Deferred action, in one form or another, dates back to at least the 1960s. Deferred action guidance was previously contained in the legacy Immigration and Naturalization Service, Operations Instructions § 103.l(a)(l)(ii) (1975). The OI stated: "When determining whether a case should be recommended for deferred action category, consideration should include the following: (1) advanced or tender age; (2) many years' presence in the United States; (3) physical or mental condition requiring care or treatment in the United States; (4) family situation in the United States effect of expulsion; (5) criminal, immoral or subversive activities or affiliations recent conduct."

DHS Secretary Jeh Johnson memo on prioritizing enforcement, which prioritized national security, border security and public safety threats (Priority 1); noncitizens convicted of a serious misdemeanor (Priority 2); and noncitizens recently ordered removed (Priority 3).

In addition to individual grants of parole, prior administrations have established special parole programs designed to address certain populations, but parole decisions also have required case-by-case adjudication. For example, George W. Bush's administration had established the Cuban Medical Professional Parole program. President Obama had a parole program for people fleeing violence in Central America who failed to secure refugee status.