Thank you for the opportunity to provide comments on the Department of Homeland Security's (DHS) proposed rule to eliminate the discretionary 60-day grace period for certain employment-based nonimmigrants and their dependents. The Colorado Health Foundation (“CHF” or “the Foundation”) is a statewide, nonprofit and nonpartisan philanthropic organization with a mission to improve the health and well-being of Coloradans. Through community engagement, research, grantmaking, and private sector investments, the Foundation works to ensure that everyone in Colorado has what they need to be healthy.
The Foundation recognizes DHS's responsibility to administer employment-based immigration programs and ensure compliance with applicable immigration law. However, we are concerned that eliminating the existing grace period would create unnecessary instability for workers and families, disrupt employers' ability to retain qualified professionals, and potentially exacerbate health care workforce shortages in Colorado and across the country. The current regulation provides a limited period for eligible workers whose employment ends to secure new sponsorship, pursue another lawful immigration option, or prepare to depart the United States.