AAU update
On October 15, the Association of American Universities (AAU) sent a letter to Secretary of Homeland Security Kristi Noem requesting a blanket national interest waiver of the $100,000 H-1B visa payment for employees sponsored by U.S. institutions of higher education and asking that the proclamation be reconsidered.
The letter is available on the AAU website.
No additional guidance has been issued on how or when the fee may be applied. We will continue to monitor developments and share updates as they become available.
Oct. 16 update
Update for Current Employees (including trainees): Based on the most recent guidance that we have received on the Presidential Proclamation from September 21, 2025, we do not anticipate that employees with existing H-1B status will be subject to the $100,000 payment when filing to extend their status; nor do we anticipate that employees with valid H-1B visa stamps will be subject to the $100,000 payment to re-enter the U.S. if traveling internationally.
Therefore, we do not anticipate that current employees with H-1B status will be affected by the $100,000 payment fee and should be able to continue working without impact. Employees traveling internationally who hold a valid H-1B visa stamp (and who therefore do not need to apply for a new H-1B visa stamp in order to return to the U.S.) should continue to exercise caution and use their own judgement when deciding whether international travel is feasible.
This information is intended to provide you with the most current guidance as we understand it today. However, the law on this issue is vague and rapidly evolving. Please contact FSIS if you have questions or follow up concerns as the situation evolves.
Sept. 26 update
Since our Sept. 20 message, several federal agencies have issued additional guidance and clarifications regarding the recent Presidential Proclamation affecting H-1B visas:
- USCIS memo (9/20/25)
- CBP memo (9/20/25)
- USCIS FAQ (9/21/25)
- DoS FAQ (9/21/25)
- DoS Statement (9/21/25)
Based on this information:
- The proclamation applies only to new H-1B petitions filed after 12:01 a.m. EST on Sunday, Sept. 21, 2025
- It does not apply to:
- Beneficiaries of petitions filed before the effective date
- Beneficiaries of currently approved petitions
- Individuals currently holding valid H-1B visas
- H-1B renewals and amendments for those already in the U.S.
- Current H-1B visa holders may continue to travel to and from the United States
- The $100,000 employer-paid fee applies only to new H-1B petitions and is not an annual payment; cap-exempt universities have not been explicitly excluded
- The proclamation includes a provision for certain exemptions, but details on implementation remain unclear
We are continuing to monitor the situation. Faculty and Staff Immigration Services is reviewing priority cases and managing operational considerations for hiring and sponsorship.
This guidance is based on our understanding of current federal information. The University of Iowa cannot provide legal guidance and individual circumstances may vary. For support, employees may contact:
- Faculty and Staff Immigration Services (FSIS)
- Employee Assistance Program (319-335-2085)
- The Law Clinic at Iowa Law (319-335-9023 or law-legal-clinic@uiowa.edu)
Sept. 20 emails to deans/VPs, senior HR leaders, and current H-1B visa holders
On September 19, 2025, the White House issued a Presidential Proclamation that will restrict the entry of H-1B employees into the United States unless the H-1B petition is accompanied by a $100,000 payment. This proclamation goes into effect at 12:01 a.m. EST on Sunday, September 21, 2025.
There are reports the new rule will not be applied to existing holders of valid visas re-entering the country. We will continue to monitor this rapidly evolving situation and provide updates as additional guidance becomes available. In the meantime, please consider the impact of the new proclamation on your current or future travel plans.
While the university cannot provide legal guidance, we can offer support and share resources, including:
- Faculty and Staff Immigration Services (FSIS)
- Employee Assistance Program (319-335-2085)
- The Law Clinic at Iowa Law (319-335-9023 or law-legal-clinic@uiowa.edu)