Biden’s Humanitarian Vision Meets Trump’s Enforcement Priorities: What Employers Need to Know About the CHNV Parole Program

The recent termination of the parole program for Cubans, Haitians, Nicaraguans, and Venezuelans (CHNV) by the Department of Homeland Security (DHS) has significant implications for US employers. As DHS revokes work permits issued under this program, employers must navigate new compliance challenges. In this Legal Update, we provide an overview of the CHNV parole program and its termination, outline the steps employers should take in response to revocations, and offer guidance for managing reverification obligations under federal immigration law.

Overview of the CHNV Parole Program

The CHNV Parole Program—formally known as the Processes for Cubans, Haitians, Nicaraguans, and Venezuelans—is a set of humanitarian parole programs that allowed eligible nationals from these countries to enter and stay in the United States for up to two years. Established by the Biden Administration in January 2023, the CHNV program approved individuals to travel to and work in the United States provided they met certain criteria, including having a sponsor in the United States. By January 2025, approximately 532,000 people had been granted parole through the CHNV program.

Under the Biden Administration, DHS characterized the program as “the safest and most effective way to pursue a temporary stay in the United States” for foreign nationals ineligible for a visa. In June 2025, DHS called the program “disastrous” and stated that it undercut American workers, and resulted in “chaos . . . and crime.”

Termination of the CHNV Program: A Timeline

• January 20, 2025: President Donald Trump issued Executive Order 14165 (“Securing Our Borders”), part of which directed the DHS Secretary to terminate all categorical parole programs that were deemed contrary to the policies established in the President’s Executive Orders, including the CHNV program.
• March 25, 2025: Consistent with this Executive Order, DHS issued a notice declaring the termination of the CHNV program. According to the notice, beneficiaries of the program would have their parole terminated within a month, and those without lawful immigration status would have to leave the country before this termination date. DHS deemed termination of the program appropriate and necessary after finding that it did not provide a significant public benefit, was not needed to reduce illegal immigration, did not sufficiently mitigate the effects of illegal immigration, did not serve its intended purpose, and was inconsistent with the administration’s foreign policy goals.
• April 14, 2025: The United States District Court for the District of Massachusetts issued a preliminary injunction blocking the DHS notice from taking effect.
• May 30, 2025: The U.S. Supreme Court granted the government’s request for a stay on the preliminary injunction, thus permitting DHS to go forward with terminating the CHNV program.
• June 6, 2025: DHS published an update on the Supreme Court decision, stating that individuals affected by the CHNV termination would receive revocation notices in their online myUSCIS accounts.
• June 12, 2025: DHS announced that it had begun sending termination notices to the email addresses provided by parolees. The notices inform parolees of the termination of their parole and work authorization. In the announcement, DHS also “encourages any illegal alien residing in the U.S. to self-deport with the CBP Home Mobile App,” promising travel assistance and a $1000 exit bonus for those who self-deport.
• June 20, 2025: DHS announced that E-Verify has introduced a new Status Change Report designed to help employers identify employees whose work authorization has been revoked. This report replaces the previous Case Status Alerts and includes key details such as the revocation date, E-Verify case number, and alien registration number (A-number).

What This Means for Employers – Key Considerations

• Employers Enrolled in E-Verify: In light of these recent changes, employers with E Verify should regularly log into E-Verify and generate the Status Change Report. For any current employee listed in the report whose parole has been revoked, the employer is required to immediately begin the reverification process using Form I-9, Supplement B. The reverification process should be completed within “a reasonable amount of time” (which may vary depending upon the circumstances) and includes notifying affected employees, collecting updated documents, and completing Section B.
  
  Employees who have another path for work authorization must present unexpired documentation from the List of Acceptable Documents from List A or List C; do not reverify List B (identity) documents. Do not create a new E-Verify for these employees. Employment must end for anyone who cannot provide valid proof of current work authorization.
  
  Notably, the introduction of the Status Change Report presents a shift for employers.

• Many employers do not track or maintain records by E-Verify case number or A numbers, making it challenging to reconcile the Status Change Report data with internal Form I-9 records. This is particularly true for employers with large workforces and multiple locations.
• Additionally, while uncommon, some employees (particularly those with complex immigration histories) may have multiple A- numbers. If a worker’s underlying application is tied to a different A-number than the one used for E-Verify, key updates may not appear.

It is important for organizations to establish a compliance record in the event of an audit or investigation. As a best practice, we recommend employers consider the following:

• Retaining the Status Change Report with the date the employer accessed the data – to document what information the employer relied upon. This is critical if DHS later revises the report (e.g., changes an effective date or reverses a mistaken revocation) by helping the employer demonstrate good-faith compliance and reducing risk exposure.
• Attaching a memorandum to each Form I-9 record briefly explaining the reason for the termination of employment or reverification (e.g., employment authorization was revoked due to the termination of humanitarian parole under CHNV), along with a printout of the relevant E-Verify guidance.

• Employers Not Enrolled in E-Verify: Employers who do not participate in E Verify, or who do not retain copies of employee documents, may find it difficult to identify affected employees. Beyond the notice for employers enrolled in E-Verify, DHS has not yet provided guidance on the termination of the CHNV program. The lack of guidance has created uncertainty for organizations and heightens their risk by leaving it unclear what actions are necessary to maintain compliance with DHS requirements. To mitigate this risk, employers are advised to reach out to counsel for assistance on maintaining detailed and accurate employee records, reviewing existing onboarding and employment verification procedures, and preparing for potential audits or investigations by the government. 
• Alternative Pathways: Some employees authorized to work under the CHNV program may have already secured alternative pathways to maintain their employment eligibility, such as obtaining work authorization on a different basis (e.g., asylum) or becoming lawful permanent residents. These employees should be permitted to present their new documentation during the reverification process.
  
  Employers may wish to coordinate with affected employees to explore alternative pathways such as employer-sponsorship to maintain legal immigration status.

• Impact to Employer Operations: Employers—especially those who employ a large number of foreign national employees from CHNV countries—should anticipate workforce disruptions as affected employees lose work authorization. Handling this disruption may require employers to expend resources on reallocating responsibilities or recruiting replacement employees.

How Mayer Brown Can Help

Mayer Brown is prepared to assist employers in navigating the ongoing changes to the CHNV program by

1.  Providing tailored guidance to employers to ensure compliance with DHS requirements and to update internal employment policies and procedures;
2. Advising on potential legal risks to employers and offering strategies to mitigate exposure;
3. Monitoring policy developments and interpreting DHS guidance to enable employers to respond quickly and effectively to changes;
4. Exploring alternative pathways to lawful immigration status for employees who receive termination notices; and
5. Designing strategies to minimize workforce disruption to employers, such as by assessing hiring alternatives and adjusting recruitment policies.