U.S. Catholic Bishops Join Groups in Calling Government to Rescind New DHS Rule Change for Migrant Workers

 The Catholic Legal Immigration Network, Inc. (CLINIC), the United States Conference of Catholic Bishops (USCCB), and Catholic Charities USA (CCUSA) submitted a joint comment regarding U.S. Citizenship and Immigration Services’ (USCIS) Interim Final Rule (IFR) entitled “Removal of theAutomatic Extension of Employment Authorization Documents,” published October 30, 2025.1 

The Department of Homeland Security has announced an interim final rule ending the practice of automatically extending employment authorization documents for aliens filing renewal applications in certain employment authorization categories. With this rule, DHS prioritizes the proper screening and vetting of aliens before extending the validity of their employment authorizations.

Aliens who file to renew their EAD on or after Oct. 30, 2025, will no longer receive an automatic extension of their EAD.

The joint statement by the USCCB continued: Since 1988, CLINIC has supported nonprofit immigration legal services programs through training, technical assistance, publications, and advocacy. CLINIC’s network, originally comprised of 17 programs, has now increased to over 400 diocesan and community-based programs in 48 states and the District of Columbia. CLINIC is the largest nationwide network of nonprofit immigration programs. Our Affiliates assist hundreds of thousands of low-income immigrants annually, including asylum seekers, temporary protected status (TPS) holders, Violence Against Women Act (VAWA) self-petitioners, parolees, survivors of trafficking and crime, and other vulnerable groups—many of whom rely on work authorization not merely as a convenience but as an essential lifeline. For these communities, work authorization is the foundation for housing stability, family unity, access to healthcare, food security, and the ability to participate fully in their communities.
The USCCB is a nonprofit corporation whose members are the active Catholic bishops of the United States, representing nearly 200 autonomous dioceses in all 50 states and the U.S. Virgin Islands. For almost sixty years, the USCCB’s Department of Migration and Refugee Services has advanced the Church’s concern for the life and dignity of immigrants, refugees, victims of trafficking, and others on the move through direct-service programs, advocacy, and outreach. This work is guided by the USCCB’s Committee on Migration and supported by the USCCB’s Subcommittee on Pastoral Care of Migrants, Refugees and Travelers, which promotes pastoral outreach to immigrants throughout the country.

Our organizations strongly oppose the Interim Final Rule’s eliminating automatic extensions of employment authorization. Although we support USCIS’s interest in maintaining an effective employmentauthorization system, the IFR fails to account for the profound and immediate harm it will cause to individuals who have complied with all legal requirements. By removing the only safeguard against adjudication delays, the rule guarantees job loss for eligible workers and destabilizes families who rely on steady income for basic needs. We urge USCIS to withdraw the IFR and to preserve a framework that ensures continuity of work authorization for those who remain fully eligible to work while their renewals are pending.  

CCUSA is the voluntary, national membership organization for Catholic Charities agencies throughout the United States. Each agency is a separate legal entity under the auspices of its bishop. CCUSA’s 168 member agencies operate in over 4,000 service sites across 50 states, Washington D.C., and five U.S. territories. Rooted in the Gospel (Matthew 25), Catholic Charities has, for over a century, provided assistance to all people, regardless of background or religious affiliation, in their time of need. The agencies help provide food, utilities assistance, trauma-informed case management, housing assistance, and other support to people who are experiencing difficulty meeting their basic needs. Last year, Catholic Charities served 16 million people nationwide. Additionally, in collaboration with government agencies at all levels, Catholic Charities provides assistance to immigrants and refugees in their integration process. Catholic social teaching emphasizes welcoming and accompanying the newcomer and caring for persons in poverty as an expression of Christ’s love for all. The Church teaches that these obligations flow from the inalienable, God-given dignity of each human person and that the common good is promoted when society upholds this dignity.

The groups concluded by saying, given our organizations’ ministries to immigrants and refugees around the country, we are deeply concerned that the changes in the IFR will disproportionately harm immigrants and their families. The IFR will guarantee widespread employment-authorization gaps; destabilize fragile households; generate severe backlogs and administrative burdens for affiliates; impede the functioning of state agencies, such as Departments of Motor Vehicles; and impose substantial costs on U.S. employers and local economies. Most importantly, the IFR will produce these harms without any demonstrated countervailing benefit. Additionally, the IFR is arbitrary and capricious. USCIS does not explain its departure from its prior policy positions; it ignores or misstates the processes the IFR affects; and the IFR does not adequately address the reliance interests of stakeholders. Furthermore, USCIS fails to establish that good cause exists for the issuance of a post-implementation comment period. Lastly, the IFR, as proposed, conflicts with fundamental humanitarian and economic principles embodied in U.S. immigration law. For these reasons, further explained below, our organizations respectfully request USCIS to rescind the IFR in its entirety.
I. The IFR’s Regulatory Changes and Their Consequences for Our Organizations and