a new fiscal year is the beginning of that year, October 1, then the earliest time an employer can file a petition is six months prior, that is, April 1. If an employer files any earlier, for example on March 31, the petition could not be approved for an October 1, start, because October 1 is more than six months from March 31. In fact, if the cap is full for the current year, and the government receives a petition in the current fiscal year, because perhaps an attorney or paralegal filed the petition too soon, then that petition will be denied.

Given this information, what should you keep in mind for H-1B?

-          Do not file too early
If the cap is full in the current fiscal year (as is true now), then the government should not receive your petition earlier than April 1. If it does, the government will deny your petition. In that case, your filing fees are gone, i.e. the government will not refund them. Therefore, if you are sending your petition via courier such as Federal Express, send your petition AT MOST the day before, no more. Yes, Federal Express offers a lower rate for its “two day delivery” service, and you might be tempted to save money and send the petition two days prior  to April 1. The problem though, is that Federal Express, even though specified a two day delivery, still nonetheless COULD deliver your package in only one day, if they are able. That is, the “two day” specification is an outer limit, not a minimum waiting time. The best approach, therefore, is to file the day before, and ask for overnight delivery.

-          There is no H-1B filing “deadline”
People often ask me, “Calvin, what is the deadline for filing an H-1B petition?” I respond by saying that there is no “deadline.” That is, the government does not end its acceptance of cap-subject petitions based on a fixed date. Rather, it ends its acceptance of such petitions when the cap “runs out,” that is, when no more cap spaces are available. Therefore, the important thing is to file your completed petition as soon as you possibly can.



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