Comment Letters

The Immigration Response Team regularly submits comment letters about immigration policy changes.

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Regarding the Strengthening and Fortification of Deferred Action for Childhood Arrivals (2021)

On Monday, September 27, the Department of Homeland Security announced a proposed rule to preserve the Deferred Action for Childhood Arrivals (DACA) program and protect the hundreds of thousands of current and potential DACA recipients throughout the United States. Marissa Hill-Dongre submitted a comment on behalf of the Immigration Response Team.

Regarding Request for Recommendations to Improve USCIS Processes (2021)

U.S. Citizenship and Immigration Services (USCIS) recently asked for comments from the public about barriers individuals and institutions experience when attempting to access immigration benefits and services. Marissa Hill-Dongre submitted a comment on behalf of the Immigration Response Team and International Student and Scholar Services (UMN-TC) about opportunities to improve customer service, eliminate technology and process inefficiencies/redundancies, adjust or change policies, and address complications that had unintended consequences. 

Regarding Immigration Fee Increase (2019)

On November 14, 2019, U.S. Citizenship and Immigration Services (USCIS) announced a proposal to increase fees for a number of immigration benefits while also reducing access. Some other entities that submitted letters opposing the fee included NAFSA: Association of International Educators and the American Council on Education.

Regarding Changes to Unlawful Presence for Students and Exchange Visitors (2018)

USCIS issued a policy memorandum proposing changes to the way it counts days of "unlawful presence" for students and exchange visitors on F, J, and M non-immigrant visas and their dependents. While USCIS stated these changes were meant to send a message to those who overstay their visas, the proposed change could mean international students could be barred from entering the U.S. for three or ten years due to minor visa infractions or changes in immigration changes that the student does not learn about for years.

Regarding the Use of Social Media Information in Visa Applications (2018)

The Department of State has proposed significant changes to the visa application process with additional questions requiring 15 years’ worth of detailed information about travel, address and employment. IRT submitted comments to express concerns about the effect such changes could have on institutions of higher learning. NAFSA: Association of International Educators also submitted a letter explaining the negative impact such changes could have on US higher education and scientific collaborations.

Regarding "Extreme Vetting" Proposals (2017)

In March 2018, the State Department proposed changes that would require all visa applicants (immigrant and non-immigration) to submit all of their social media accounts, phone numbers, and email addresses for the previous five years when applying for a visa. This requirement would affect the nearly 15 million individuals who apply for an immigrant and non-immigrant visa each year, and it would apply to more than 20 social media networks.