The U.S. Department of State has begun transitioning certain visa issuance, reciprocity,  and Blanket L fraud prevention fee payments to the Pay.gov platform. While the change is intended to modernize fee collection and standardize payment processes across consular posts, immigration practitioners have reported implementation issues that have resulted in delays, confusion, and, in some cases, visa refusals under INA Section 221(g). 

As with many government technology initiatives, the policy objective may be straightforward, but the practical impact on visa applicants can be significant. 

What Is Changing? 

Historically, visa issuance fees, reciprocity fees, and certain Blanket L fraud prevention fees were often paid directly through post-specific payment systems. The Department of State is now moving many of these payments to Pay.gov, the federal government’s centralized payment platform. 

The transition affects fees that are separate from the standard visa application fee (MRV fee), including: 

  • Visa reciprocity (issuance) fees applicable to certain nationalities; 
  • Fraud prevention fees associated with Blanket L visa applications; and 
  • Other post-specific fees that may be required before visa issuance. 

While centralization may eventually improve consistency, the rollout appears to be creating uncertainty for applicants and consular officers. 

Emerging Issue: Visa Refusals Under INA Section 221(g) 

Practitioners have reported INA Section 221(g) refusals in cases where payment-related issues prevent immediate visa issuance. 

Although a Section 221(g) refusal is generally considered a temporary administrative hold rather than a final denial, it can delay travel plans, employment start dates, project assignments, and business operations. Consular officers issue Section 221(g) refusals when additional action or documentation is required before a visa can be issued. 

In the context of the Pay.gov transition, applicants may encounter situations where: 

  • Payment records are not immediately reflected in consular systems; 
  • Payment instructions are unclear or inconsistent; 
  • Applicants are unsure which fees must be paid and when; or 
  • Consular officers cannot verify payment at the time of adjudication. 

Any of these issues may result in additional administrative processing and delayed visa issuance. 

Why Employers Should Care 

For multinational employers, visa issuance is often the final step in an employee’s mobility process. Even after a petition has been approved by USCIS, an employee may be unable to begin work or return to the United States until a visa is issued. Administrative issues at this stage can create meaningful business disruptions. 

 Employers with employees applying for visas abroad — particularly Blanket L applicants — should consider: 

  • Confirming fee payment requirements well before the visa interview; 
  • Retaining copies of all payment confirmations and receipts; 
  • Building additional time into travel and onboarding schedules; 
  • Preparing employees for the possibility of post-interview administrative processing; and 
  • Coordinating closely with immigration counsel when unusual payment issues arise. 

 The Bigger Picture 

The Pay.gov transition reflects a broader trend in immigration processing. Delays increasingly arise not from substantive eligibility issues but from operational and procedural requirements surrounding adjudication. For employers, immigration planning can no longer focus solely on petition approval. Consular processing, appointment availability, security vetting, payment systems, and post-interview administrative processing may affect business timelines.  

As additional consular posts adopt Pay.gov and implementation issues are resolved, the process may become more streamlined. In the near term, however, applicants and employers should be prepared for additional scrutiny and potential delays associated with fee verification and processing. 

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Photo of Kate Kalmykov Kate Kalmykov

Kate Kalmykov is based in our New York and New Jersey offices and has over two decades of experience in business immigration matters. Kate currently Co-Chairs the Global Immigration & Compliance Practice at Greenberg Traurig. In this role, she works with employers of

Kate Kalmykov is based in our New York and New Jersey offices and has over two decades of experience in business immigration matters. Kate currently Co-Chairs the Global Immigration & Compliance Practice at Greenberg Traurig. In this role, she works with employers of all sizes across a variety of industries in understanding and complying with the immigration laws relating to the hiring and retention of foreign talent. Specifically, her practice focuses on supporting clients and advising them on temporary and permanent residency immigration options for multi-national executive, business, scientific, and information technology personnel. In addition, her practice provides support to companies in the global transfer of personnel. Known by her clients for her out-of-the-box thinking, responsiveness and hands-on approach, Kate is often called upon to assist in developing immigration options and strategies in the most unique circumstances and to respond to complex Requests for Evidence (RFEs), Notices of Intent to Deny (NOIDs) or to appeal denied cases. Likewise, she has also been instrumental in developing employer compliance programs for DOL related filings including H-1Bs and PERMs, as well as for I-9 employment eligibility verification. To this end, she develops and conducts nationwide I-9 compliance trainings and policy manuals for human resources personnel, advises on best practices for E-Verify employers, provides guidance on avoiding immigration-related unfair employment practices claims and has defended and minimized penalties in immigration-related government audits. Kate regularly works with professionals from the firm’s labor, employment, tax and benefits groups, to provide strategic planning on immigration issues within a cross-border framework.

Kate also has deep experience working on all aspects of the EB-5 immigrant investor program. Kate has worked with real estate developers, private equity funds, and other organizations on applications to designate new EB-5 Regional Centers, applications for pre-approval of EB-5 projects; having projects adopted by existing EB-5 Regional Centers; structuring projects to be EB-5 compliant, the sale of existing EB-5 Regional Centers, preparing template I-526 petitions and advice on structuring direct EB-5 projects. Pursuant to the requirements introduced under the EB-5 Reform and Integrity Act, Kate works with EB-5 Regional Centers, EB-5 Projects, Overseas Migration Agents and Broker/ Dealers to develop internal programs for ongoing compliance and to prepare USCIS I-956, I-956F, I-956,G, I-956H, I-956K submissions. Kate has represented thousands of investors in obtaining their green cards through EB-5 regional center projects, as well as direct EB-5 investment opportunities. She also represented and structured the largest EB-5 offering in the Program’s history and has over the course of her career structured over $12 billion in EB-5 deals.

Within the field of immigration law, Kate is a well-known speaker and author. She is often called upon by various media outlets to comment on topics of business immigration law including the Real Deal, the Wall Street Journal, and Law360. Kate has appeared on numerous TV programs related to immigration law including CNN, the Stoler Report, Vietface TV, and China Business Network. Kate is also a prolific writer on the topic of immigration and has been published in immigration practice handbooks for the American Bar Association, American Immigration Lawyers Association, ILW, and in news periodicals that include the New Jersey Lawyer, the New York Law Journal, the New Jersey Law Journal, USA Today, GlobeSt.com, and the Commercial Observer. At the request of the American Bar Association, Kate co-authored the book “What Every Lawyer Needs to Know About Immigration Law,” a guide for non-lawyers on immigration law practice. She has sat on numerous bar association related committees including the American Immigration Lawyers Association EB-5 Practice Committee, the New Jersey Business Immigration Coalition and has chaired the American Bar Association’s, Committee on Immigration and Naturalization, Section of Administrative Law since 2011. Kate has been recognized in various legal surveys including Chambers Global, New York Super Lawyers, the New Jersey Law Journal who ranked as her as a “New Leader of the Bar,” (formerly 40 under 40) in 2012, NJBIZ “Best 50 Women in Business,” 2019, National Law Review, “Go-To Thought Leader: Immigration Law,” 2022, and Lawdragon 500, Leading U.S. Corporate Employment Lawyers, 2020-2022.

Kate is devoted to pro bono matters and has spent extensive time helping clients fleeing conflict and persecution with asylum applications, applying for and obtaining Temporary Protected Status and Humanitarian Parole.