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

On June 5, 2019, USCIS published another notice and opportunity for comment on their proposed fee waiver changes. These changes were initially proposed in September 2018, and later addressed in a second opportunity for comment in April 2019. This third notice provides additional details regarding USCIS’ rationale for adjusting the fee waiver form and practices.  You can review this new notice here. We encourage stakeholders to submit comments to show the impact of these harmful changes to fee waiver forms and guidance on survivors and their families. 

To have the most impact, your comment submission should be in your own words and based upon your agency’s concerns and interests. 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? (For a table of changes, see here)
  • IMPORTANT: If giving examples, please take all appropriate measures to protect client confidentiality, including using a pseudonym, not listing specific locations, etc.

The Immigrant Legal Resource Center (ILRC) also posted an updated template comment HERE, which is customizable and addresses a wide range of concerns with the fee waiver memo and updated forms. In addition, Asian Americans Advancing Justice in Los Angeles have also released a template comment, which is available HERE. Feel free to adjust your comment to incorporate any of these additional issues. 

Deadline and How to File: Deadline for submission is July 5, 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”.