Business Roundtable Comments on “Deferred Action for Childhood Arrivals,” Notice of Proposed Rulemaking, Department of Homeland Security Docket No. USCIS-2021-0006

View a PDF version of the letter here.

November 15, 2021

Dear Ms. Strano:


Business Roundtable Comments on

“Deferred Action for Childhood Arrivals,”

Notice of Proposed Rulemaking,

Department of Homeland Security Docket No. USCIS-2021-0006




Business Roundtable CEOs lead America’s largest companies, employing 20 million workers. Their companies’ total value, over $20 trillion, accounts for half of the value of all publicly-traded companies in the United States. They spend and invest over $7 trillion a year, helping sustain and grow tens of thousands of communities and millions of medium- and small-sized businesses.   

Business Roundtable appreciates the opportunity to comment on the Notice of Proposed Rulemaking (NPRM) that U.S. Citizenship and Immigration Services (USCIS) published on September 28, 2021, regarding “Deferred Action for Childhood Arrivals” (DACA). Business Roundtable shares the Biden Administration’s goal of removing legal uncertainty[i] for “Dreamers”—individuals who entered the United States as children, know this country as their only home and play a vital role in our workplaces, economy and communities.

Business Roundtable encourages USCIS to finalize without delay this regulation to allow eligible DACA beneficiaries to remain in the United States and maintain their employment authorizations. In addition, Business Roundtable urges the Biden Administration to continue to work with Congress to enact bipartisan legislation that provides permanent legal status for these individuals. We stand ready to assist lawmakers and the Administration on a bipartisan, constructive solution.



Business Roundtable supports public policies that enable U.S. economic growth and job creation and that expand economic opportunity for all Americans. This includes efforts to strengthen the pipeline of domestic talent as well as to ensure lawmakers enact sound immigration policies that support our economy. Business Roundtable has conducted extensive research and released in-depth reports that examine immigrants’ contributions to the American economy,[ii] compare U.S. immigration policies to those of other countries,[iii] and propose realistic solutions for fixing the country’s immigration system.[iv] With 11 million job openings currently unfilled, employers rely on immigrants with the skills needed to curb the U.S. labor shortage. Furthermore, nearly 49 percent of the Dreamer population works in essential industries.[v] Business Roundtable continues to encourage Congress to fix our country’s broken immigration system on a bipartisan basis.




The agency should finalize this regulation to protect Dreamers, who make invaluable contributions to American society and our economy.

 Business Roundtable welcomes the agency’s public engagement and input as it carries out the memorandum President Biden signed on January 20, 2021, “Preserving and Fortifying Deferred Action for Childhood Arrivals.”[vi] We urge the agency to move quickly to finalize and implement this regulation.

 A survey by the Center for American Progress found that nearly 90 percent of DACA beneficiaries are employed in the United States in a wide range of industries.[vii] Over the last year and a half, Dreamers have been on the frontlines of fighting the COVID-19 pandemic as health care workers and in other disciplines and industries that have helped countless Americans. An estimated 29,000 DACA beneficiaries are frontline health care workers, with an additional 12,700 working in critical roles in the health care industry. [viii] More than 200,000 DACA beneficiaries have served as critical infrastructure workers during the COVID-19 pandemic as well.

 Despite their integral roles in our communities, Dreamers continue to live with the uncertainty of ongoing litigation. As we work to reinvigorate the U.S. economy, we need their continued contributions and urge the agency to finalize this regulation. Failure to act would have a significant negative impact on businesses that rely on these individuals as employees and customers. Given current processing delays at USCIS, Business Roundtable also asks the agency to expand the availability of automatic Employment Authorization Document (EAD) extensions to prevent disruptions in employment.


The Administration should work with Congress to pass bipartisan legislation that provides lasting relief for Dreamers.

 Business Roundtable urges the Administration to continue to work with Congress to find a lasting, bipartisan legislative solution that promotes economic growth, reflects American values and keeps our communities safe. We have long called for a permanent solution for DACA beneficiaries, including a path to citizenship. Given their immense contributions to our workplaces, communities and the U.S. economy, Dreamers should not be expected to continue living under administrative and judicial uncertainty. Congress should act to provide lasting relief and a path to citizenship for these individuals.

 Legislation to provide a path to citizenship for Dreamers has seen bipartisan support since the first DREAM Act was introduced in 2001. Polling data has consistently shown that the vast majority of Americans also favor granting permanent legal status to Dreamers.[ix]  

 Economists have found that enacting the American Dream and Promise Act (H.R.6) would increase U.S. GDP by a cumulative $799 billion over ten years and create 285,400 new jobs.[x] As the U.S. Department of Homeland Security acknowledges in the NPRM, DACA beneficiaries make significant contributions in the form of taxes and economic activity. A 2020 report revealed that DACA beneficiaries pay about $5.6 billion in annual federal taxes and about $3.1 billion in annual state and local taxes, which is in addition to their contributions to Social Security and Medicare funds through their employment.[xi] 

Business Roundtable stands ready to work with Congress and the Administration to achieve these solutions. We thank USCIS for taking action to protect Dreamers and urge the Administration to finalize this regulation and continue working with Congress to pass legislation. Further, we appreciate the opportunity to respond to this NPRM and look forward to continued communication with the agency on these and other issues surrounding the U.S. immigration system. Please contact Dane Linn, Vice President, Business Roundtable at if you have any questions.







[i] New American Economy. (2020, May). Spotlight on the DACA-Eligible Population. Retrieved from; (2021, October). The Impact of DACA: Nine Years After Implementation. Retrieved from

[ii] Business Roundtable. (2017, September). Economic effects of immigration policies: a 50-state analysis. Retrieved from

Business Roundtable. (2014, June). Contributing to American growth: the economic case for immigration reform. Retrieved from  

[iii] Business Roundtable. (2015, March). State of immigration: how the United States stacks up in the global talent competition. Retrieved from

[iv] Business Roundtable. (2013, April). Taking action on immigration: realistic solutions for fixing a broken system. Retrieved from

[v] (2021, February). Undocumented Immigrant Essential Workers Five Things to Know. Retrieved from


[vii] Tom K. Wong, et al., Center for American Progress. (2020, October). New DHS Policy Threatens to Undo Gains Made by DACA Recipients. Retrieved from

[viii] Nicole Prchal Svajlenka. Center for American Progress. (2020, April). A Demographic Profile of DACA Recipients on the Frontlines of the Coronavirus Response. Retrieved from

[ix] (2021, March). Polling Update: Pathway to Citizenship for Undocumented Immigrants Remains Overwhelmingly Popular. Retrieved from; Pew Research Center. (2020, June). Americans broadly support legal status for immigrants brought to the U.S. illegally as children. Retrieved from

[x] Giovanni Peri and Reem Zaiour. (2021, June). Citizenship for Undocumented Immigrants Would Boost U.S. Economic Growth. Retrieved from

[xi] Nicole Prchal Svajlenka and Philip E. Wolgin, Center for American Progress. (2020, April). What We Know About the Demographic and Economic Impacts of DACA Recipients: Spring 2020 Edition. Retrieved from