Comment Submitted by Viktor Movchaniuk

I am submitting this comment as a Ukrainian humanitarian parolee whose employment and financial stability have already been harmed by the current employment authorization renewal process. I worked as a software engineer at BL.INK, a U.S. technology company, from June 2023 until February 2025. My EAD expired on December 22, 2024. I began the renewal process in October 2024, approximately two months before expiration. Despite applying before my EAD expired, the process involved lengthy delays and uncertainty. My employer could not obtain sufficient assurance that I could continue working without interruption, and my employment ended in February 2025 because of the uncertainty surrounding my renewal. After losing my job, I supported myself with personal savings. I have never requested or received government financial assistance or public benefits. I have consistently tried to support myself through employment, pay taxes, and contribute through my professional work. My replacement EAD was approved on December 9, 2025, and delivered on December 20, 2025. It was valid only until December 23, 2025. Because its validity was measured from the expiration of my previous EAD rather than from the approval or delivery date, I received it only three days before it expired. I waited more than a year for a document that was almost immediately unusable. I filed another EAD application on March 13, 2026. It was approved on May 5, 2026, and expires on December 23, 2026. I have been actively searching for another software engineering position since April 2026. As of July 22, 2026, I am in final interview stages with prospective employers. I am concerned that employers may choose another candidate because they cannot predict whether my work authorization will continue beyond the next few months, even though I am currently authorized to work and intend to file all required applications on time. Hiring for senior technology positions often takes several months and may include multiple interviews, background checks, and onboarding. A qualified worker with only a few months remaining on an EAD may be viewed as too risky regardless of current legal authorization. This creates a repeating cycle: short EAD validity makes employment harder to obtain, unemployment depletes personal savings, and each renewal creates another period of uncertainty that discourages employers from hiring or retaining qualified workers. As of July 22, 2026, I have approximately five months remaining on my current EAD and am using savings during a second period of unemployment. The proposed economic-necessity requirement would add another burden without solving this problem. My savings should not be treated as evidence that I do not need to work. They were accumulated through years of employment and are being depleted while I search for another position. Requiring people to exhaust their savings before qualifying for work authorization would punish financial responsibility and could make them more likely to need assistance later. Employment, not savings, is how I remain self-sufficient. The proposed E-Verify requirement could also make the problem worse. Many legitimate employers, especially startups and smaller technology companies, do not participate in E-Verify. Applicants cannot control whether a prospective employer is enrolled. Conditioning renewal eligibility on an employer’s participation would reduce job opportunities and create additional uncertainty. My experience shows that the existing system already causes employers to terminate or avoid qualified workers because of processing delays and short EAD validity periods. Additional documentation and employer restrictions would increase that harm. I respectfully ask DHS and USCIS to: 1. Continue work authorization for applicants who timely file renewal applications. 2. Issue EADs for the full authorized parole period whenever legally permitted. 3. Calculate validity from the approval or issuance date when processing delays occur. 4. Do not condition renewal eligibility on an employer’s E-Verify participation. 5. Do not treat personal savings as proof that an applicant lacks economic necessity. 6. Protect unemployed applicants who are actively searching for work. 7. Provide transition protections for parolees who have relied on renewable work authorization. I want to work, support myself, pay taxes, and contribute my professional skills in the United States. I have never asked the government to support me financially. The main obstacle to my self-sufficiency has been the uncertainty created by short EAD periods and a renewal process that employers cannot reliably plan around. I respectfully urge DHS not to add restrictions that would make this cycle even more difficult.