On August 25, 2026, the Department of Homeland Security (DHS) published a proposed rule, Fee for Certain H-1B Petitions, that would impose an additional $103,265 filing fee on all cap-subject H-1B petitions, including those eligible for the advanced-degree exemption. The fee would not apply to petitions filed by cap-exempt employers, such as the University of Michigan and other institutions of higher education.
Although the proposed rule would not apply to U-M as an employer, the University submitted a comment letter opposing the fee and urging DHS to withdraw the proposal. The letter argues that DHS relies on implausible assumptions and calculations and lacks the authority to impose a fee that would fund other federal agencies. The proposed fee would also substantially limit U-M’s international students’ ability to connect their studies with post-graduation professional development and employment, disrupting a critical talent pipeline for the U.S. economy.