The views expressed in this comment are those of the author(s) and do not necessar- ily ref lect the views of The Center for Growth and Opportunity at Utah State University or the views of Utah State University. [...] Smith, Immigration Policy Director, The Center for Growth and Opportunity at Utah State University Introduction The Center for Growth and Opportunity at Utah State University (CGO) welcome the oppor- tunity to respond to the Department of Homeland Security (DHS) and US Citizenship and Immigration Services (USCIS) Notice of Proposed Rulemaking (NPRM), published October 23, 2023, entitled “Modernizi. [...] The changes According to DHS, the updates to the regulations can be divided into the following categories: 1. [...] While the cap refers to the limit of H-1B holders, the gap indicates the period between the two statuses. [...] To meet the goal of USCIS and DHS to modernize and improve the eff iciency of the H-1B program, the changes need to avoid adding restrictive language and overreach and instead allow eff icient and optimal pathways for skilled foreign talent to come to the United States.
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