On February 2, 2009, the United States Conference of Catholic Bishops (USCCB), and the Catholic Legal Immigration Network (CLINIC) submited comments on the interim rule issued by U.S. Citizenship and Immigration Services (USCIS), Department of Homeland Security (DHS) that would require all documents submitted to employers for employment authorization verification purposes to be unexpired.
A copy of the letter is included below.
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USCCB/CLINIC’s Interest in the Interim Rule
USCCB has particular interest in this rule making because it has Federal Government grants and cooperative agreements for refugee resettlement and the Cuban/Haitian entrant program. Many of USCCB sub-recipients are responsible for assisting refugees, parolees, and asylees obtain employment in the United States. For its part, CLINIC supports a national network of community-based immigration programs. The network includes 173 affiliated immigration programs, which operate out of 267 offices in 48 states. The network employs roughly 1,200 attorneys and “accredited” paralegals who, in turn, serve 600,000 low-income immigrants each year. CLINIC and its network serve vulnerable migrants such as refugees, asylum-seekers, and parolees and help them to understand the employment verification process. While we support improvements to the integrity of the employment verification process, we are concerned that certain populations, especially asylees, refugees and parolees, will be adversely impacted by certain provisions of the interim rule.
To read the complete letter, please click here.