RE: Rescind Policy Memorandum PM-602-0199 Restricting Access to Adjustment of Status

Dear Director Edlow:

We, the undersigned organizations, write to express our deep concern regarding U.S. Citizenship and Immigration Services (USCIS) Policy Memorandum PM-602-0199, “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,” issued on May 21, 2026. We urge USCIS to immediately rescind this memorandum and reaffirm adjustment of status (AOS) as a critical and Congressionally authorized pathway for eligible immigrants seeking lawful permanent residence from within the United States.

For more than 70 years, AOS has served as a foundational component of the U.S. immigration system. In establishing this pathway, Congress recognized the need to allow eligible immigrants already present in the United States to obtain green cards without the unnecessary disruption and prolonged family separation that accompany departing for consular processing in their countries of origin. The memorandum’s framing of adjustment of status as an “extraordinary” form of relief undermines Congress’s intent as well as the plain statutory meaning of the Immigration and Nationality Act. In addition, the memorandum drastically departs from longstanding agency practice. Although adjustment of status has always involved discretionary agency review, this memorandum’s misguided interpretation of AOS as an exceptional recourse disregards decades of policy. In fact, since 1980, over half of all legal permanent residents adjusted status within the United States, including nearly 800,000 individuals in Fiscal Year 2024 alone.

Read the full letter and see the full list of signers by downloading the file below.