On June 5, 2019, the Department of Homeland Security’s U.S. Citizenship and Immigration Services (USCIS) published a third notice regarding its plans to dramatically change fee waiver eligibility and process. The June 5 notice attempts to provide additional justification for its plan to eliminate means-tested benefits as a basis for requesting a fee waiver, among other changes, following April 5 and September 28 notices that lacked rationale for why such changes to fee waivers are justified. Now, USCIS is also claiming lost fee revenue as a reason for its proposed changes to fee waivers, making clear its intention to reduce the number of fee waivers that are granted. If finalized, these proposed changes will discourage eligible individuals from filing for fee waivers and immigration benefits and place heavy time and resource burdens on those who do still apply for fee waivers.
We urge you and your agency to submit comments—even if you sent comments during the other public comment periods—to let USCIS know that you are still opposed to these proposed changes and that their attempts to bolster their weak justifications for this change are unacceptable and insufficient. The comment period closes on Friday, July 5, 2019 (*note with the Fourth of July holiday you may want to get your comments in sooner than this deadline).
Below, please find a template comment to aid in your advocacy. While the template is a great starting point, we strongly encourage you to include your unique perspective about the detrimental effect of these proposed changes when submitting your or your agency’s comment. The goal is to maximize the number of unique comments to have the greatest impact.