This is an information-only tool, not legal advice. You are responsible for your decisions. When in doubt, consult an immigration attorney.
Updated May 2026 for USCIS PM-602-0199
Close the discretion gap before filing I-485
On May 21 2026 USCIS issued Policy Memorandum PM-602-0199 reframing adjustment of status as “extraordinary discretionary relief.” Statutory eligibility is unchanged, but adjudicators now actively weigh positive equities against adverse factors on every case. This tool scores your profile across 14 dimensions, flags hard-stop conditions, and generates a cover-letter scaffold tied to your inputs.
Fill in at least “years continuous US presence” or “years W-2 tax filings” to see your equities score.
How this scoring works
PM-602-0199 instructs adjudicators to weigh positive equities (long lawful presence, family ties to U.S. citizens / LPRs, tax compliance, community contributions, professional standing) against adverse factors(status violations, unauthorized employment, fraud, criminal history, public-charge concerns, prior denials). The memo expressly preserves dual intent for H-1B / L-1 holders — but says that maintaining dual-intent status alone is “not sufficient” to warrant favorable discretion. You need to AFFIRMATIVELY build the equities record.
The scoring rubric is a heuristic, not a legal opinion. Paired attorney review before filing I-485 is non-optional — especially given how new this memo is and how adjudication patterns are still emerging.
Why front-loading matters
Pre-memo, many I-485 packets relied on the implicit assumption that adjudicators would approve once eligibility was met. Post-memo, an I-485 packet without an equities cover letter effectively asks the adjudicator to build the equities record from raw documents. That’s an invitation to RFE or NOID at best, denial at worst. The cover-letter scaffold this tool generates is what your attorney will refine into the final equities memorandum for filing.
Related tools
- · PM-602-0199 explained — primary-source explainer of the new memo, with verbatim lists of positive equities and adverse factors.
- · Visa Bulletin tracker — your priority date determines WHEN you can file; this tool addresses WHAT to file.
- · EB-2 NIW evidence builder — if your equities are thin and you’re considering NIW as a parallel path, the same evidence-gathering discipline applies.
- · Personal timeline — sequences equity-building against your H-1B grace deadlines and Visa Bulletin movement.