Congress returns to Washington, DC with very few days to accomplish much, and many new reasons or excuses not to “get to” Immigration Reform. Faced with immediate and pressing issues, such as a continuing resolution to prevent a government shutdown at the end of September, the sequester and debt ceiling debate and the impending Syria crisis votes, it seems quite clear that Immigration Reform will be pushed off again. As reported in early August, the U.S. House of Representatives has made some progress at the committee level on Immigration Reform, but the ability and willingness to move legislation to the floor with less than 35 days in session seems very unlikely. Can Congress address Immigration Reform in 2014? It certainly can, but whether it will, depends on the ability to do so well in advance of the 2014 election cycle. It will also be critical to overcome innate inertia and what we have referred to as the culture of “no” to make immigration reform a possibility.