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United States of America: IRC comment opposing proposed USCIS fee schedule changes

Source: International Rescue Committee Country: United States of America, World
December 27, 2019 Submitted via www.regulations.gov Ms. Samantha Deshommes, Chief
Regulatory Coordination Division
Office of Policy and Strategy
U.S. Citizenship and Immigration Services
Department of Homeland Security
20 Massachusetts Ave. NW
Washington, DC 20529 Re: U.S. Citizenship and Immigration Services Fee Schedule, DHS Docket No. USCIS2019- RIN 1615-AC18 Dear Chief Deshommes, The International Rescue Committee (IRC) respectfully submits this comment on the proposed U.S. Citizenship and Immigration Services (USCIS) Fee Schedule, published on November 14, 2019 and supplemented on December 9, 2019. The proposed rule threatens to unjustly burden immigrants, placing a financial barrier between eligibility and immigration status for many non-wealthy and vulnerable immigrants and their families. Furthermore, the negative impacts of the proposed rule would go beyond the individual immigrant to span communities, the legal service sector, and the fairness and integrity of our immigration system. For these reasons and as detailed below, the IRC strongly opposes the proposed fee rule. Established in 1933, the IRC provides relief, protection, resettlement, and integration services to refugees and other humanitarian, vulnerable immigrants. Globally, the IRC responds to the world’s worst humanitarian crises and helps people whose lives and livelihoods are shattered by conflict and disaster to survive, recover, and gain control of their future. Our network of 25 program sites in the United States provides resettlement and integration assistance to thousands of refugees who have been lawfully admitted to the United States as well as Iraqi and Afghan special immigrants, asylum-seekers, asylees, victims of human trafficking, humanitarian parolees, TPS holders, lawful permanent residents and others. The provision of basic immigration legal services—in particular, adjustment of status, family reunification and naturalization—is a necessary extension and integral component of our mission in the U.S. To ensure the successful integration of our clients, our network of 24 legal services programs, which has been recognized by the U.S. Department of Justice since 1958, is committed to providing high quality, affordable, and essential immigration services to primarily low-income refugees, asylees, and other immigrants. Our long-standing services in the communities in which we operate allow us to fully anticipate the detrimental effects and ramifications of the proposed fee and policy changes.


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