E O 12866 Meeting on the USCIS Fee

IRC’s Vested Interest in the Fee Rule & Its Impact • IRC network consists

IRC’s Vested Interest in the Fee Rule & Its Impact • Requested that USCIS

The Rule Will Cause Disproportionate Harm to Low-Income Immigrants • Such large increases in

Recommendations • USCIS should maintain fee waivers and current guidelines for all current categories.

Insufficient Analysis and Basis for Increases • History of increases shows increased fees do

Insufficient Analysis and Basis for Increases • Congress has called on USCIS to keep

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E. O. 12866 Meeting on the USCIS Fee Schedule* June 22, 2020 *Final rule pending review: OMB Control Number 1615 -AC 18

IRC’s Vested Interest in the Fee Rule & Its Impact • IRC network consists of 25 sites in the United States providing resettlement and integration assistance. • IRC provides essential immigration legal services to over 13, 000 primarily low-income individuals annually. • Clients include refugees, Iraqi and Afghan special immigrants, asylum-seekers, asylees, victims of human trafficking, humanitarian parolees, TPS holders, lawful permanent residents and others.

IRC’s Vested Interest in the Fee Rule & Its Impact • Requested that USCIS and OMB provide a full, 60 -day comment period. • Submitted a public comment in response to proposed fee rule. • Conducted outreach and awareness raising for stakeholders on the rule, encouraging public comments.

The Rule Will Cause Disproportionate Harm to Low-Income Immigrants • Such large increases in application fees constitute a wealth test for immigrants who are statutorily eligible for immigration benefits. • Individuals granted humanitarian protection in the United States must be able to continue accessing benefits and status to further the initial safety offered by the U. S. government. • Limiting payment types accepted would unfairly disadvantage low-income, low literacy, and/or newly arrived immigrants.

Recommendations • USCIS should maintain fee waivers and current guidelines for all current categories. • Naturalization should remain affordable, in line with Congressional intent. • Adjustment of Status applications should remain bundled and affordable. • USCIS’ proposal to transfer applicant fees to ICE is inappropriate • USCIS should not impose a fee for asylum. • USCIS should not impose a fee for DACA renewals.

Insufficient Analysis and Basis for Increases • History of increases shows increased fees do not have a positive impact on backlogs and processing times, and will not address some of the operational and systemic issues plaguing USCIS, such as inefficient communication systems, lack of integration of technology to support workflow, and inadequate staff training. • In 2007, USCIS stated that increases would enable the agency to “maintain proper service levels and avoid backlogs. ” However, since 2010, USCIS’ backlog has increased by more than 6, 000% and the overall average case processing time has increased 91% between 2014 and 2018.

Insufficient Analysis and Basis for Increases • Congress has called on USCIS to keep naturalization affordable (H. Rep. No. 115 -948 accompanying H. R. 6776, the Department of Homeland Security Appropriations Act (2019). • Creating a financial barrier to immigration status for those who are statutorily eligible delays their ability to gain greater job security, stability, and gains that impact not only the individual or family, but the whole community and economy as well. One study found that the U. S. gross domestic product (GDP) would increase between $37 billion to $52 billion over 10 years if those eligible obtained U. S. citizenship.

Thank you