The Issue

The Department of Homeland Security (DHS) announced on March 25, 2025, that it was terminating the CHNV parole programs for (Cubans, Haitians, Nicaraguans and Venezuelans) and that foreign nationals in the United States under the CHNV parole programs whose parole has not already expired by April 24, 2025, will terminate on that date. CHNV parolees without a legal basis to remain in the United States must depart the United States by the April 24th parole termination date. 

A Deeper Dive

In late 2022 and early 2023, the Biden Administration implemented programs through which citizens or nationals Cuba, Haiti, Nicaragua and Venezuela could request authorization to travel to the United States in order to be considered for parole into the country for a period of up to two years from the date of parole. These programs, collectively known and the CHNV parole programs, reportedly enabled approximately 500,000 individuals to live and work temporarily in the United States.

In the January 20, 2025 Presidential Executive Order entitled, “Securing our Borders,” the Department of Homeland Security was ordered to terminate all categorical parole programs that are “contrary to the policies of the United States,” including the CHNV parole programs. The March 25th announcement implements the Executive Order and terminates parole and employment authorization for all existing CHNV parolees as of the expiration date of their current parole or April 24th whichever is earlier. Those parolees who have obtained another valid immigration status that permits them to remain in the United States are not required to depart the United States. DHS has indicated that it intends to commence removal actions and enforce the departure of those CHNV parolees who remain in the U.S. after the termination of their parole.

What This Means for Employers

Any employee granted employment authorization pursuant to the CHNV Parole programs will lose their employment authorization as of the expiration date of their existing employment authorization card or April 24, 2025, whichever is earlier. The lack of implementation guidance from DHS places employers in a difficult position as employers who continue to employ a CHNV parolee after the expiration of their employment authorization risk being fined by Immigration and Customs Enforcement for knowingly employing/continuing to employ an individual lacking work authorization. At the same time, any employer who requires more or different documentation of work authorization from an employee risks fines for “document abuse” and a potential discrimination investigation if requesting specific documentation of citizenship (i.e. to determine whether the employee is working pursuant to the CHNV parole program). 

We will continue to monitor this issue for further DHS guidance. In the meantime, if you would like to discuss the impact of the termination of the CHNV parole programs on your workforce, please contact your Meltzer Hellrung attorney.