Following the termination of the Cuban, Haitian, Nicaraguan, and Venezuelan (CHNV) parole program, the Department of Homeland Security has introduced significant changes to E-Verify procedures that require immediate employer attention. On June 20, 2025, DHS launched the new “Status Change Report” to help employers identify employees whose Employment Authorization Documents (EADs) have been revoked. The new report streamlines and increases obligations of compliance efforts by employers in ensuring proper work authorization of employees.

Background: The End of the CHNV Program

The CHNV parole program, established in January 2023, allowed eligible nationals from Cuba, Haiti, Nicaragua, and Venezuela to enter and work in the United States for up to two years with proper sponsorship. By January 2025, approximately 532,000 individuals had received parole under this program.

However, following the Trump Administration’s Executive Order 14165 in January 2025, DHS terminated the CHNV program. After legal challenges and a Supreme Court decision in May 2025, DHS began sending termination notices directly to affected individuals on June 12, 2025, immediately revoking both their parole status and work authorization.

The New Status Change Report: What Employers Need to Know

The new Status Change Report introduces several key features that enhance the functionality of the prior system of employer notifications. Previously, employers would receive a case status alert notification through the E-Verify system to indicate that there were cases requiring action, particularly for those with potential issues such as expiring or revoked work authorization. Employers would need to log in and search to locate records of the affected individuals.

The new Status Change Report replaces the previous E-Verify Case Status Alerts specifically to enable and obligate companies to take action when there are instances of Employment Authorization Document (EAD) revocations. This report includes essential details such as document revocation dates, E-Verify case numbers, and A-numbers. It is regularly updated as the Department of Homeland Security (DHS) processes additional revocations, ensuring the information remains current. Additionally, the report is available in CSV format, facilitating download and analysis.

E-Verify employers can access the Status Change Report by taking the following steps:

1. Log into your E-Verify account
2. Navigate to the “Reports” tab
3. Select “Status Change Report”
4. Optional: Filter by specific revocation dates
5. Click “Generate Report” and download as CSV

The introduction of the Status Change Report imposes immediate compliance obligations on E-Verify employers, shifting the compliance burden from passive notification to active monitoring. Employers are now required to regularly generate and review the Status Change Report, with frequency recommendations suggesting weekly or bi-weekly monitoring. Upon identifying employees listed in the report, employers must immediately begin the reverification process using Form I-9, Supplement B. This reverification should be completed within a reasonable timeframe, although the Department of Homeland Security (DHS) has not defined this term. Furthermore, employers are obligated to terminate employment for individuals who cannot provide valid alternative work authorization. Importantly, new E-Verify cases should not be created for affected employees during the reverification process.

As part of reverification process best practices, employers should not immediately terminate an employee upon their appearance in the Status Change Report. Instead, they should inquire about alternative work authorization. Although employers may not request specific documents, examples of acceptable alternative documentation may include asylum-based EADs with category C08 or adjustment-based EADs with category C09. Employers should use Form I-9, Supplement B for reverification and accept only List A or List C documents, refraining from reverifying List B identity documents. It is also crucial to document the entire process thoroughly to ensure audit protection.

Challenges for Non-E-Verify Employers

Employers not enrolled in E-Verify may encounter specific challenges due to the limited guidance provided by the Department of Homeland Security (DHS) for identifying affected employees. These employers are advised to rely on employee self-reporting of revocation notices to stay informed about when reverification is required. Additionally, they may choose to review existing documentation for Employment Authorization Documents (EADs) with category C11 from CHNV countries, while keeping in mind that not all C11 EADs were issued under the CHNV parole program. It is also recommended that these employers consider consulting with immigration counsel regarding proactive inquiries to employees.

Data Security and Third-Party Considerations

The Status Change Report contains sensitive personally identifiable information (PII), including alien registration numbers (A-numbers). Employer agents must ensure secure transmission of this data to client companies, in compliance with E-Verify Memorandum of Understanding (MOU) requirements.

Risk Management Recommendations

In terms of documentation strategies, employers should retain the Status Change Report with access dates to establish good-faith compliance, attach memoranda to Form I-9 records explaining termination reasons, and maintain consistent timeframes for reverification across all employees.

While DHS uses permissive language like “allows” and “should,” we anticipate that the Status Change Report will be treated as constructive notice. Employers could potentially face liability for continuing to employ individuals whose revoked EADs appear in the report.

Looking Forward: Alternative Pathways

Some affected employees may have secured alternative work authorization through asylum applications (C08 category EADs), family-based adjustment of status (C09 category EADs), or other employment-based petitions. Employers should coordinate with affected employees to explore employer-sponsored options where appropriate and consider workforce planning for potential disruptions.

To enhance the strategic approach to managing HR processes, several key recommendations have been identified. First, it is crucial that employers enrolled in the E-Verify system establish regular monitoring procedures for the Status Change Report to ensure timely updates and accuracy. Training HR personnel on the new reverification requirements is also essential to maintain compliance and efficiency in handling employee documentation. Additionally, developing consistent documentation practices will bolster audit readiness and streamline operations. For complex cases or policy interpretations, consulting immigration counsel is advised to navigate potential legal challenges effectively. Finally, preparing for potential workforce disruptions in industries with significant CHNV employee populations will help mitigate risks and maintain operational continuity.

Conclusion

The introduction of the Status Change Report represents a significant shift in immigration compliance responsibilities, particularly for employers that utilize E-Verify. These employers must adapt quickly to these new requirements while maintaining consistent, lawful employment verification practices. Given the complexity and evolving nature of these requirements, regular consultation with experienced immigration counsel is strongly recommended.