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Filing H-1B visa petitions for foreign employees in 2019 could be even more complicated than usual due to proposed process changes from the U.S. Citizenship and Immigration Services.

On Monday, USCIS published a proposed rule that would require the electronic registration of all H-1B visa applicants over a 14-day period each year. Applicants would then be placed in a lottery, and those selected would have 60 days to submit a petition to obtain the visa, which allows them to work in the U.S. for specialized jobs.

“It’s always complicated to begin with, but this year it’s going to get even more complicated,” said Kelli Duehning, senior counsel in the San Francisco office of Berry Appleman & Leiden.

That’s because it’s unclear if USCIS will be able to implement its new rule, and the technology required, in time to register 2019 H-1B applicants.

Gregory Wald, a partner at Squire Patton Boggs‘ San Francisco office, said the proposed two-part process could allow applicants to find out whether they’ve won the lottery sooner and save companies the extra work of filing a petition for unsuccessful entrants. But, like Duehning, he said he’s not certain if the new process will be effective next year, estimating a “less than 50 percent” chance.

“The smart play is for employers to prepare now, as if it was status quo, a regular H-1B cap season, and work with their attorneys to have a contingency in place, or have some kind of plan in place, in case the registration does kick in,” Wald said. “But proceed, at least at this point in time, as if it is not.”

For Silicon Valley tech companies, which rely heavily on foreign workers, that means planning ahead. Duehning said companies should push the hiring season ahead for foreign workers if possible, so they can meet the potential March registration date. Many companies wait until after the holidays, but she said that could be “too late” for this H-1B season.

Companies should also have full petitions ready to go for USCIS’s usual April 1 due date, in case the proposed changes don’t take effect in 2019. The proposal is currently in its 30-day comment period.

Duehning said there could also be tech-related complications with electronic filing. USCIS hasn’t stated what system it will use for H-1B registrations, and the agency has had issues in the past with online applications.

USCIS’s proposed rule also prioritizes applicants with advanced degrees from U.S. universities. Under the new rule, applicants with a U.S. advanced degree will be placed into the lottery twice—the first time only with other American degree holders, and a second time with non-U.S. degree holders mixed in.

Currently, applicants with a U.S. degree are placed in one lottery, and those with an advanced non-U.S. degree are placed in a separate lottery.

“The government claims that this way, you have a bigger second bite at the apple if you’ve got a U.S. advanced degree,” Wald said. “So that’s going to be the biggest change.”