A new internal memo at U.S. Citizenship and Immigration Services (USCIS) may force more green card applicants to complete the process from outside the United States, and immigration practitioners are already reporting chaos and confusion as a result, according to the American Immigration Council.

The change concerns how USCIS handles certain adjustment-of-status cases — the pathway applicants inside the United States use to obtain lawful permanent residence without leaving the country. Under the new guidance described in the memo, more applicants could lose the ability to finalize their applications domestically and instead be routed through consular processing at a U.S. embassy or consulate abroad.

What the memo changes

The memo revisits a long-standing feature of the U.S. immigration system: when USCIS waives the in-person interview requirement for certain green card applicants, the applicant can be approved without appearing before an officer. Interview waivers have historically allowed the agency to manage caseloads and have spared many applicants — particularly family-based and employment-based applicants with straightforward cases — from lengthy delays.

If USCIS narrows the circumstances in which it grants these waivers, or stops granting them for certain case types, the practical consequence is that applicants would need to appear for interviews. And where an applicant cannot complete the required steps inside the United States, the case could shift to consular processing abroad.

Who is affected

The applicants most directly exposed are those already living in the United States who have filed, or plan to file, Form I-485 applications to adjust status. For these individuals, a shift to consular processing would mean leaving the country, attending an interview at a U.S. consulate in their home country, and waiting there for a decision.

Practitioners quoted in coverage of the memo describe significant uncertainty about how the new instructions will be applied case by case. Applicants and attorneys have reported difficulty determining whether a pending case will be affected, whether an interview waiver already granted remains valid, and what happens to applicants who travel abroad while their case is in transition.

Why it matters

Consular processing differs from adjustment of status in several practical ways. The applicant must generally remain outside the United States for the interview and any administrative processing that follows. Travel, separation from family and employers, and extended waits abroad can add months to a process that, under adjustment of status, would have been completed from within the country.

The American Immigration Council, which reported on the memo, frames the change as part of a broader pattern of policy shifts that create unpredictability for applicants. Confusion at the implementation stage, the Council notes, falls hardest on applicants who cannot easily absorb sudden travel requirements or prolonged separation from jobs and families in the United States.

What applicants should watch

USCIS has not yet published final public guidance tied to this memo, and the scope of any change will become clear only when the agency issues formal policy or updates its manual. Applicants with pending or planned adjustment-of-status cases should monitor official USCIS communications rather than rely on informal summaries, and should verify any questions about their own situation with a licensed immigration attorney or accredited representative before making travel decisions.

This article summarizes the reported memo and does not constitute legal advice. Official instructions, forms, and policy alerts appear on the USCIS website at uscis.gov, and the American Immigration Council's reporting provides the underlying analysis of the document.