Today, January 23, 2015, American Immigration Lawyer's Association (AILA) has published its letter to the U.S. DOL Secretary Perez encouraging the Department's position on making changes to its PERM system. Offered on behalf of the entire organization, the letter advocates and provides ideas in promoting predictability and fundamental fairness in the PERM Labor Certification. The letter points out that the DOL should hold true to its own regulations — otherwise, what would be the point of amending them — and hold its officers responsible for acting in accordance with their letter and spirit. The letter further points out the important of proper notice giving to insure fairness. The letter advocates engaging stakeholders regularly thorough the Q&A system. The letter emphasizes the necessity of insuring across the board consistency of the interpretation of PERM regulations by all agency employees to prevent the inconsistency in its decisions for which the DOL is notorious as traced for the period of almost a decade since PERM regulations have been implemented. The letter raises a number of other useful recommendations and advocates openness and cooperation with the stakeholders in the amendment process.
References: AILA Doc. No. 15012342.
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