Comment Opportunity: Oppose USCIS Changes to Fee Waiver Forms and Policy

ASISTA has created an updated template to comment on proposed fee waiver changes, initially proposed in September 2018.  This second opportunity to oppose these harmful changes takes into account USCIS’ response to the comments submitted and updated I-912 form and instructions.  (Click here for an updated table of changes)

To have the most impact, please individualize your comments with your own reasons and experiences, especially focusing on how the proposed fee waiver changes would burden survivors and your agency. In particular,

—How will eliminating the means-tested benefit grounds for fee waiver harm the immigrant survivors and families with whom you work? How will this change harm your agency?

—How will the new changes in the updated form instructions and new I-912 form, including requiring additional documentation to show household income, harm your clients and your agency?

To the extent possible, your comment submission should be in your own words and based upon your agency’s concerns and interests.

For another sample, see the Immigrant Legal Resource Center’s updated template comment HERE, which is customizable and addresses a wide range of concerns with the fee waiver memo and updated forms.  CLINIC has also provided updated guidance for public comment available HERE.  We are grateful to ILRC and CLINIC for putting these amazing resources together. Feel free to adjust your comment to incorporate any of these additional issues.

Deadline and How to File:Deadline for submission is May 6, 2019

Comments may be submitted via email to the OMB USCIS Desk Officer at All submissions received must include in the subject line the government agency name (USCIS), and the OMB Control Number 1615-0116. Sample subject line for your email: “USCIS Information Collection Activity, OMB Control Number 1615-0116”.

Be sure to also include your name and the name of your agency in the comment. For more information on how to file, click here.


ASISTA Template Comment in Google Doc Format
USCIS Response to Comments Submitted in Fall 2018
Updated Instructions
Updated I-912 Form
IRLC Template Comment
CLINIC Public Comment Guidance