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Question:

I am operating under the following assumption: I am planning to file some RIR cases pre-PERM implementation, with the expectation that they will get reviewed and processed under RIR standards. I am also assuming that if RIR processing is denied to those cases, they will still be processed through standard/supervised recruitment with opportunity to amend the job description before supervised recruitment opens. That has been the practice in Texas ever since the GAL 2-02 (I think) in which procedures were outlined for RIR processing and subsequent transfer to supervised recruitment in cases of RIR denial.

Does the panel believe that procedures now in place for RIR cases and RIR denials will hold firm after PERM publication, at least for the cases filed now and/or in the (presumed) 60-day "window" before PERM implementation?

Answer by Christian Allen:

My opinion is that the questioner is absolutely correct. I would be very cautious about the "opportunity to amend the job description before supervised recruitment opens" part, but I think her assumptions are otherwise the same as mine.