Updated June 8, 2026
On May 22, 2022, U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0199, titled “Adjustment of Status is a Matter of Discretion and Administrative Grace, and an Extraordinary Relief that Permits Applicants to Dispense with the Ordinary Consular Visa Process.”
In this memorandum, USCIS maintains that obtaining permanent residence through an Adjustment of Status (AOS) within the U.S. should be understood as an "exceptional" alternative to the "normal" process of applying for an immigrant visa at a U.S. consulate, also referred to as “consular processing.” Consequently, the memorandum indicates, an AOS will only be granted at the discretion of a USCIS adjudicator as a matter of “administrative grace.” The memorandum further instructs adjudicators to weigh a variety of positive and negative factors when deciding whether to approve an AOS application. Importantly, however, the memo does not contain any new regulatory restrictions preventing eligible individuals in the U.S. from pursuing permanent residence through adjustment of status.
What This Means for the Brown Community
ISSS is aware of this memorandum and is currently in communication with the University's external immigration attorneys to assess its impact on current and prospective permanent residence sponsorship cases. We will share further guidance as it becomes available. In the meantime, any University employee currently being sponsored for permanent residence is welcome to reach out to ISSS Director Andrew Shiotani with questions. Individuals pursuing family-based immigration (permanent residence via an eligible family relationship) or any other category unrelated to their University employment should consult their personal immigration attorney for guidance.