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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

The recent termination of the parole program for Cubans, Haitians, Nicaraguans and Venezuelans (CHNV) by the Department of Homeland Security (DHS), and subsequent termination of work authorization for CHNV parolees, has significant implications for U.S. employers. Employers now face urgent new compliance challenges that must be carefully navigated.

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As we previously reported, DHS has terminated parole for individuals under the CHNV program and has revoked their Employment Authorization Documents (EADs).

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On Friday, June 20, 2025, DHS sent an email to all E-Verify employers announcing a new “Status Change Report,” which is a self-service tool within the E-Verify platform.

The Status Change Report allows employers to identify employees whose work authorization has been revoked. This Status Change Report includes revocation dates, case numbers and A-numbers of the affected individuals.

If an individual appears in the Change Status Report, then their work authorization has been revoked. They must present new work authorization documents for reverification to keep working.

DHS has instructed employers to use Form I-9, Supplement B to begin reverifying work authorizations for any current employee listed in the Status Change Report.

Employees who cannot produce new evidence of work authorization must be terminated.

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Key Implications for Employers

According to DHS, the Status Change Report will be updated regularly. DHS believes that making individual revocation data available to employers constitutes constructive notice that affected individuals are no longer authorized to work in the U.S. To avoid employing such persons, employers who use E-Verify should regularly log on to the E-Verify platform and generate the Status Change Report. This will provide employers with certainty as to the revocation of work authorization.

If a current employee is listed in the Status Change Report with their parole and employment authorization revoked, the employer must begin the reverification process using Form I-9, Supplement B. An employee can continue employment if they have an identification document that confirms an alternate path to work authorization (e.g., work authorization via asylum).

Employers may not accept a revoked EAD as valid work authorization, even if it appears to be unexpired. This reverification process must be completed within “a reasonable amount of time.” We recommend no more than a few business days. The employer should not create a new E-Verify case for the individuals affected during the reverification process. If an employee cannot provide valid proof of current work authorization in the reverification process, the employer must end the employment.

The individuals affected by the termination will likely hold EADs with the category C11 notation, but not all individuals with C11 EADs are under the CHNV parole programs. An employee could have a C11 EAD and not have been affected by the CHNV cancellation. Moreover, revocations made on a case-by-case basis or revocations for other groups whose parole has been terminated will appear in the Status Change Report. If there is any question about whether the individual's work authorization has been revoked, employers should consult with immigration counsel.

How to Access “Status Change Report”

Log in to E-Verify and click on the “Reports” tab at the top of the homepage to select the new “Status Change Report.”

After you click “Run Report,” you have the option to choose among a list of revocation dates in the “Revocation Date” field if you wish to narrow the report to specific dates. If you do not select a date, the report will include data for all revocation dates.

When the report generates, you will see a “Report Creation Successful” banner in E-Verify.

Download reports as a CSV file to view data.

We recommend that employers do the following:

Review I-9 and E-Verify records (including copies of work authorization documents, if retained) to identify employees from CHNV countries who presented an EAD showing category (c)(11) at the time of hire.

Review E-Verify regularly to view the “Status Change Report” portal.

Promptly start the reverification process for all individuals affected by cancellation of the CHNV parole program and complete the Form I-9, Supplement B when necessary.

If employees seek advice or information from you, encourage them to retain experienced immigration counsel or refer them to a resource such as the <a href="https://michiganimmigrant.org/">Michigan Immigrant Rights Center.</a>

If you have questions about your employees’ status under the CHNV program or related compliance measures, reach out to an immigration attorney.

Stay alert for further updates. We recommend continuing monitoring of both court and agency developments.

We will continue to provide timely updates as the legal and policy landscape continues to shift. If you have questions about these or any other immigration matter, please contact Sarah Bileti, Daniel Persinger, Christopher LeClair or your Warner attorney.

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Warner Summer Associate Saher Zaidi contributed to this blog.

Talent Without Borders

Senior Counsel

Sarah R. Bileti

Associate

Christopher M. LeClair

Daniel C. “Dan” Persinger

Immigration

DHS Creates Report for E-Verify Employers to Identify Workers Impacted by the Termination of CHNV Parole

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DHS Creates Report for E-Verify Employers to Identify Workers Impacted by the Termination of CHNV Parole

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