Humanitarian Parole for Cubans, Haitians, Nicaraguans and Venezuelans (CHNV)
What’s the State of Play?
At a Glance
- The Trump administration terminated a humanitarian parole program for beneficiaries from Cuba, Haiti, Nicaragua and Venezuela (CHNV) following the Supreme Court of the United States’s lifting of a preliminary injunction issued by a U.S. district court.
- To assist employers, a new “Status Change Report” was launched for E-Verify-enrolled employers that allows them to identify employment authorization documents (EADs) that have been revoked.
- There is no clear guidance for employers who may have employees who presented and continue to have unexpired EADs, which is causing confusion.
- It is important for employers to refrain from proactively terminating employees whose EADs have yet to be revoked and to refrain from proactively terminating those with revoked CHNV EADs without first giving them the opportunity to present another form of valid work authorization.
On May 30, 2025, the Supreme Court of the United States cleared the way for the Trump administration to terminate a humanitarian parole program for beneficiaries from Cuba, Haiti, Nicaragua and Venezuela (CHNV) by lifting the preliminary injunction issued by the U.S. District Court for the District Court of Massachusetts in response to a lawsuit challenging the initial termination of the CHNV program.
The Department of Homeland Security (DHS) is now proceeding with terminating all parole granted under the CHNV program and revoking related employment authorization documents (EADs) regardless of the existing parole and EAD expiration date. Impacted individuals have already started receiving CHNV status termination and EAD revocation notifications from DHS directly.
What This Means for Employers
For U.S. employers, the CHNV parole terminations mean that they will no longer be able to continue employing individuals who previously provided CHNV parole-related EADs that have since been revoked despite being still valid on their face.
There is no clear guidance for employers who may have employees who presented and continue to have unexpired EADs, which is causing confusion. One way to identify an EAD that may have been issued under the CHNV program is to review the category listed on the card itself, which would be a C11 code. However, the C11 code is not used exclusively for CHNV parolees (for instance, individuals granted parole under other programs may have been issued EADs under that same code), which makes it difficult for employers to determine if an employee is affected by a CHNV EAD revocation.
To assist employers, a new “Status Change Report” was launched for E-Verify-enrolled employers that allows them to identify EADs that have been revoked. As of June 20, 2025, employers who are enrolled in E-Verify need to generate the newly available report regularly to determine which EADs have been revoked and allow them to take the appropriate action, including reverifying employees’ work authorizations on Form I-9. While the report is not available to employers who are not enrolled in E-Verify, non-E-Verify employers may want to consider auditing their I-9s and working with immigration counsel to identify employees whose EADs may have been revoked.
It is important for employers to refrain from proactively terminating employees whose EADs have yet to be revoked and to refrain from proactively terminating those with revoked CHNV EADs without first giving them the opportunity to present another form of valid work authorization.
For More Information
For relevant immigration-related information through 2025, register for Faegre Drinker’s Immigration and Global Mobility practice’s Business Immigration Webinar Series: Compliance & Hiring Strategies for 2025.