On October 14, U.S. Citizenship and Immigration Services (USCIS) published an interim final rule (IFR) Removing 30-Day Refugee Termination Notice. The new rule reduces the window of time refugees have to respond to a Notice of Intent to Terminate (NOIT) their status from 30 days to 10 days. This shortened window provides no meaningful opportunity for refugees to seek counsel, provide evidence, or defend their refugee status, and is part of a series of policies targeting refugees (who resettled here at our country’s invitation) for immigration enforcement.

What’s Changed

The new Interim Final Rule takes effect immediately. Under federal statute, refugee status may be terminated for one reason only: when the government determines the individual did not meet the statutory definition of refugee at the time of their admission. Before termination, USCIS sends a Notice of Intent to Terminate (NOIT), explaining why the government seeks to terminate status and providing an opportunity to respond. Historically, refugees had a 30-day response window in which they could seek counsel, submit evidence, or ask for an interview. Under the new IFR, refugees have only 10 days from service of a NOIT to respond (with 3 additional days if service is by mail). The new period includes weekends and holidays, with an exception that if the deadline falls on one of these, it will be moved to the next business day. If USCIS does not receive a response within the now truncated response period, it may terminate status and the refugee may be placed in removal proceedings.

Why This Matters

Refugees are people who fled persecution on account of their race, religion, nationality, membership in a particular social group, or political opinion. Those admitted to the United States as refugees have undergone an extensive vetting process. First, they must be referred for access to the U.S. Refugee Admissions Program (USRAP) by a U.S. embassy, the United Nations, or other referral body (such as a non-governmental organization). Access to apply for refugee status through the USRAP is based on the U.S. government’s own priorities regarding who should be offered resettlement here. Once accepted into the program and allowed to apply for resettlement, they were approved only after rigorous security screenings and adjudications of their claims by USCIS officers with specialized training in determining whether an applicant meets the refugee definition. After they were approved and traveled to the US, they were again inspected by DHS before being admitted as refugees.

The law envisions that admission and resettlement will offer refugees a stable new home where they can rebuild their lives, and that they will generally be granted adjustment to permanent residence status (“green cards”) after a year, after which they may ultimately seek U.S. citizenship.

In November of 2025, however, the administration issued a new policy to re-vet the refugee claims of refugees who arrived between January 21, 2021 and February 20, 2025, and to pause pending applications for permanent residence by refugees who came during this period. This policy has had devastating effects on refugees. Traditionally, refugees have been eligible for basic public benefits immediately after their arrival in the United States. But new policies also strip eligibility for these programs from those without green cards. This means refugees who have not yet obtained permanent resident status are cut off from Medicaid and CHIP, as well as Medicare beginning in January 2027. Adding to the uncertainty about their status, refugees who have serious medical conditions are losing critical healthcare suddenly and unexpectedly. Together with the mass re-vetting policy and green card adjudication freeze, the new IFR fast-tracking refugee status terminations are deadly.

Under federal statute, refugee status may only be terminated in cases where the government determines an individual did not meet the statutory definition of a refugee at the time of their admission. Given the extensive vetting refugees underwent before being admitted, decisions to re-vet and seek to terminate refugee status have historically been rare. They were generally taken only when evidence in an individual case or a discrete set of cases warranted. To be sure, where there was evidence of fraud or other indicia that a specific individual was not a refugee when admitted, termination could be pursued. Additionally, where there was evidence of criminal conduct or other circumstances that made them removable, removal could be pursued even without first terminating refugee status. But these instances have been relatively uncommon in the past, across both Republican and Democratic administrations, and longstanding policies already provided effective means to address them when they did arise.

With no formal appeals process, the notice period following service of a NOIT provides the only real opportunity for a refugee to defend their status. By shortening the window, the new rule severely restricts refugees’ ability to obtain legal representation, request an interview, or otherwise provide evidence demonstrating that they met the refugee definition when they were admitted to the U.S. Furthermore, it drastically increases the risk of erroneous terminations, unwarranted placement of refugees in removal proceedings, and devastating uncertainty for people who were promised safety and a new home here. When refugees receive a final termination notice, they are not only generally placed in removal proceedings, but also lose work authorization, jeopardizing families and destabilizing workplaces.

Those approved through the USRAP’s extensive processing and background checks have worked to rebuild their lives and contribute to our communities. Mass “re-vetting” of many thousands of refugees is inhumane, unnecessary and wasteful. Terminating status in the hasty manner announced by this rule is reckless and violates basic concepts of due process, fairness, and compassion. And it places refugees at risk of removal, potentially resulting in return to the very persecution they fled.

Take Action

The Jesuit Conference Office of Justice and Ecology and JRS/USA urge the Department of Homeland Security and USCIS to rescind the Interim Final Rule, to end mass re-vetting of admitted, resettled refugees, and to resume processing their applications for permanent residence status (green cards).

Please contact your representatives and ask them to demand the same.