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CLINIC’s Comments on Immigration Forms and Regulations

N-400 (Application for Naturalization Form)

On November 11, 2015, CLINIC submitted comments to the U.S. Citizenship and Immigration Services (USCIS) in response to its proposals to change the Application for Naturalization Form (N-400) and related documents. CLINIC’s Advocacy and Capacity Building teams worked closely together to analyze and provide constructive feedback on the lengthy list of items set forth by USCIS for comment, including Form N-400, Form N-400 Instructions, guidance to the public about the naturalization process and requirements, and N-400 Online Form and process. CLINIC’s Advocacy team also reached out to affiliates to raise awareness of the proposed changes, listen to concerns about the current process, and to further our understanding of the impact of the proposed changes in the field.  CLINIC’s comments acknowledge the challenges faced by the 8.8 million immigrants living in the United States who are eligible for naturalization but have not yet applied. Our comments also raise up concerns from practitioners in the field who regularly provide direct services, naturalization workshops, and citizenship preparation.

While CLINIC applauded certain initiatives by the USCIS to address barriers for naturalization, including the implementation of credit card processing for payment of the naturalization fee, CLINIC’s comments mainly provided constructive feedback on the following:

  • Form length – CLINIC opposed the increased length of the form to 22 pages. CLINIC provided several recommendations to USCIS that would significantly reduce the length of the form while maintaining the integrity of the form and adjudicatory process.
  • Collection of Third Party Data – CLINIC opposed the collection of data through the proposed Form N-400 that is not directly connected to an eligibility factor.
  • Certifications and Statements – CLINIC opposes the proposed addition of lengthy and complex statements, certifications and acknowledgements for the applicant, interpreter and preparer.

In addition, CLINIC provided comments on the proposed USCIS Online Form, applauding USCIS’s transition to automation. CLINIC provided feedback and recommendations to USCIS about how the proposed online process may be improved to include more direct information about the availability of fee waivers.  In its comments on proposed changes to the Guide to Naturalization, CLINIC provided over a dozen suggestions on improving the clarity of language and instructions.  CLINIC’s comments were joined by several affiliates and partners. Overall, USCIS received 75 comments. We expect further developments on Form N-400 in the coming months.

I-130 (Petition for Alien Relative)

On December 14, 2015, CLINIC submitted comments to USCIS regarding changes to Form I-130, Form I-130A, and Form I-130 and I-130A Instructions. CLINIC’s comprehensive comments and suggestions focused on several key areas previously discussed in our summary of the proposed forms.

  • Clear Language - CLINIC commended USCIS’s efforts to use clearer language on forms
  • Form Length - CLINIC voiced concerns about the overall pace and volume of form changes proposed and provided specific suggestions for reducing the form length.
  • Public Engagement - CLINIC requested greater public engagement on substantial form changes

You may access the Forms, Instructions, Tables of Changes, as well as additional information, by visiting the Federal eRulemaking Portal site and entering USCIS-2007-0037 in the search box.

Draft “Extreme Hardship” Policy

On November 23, 2015 CLINIC submitted comments to USCIS regarding its proposed guidance interpreting the term “extreme hardship” as it is applied to certain waiver of inadmissibility applications. CLINIC’s comments and suggestions focused on several key areas previously discussed in our summary of the draft guidance.

  • Extreme Hardship through A Single Scenario - CLINIC commends USCIS on the proposed change that would allow an applicant to establish extreme hardship to the qualifying relative based upon a single scenario
  • Aggregate Hardship Consideration - CLINIC supports the established principle that hardship should be considered in the aggregate
  • Reclassification of 5 Extreme Hardship Factors - CLINIC supports the reclassification of the 5 extreme hardship factors and requests that USCIS keep education a stand-alone factor
  • Presumption of Extreme Hardship - CLINIC strongly urges USCIS to create a presumption of extreme hardship

Overall, CLINIC applauded the proposed guidance that, when implemented, is expected to improve consistency in adjudications and broaden the use of this critical program for families facing hardship and separation.  Comments to the draft guidance were due on November 23, 2015. You may access the Forms, Instructions, Tables of Changes, as well as additional information, by visiting the Federal eRulemaking Portal site and in the search box.


Board of Immigration Appeals (BIA) Recognition and Accreditation Program

More than 20 years have passed since the Executive Office of Immigration Review (EOIR) last made substantive change to the rules and procedures governing the BIA Recognition and Accreditation Program (R&A) program. On September 16th, EOIR announced a new set of proposed changes. Recognizing the significance of the proposed extensive changes, CLINIC reported on the proposed rule in a free webinar on Sept. 21.

CLINIC also conducted a survey, requesting feedback on key issues raised for comment by EOIR. This feedback and the many questions and concerns raised by affiliate programs helped to prepare CLINIC, as we attended each of the three stakeholder meetings held by EOIR since September.

CLINIC updated our BIA R&A toolkit by adding a section dedicated to the proposed rule changes The new section includes links to webinars, a summary of the changes, key government links, as well as model comments and tips for organizations that planned to submit comments.

In addition to CLINIC’s outreach, our advocacy team organized and led discussions with national partners and other stakeholders, including World Relief, the American Bar Association, CARECEN, the International Rescue Committee and the New York Immigration Coalition. A second, free webinar lead by CLINIC and hosted by Immigrant Advocates Network had more than 300 participants.

These efforts culminated in the submission of CLINIC’s comments to EOIR on Nov. 17 and the subsequent submission of comments by CLINIC affiliates. The comments offered program-specific examples of how the proposed changes may affect service delivery and program performance.

According to the Federal Rulemaking Portal, EOIR received 64 comments to its proposed rule. A vast majority of the 42 publicly available comments are consistent with CLINIC’s recommendations and many directly reference and support CLINIC’s suggestions.

While we do not know what the final rule will look like, we are grateful for the opportunity to work closely with our affiliates and other stakeholders who presented comments or otherwise contributed to the development of our submission. Our advocacy is strengthened and informed by you.

CLINIC shared its comments to EOIR publicly so that the scope of the proposed changes is known and our perspectives are understood. Other comments may be found at: and more directly at this link

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New and Proposed Rules and Policy Guidance

Fee Waivers (Form I-912)

On July 9, 2015, CLINIC submitted a second round of comments concerning revisions to Form I-912 (initial comments were submitted in May). On August 6, 2015, USCIS met with advocates to discuss further. At that time, USCIS indicated that it had received sufficient feedback on the proposed revision and no further comments were to be collected. Although Form I-912 indicates that it expired May 31, 2015, the May 10, 2013 version or other previous versions may be used until a new version is issued.

Expansion of the Provisional Waiver Program

On July 22, 2015. USCIS published a proposed rule that would expand the current provisional waiver program in two significant ways: (1) allowing other immigrant visa applicants and (2) allowing Lawful Permanent Resident (LPR) parents and spouses to be “qualifying relatives”. At the present time, only U.S. citizen parents and spouses qualify. (For more information, read our article.) 

In preparing its comments to the proposed rule, CLINIC collected feedback from affiliates representing all regions of the United States. CLINIC submitted comments on September 18, 2015. CLINIC will continue to monitor the progress of this initiative and is now preparing for the release of policy memoranda that would define the extreme hardship standard.

Board of Immigration Appeals Recognition & Accreditation

On September 17, 2015 the Executive Office for Immigration Review (EOIR) announced a new proposed rule governing recognition and accreditation (R&A).  It also issued two final rules, each addressing various aspects of legal representation. The proposed rule is titled Recognition of Organizations and Accreditation of Non-Attorney Representatives. The two final rules are titled List of Pro Bono Legal Service Providers for Individuals in Immigration Proceedings and Separate Representation for Custody and Bond Proceedings.

On September 21, CLINIC staff hosted a webinar in which it presented each proposed change and explained the implications for nonprofit organizations. CLINIC is soliciting comments for each of the key areas of proposed change and is working actively with its network of affiliates and other national organizations to provide formal written comments to EOIR by the November 30th deadline.  CLINIC chairs the BIA R&A liaison group, a forum to discuss comments on the proposed rules. Please submit comments here.

USCIS Form N-400, Application for Naturalization

On Monday, September 28, USCIS announced the extension of a comment request period for proposed revisions to Form N-400. USCIS is requesting comments on its proposed updates to Form N-400, Form N-400 Instructions, Public-facing guidance, and USCIS's proposed online N-400 form.  Comments are due by November 12, 2015. (80 FR 58292, 9/28/15). 

Draft Extreme Hardship Policy Guidance for Waiver Applications

On October 7, 2015, USCIS circulated draft guidance interpreting the term “extreme hardship” and explaining how it should be applied to waiver applications. The proposed policy guidance is in draft form only and has not yet gone into effect.

The guidance would set forth, in greater detail and specificity, how adjudicators should weigh various hardship factors in a waiver application. For example, applicants would only have to establish extreme hardship to the qualifying relative if that family member were to relocate with the applicant or remain in the United States separated from the applicant, depending on which is more reasonably foreseeable.  Currently, the waiver applicant has to establish extreme hardship under both scenarios. 

In addition, the guidance lists five special circumstances that strongly suggest the existence of extreme hardship. One of the listed special circumstances is when the State Department has issued a travel warning with respect to a country or a region of a country.

Comments on the draft guidance are due on November 23, 2015. CLINIC will be preparing model comments and circulating them to affiliates. Please see the link below from USCIS to access the text of the draft guidance and contact us at if you have any specific questions or comments.


Center for Immigrant Integration (June 2015 Update)

By Louise Maria Puck

CLINIC’s new Center for Immigrant Integration seeks to encourage and facilitate the development of immigrant integration initiatives throughout its network through the creation of resources and trainings and through the dissemination of best practices currently present in CLINIC affiliate agencies.


This month, the Center has several new developments.


In the News

Celebrating Immigrant Heritage Month

Earlier this month, President Obama recognized the month of June as Immigrant Heritage Month in an effort to celebrate our heritage and diversity. The President reminded the public to visit to share stories and experiences of moving to America. The audio and video of the address is available online at


Affiliate Highlights

Learn about Littleton Immigration Resources Center (LIRC), a Colorado-based CLINIC affiliate led by Petula McShiras. This program emerged from a gathering of Littleton residents in 2004. Today a great part of LIRC services are centered on its citizenship program, but in addition the program offers an array of other services such as English tutoring and advice on employment, healthcare and education. 


ESL/Citizenship Test Preparation

Upcoming CLINIC Webinar

Training Teachers: Tricks, Tools and Strategies for Volunteer-based Language Learning

Tue, Aug 11, 2015; 2:00 - 3:00 p.m. Eastern

Are you interested in creating or strengthening an English as a Second Language or citizenship test preparation program? Are you wanting to use volunteer teachers yet are unsure of how to train and retain quality instructors? Join us for this webinar as we learn the nuts and bolts of staffing your program along with tricks and tips to effectively train and keep high-quality teachers. Lee Shainis, Executive Director and Co-Founder of Intercambio: Uniting Communities in Boulder, Colorado will share with us the strategies he uses to train staff for his high-volume language-learning programs. Register here.


Outside Resources

MIPEX – The Migrant Integration Policy Index - here you can learn how the United States scores on its integration efforts. The MIPEX is used as a tool to evaluate and compare what governments around the world are doing to promote integration of migrants. The success of a country’s integration efforts is measured in eight different policy areas. 

New Capacity Building and Immigrant Integration Resources

By Leya Speasmaker

Immigrant integration is the ultimate goal of the work the CLINIC network does each day as our affiliates assist eligible immigrants to pursue immigration benefits. CLINIC announces the creation of new tools designed to help your program promote and encourage immigrant integration within your community.  Two new self assessment tools are now available on our website.

  • The Immigration Legal Program Management Self Assessment is a useful way to evaluate progress towards implementation of the seven areas which CLINIC views as strong indicators of a successful, charitable legal immigration program.  CLINIC offers this self assessment tool to identify program strengths and weaknesses so that improvements can be targeted and purposefully undertaken.

CLINIC has also consolidated all its resources on immigrant integration into one place on our website.

Additionally, CLINIC's Core Standards have been revised to include immigrant integration recommendations for all programs to pursue.

CLINIC would like to assist you in developing immigrant integration programs. If you would like your program highlighted, or if you are interested in learning more about immigrant integration or how to develop program outcomes related to immigrant integration, please contact Leya Speasmaker at We will continue to update the website, so please check back often. If there are resources that you would like to see CLINIC offer, please let Leya know.

Please inform all agency staff engaged in serving the foreign born, as we are not just offering this to legal staff but all those who serve immigrants in their daily work.

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Spotlight on Integration: 6 Part Series

Looking for ideas to promote and encourage immigrant integration within your community? CLINIC offers this 6 part series that spotlights immigrant integration initiatives across our network. Learn the definition of immigrant integration, its importance for our network and nation, and how it can be promoted locally. Featured programs encourage relationships between the receiving community and immigrants, give elderly refugees a place to use skills gained in their home countries, and connect asylees with available resources.

Please contact Leya Speasmaker at if you would like for one of your projects to receive the spotlight.


Spotlight on Integration:  October 2010
Immigrant Integration and Why it Deserves the Spotlight

Spotlight on Integration:  November 2010
St. James English as a Second Language Program in Seattle, Washington

Spotlight on Integration:  December 2010
New York State Immigration Hotline and the ORR National Asylee Information and Referral Hotline, Catholic Charities Community Services in New York City, New York

Spotlight on Integration:  January 2011
Garden Project for Older Adult Refugees, Catholic Charities of the Archdiocese of Milwaukee, Inc. in Milwaukee, Wisconsin

Spotlight on Integration:  February 2011
Institute for the Hispanic Family, Catholic Charities of Hartford in Hartford, Connecticut

Spotlight on Integration:  March 2011
The Borromeo Legal Project, St. Charles Borromeo Catholic Church in Arlington, VA

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How to Establish and Develop a Successful ESL Program

Held Nov. 16, 2010

Due to an increasing need for quality English as a Second Language (ESL) and Citizenship Test Preparation classes, many community-based organizations are interested in starting their own language learning programs. Combining CLINIC’s key components for program management and Teachers of English to Speakers of Other Languages’ (TESOL) Standards for Adult Education ESL Programs, this Webinar will provide a foundation for interested organizations to plan and implement a language learning program. Instructor: Leya Speasmaker.

To download the presentation, click here.

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The Mechanics of English Language Learning

Held October 21, 2010

This is part 2 of a 3-part series on language access.

English Language Learners (ELL) make up a large percentage of the total number of adult learners in classrooms around the United States. These learners face unique challenges in their educational pursuits. This Webinar will explain how the adult brain learns, what challenges an ELL faces inside and outside of the classroom, and how a program might overcome these obstacles. Program Representatives will present their own experiences in offering an ESL program in their community and share what they have learned in the process.  Presenters: Dr. Patricia Maloof and Leya Speasmaker, both of CLINIC.

To download the Power Point presentation, please click here.

Part I: Language Access: Effectively Serving Limited and Non-English Speakers (October 5, 2010).

Part II: How to Establish and Develop a Successful ESL Program at Your Agency (Nov. 16, 2010)

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Language Access: Effectively Serving Limited- and Non-English Speakers

Language Access: Effectively Serving Limited- and Non-English Speakers

This is part 1 of a 3-part series on language access.

Does your agency have a legal obligation to provide interpretation or translation services to the people that you serve? Do language barriers prevent your clients from accessing critical information and services such as the legal system, emergency medical care, schools, firefighters or police? This Webinar will explain the laws that entitle limited- and non-English speakers to interpreters and that legally obligate organizations to provide individuals with language access. Learn how to ensure that your clients’ language access rights are fulfilled and how to develop an effective language access strategy for your agency.

To download the Power Point presentation, click here.

Held October 5, 2010


Part II - The Mechanics of English Language Learning

Part III - How to Establish and Develop a Successful ESL Program at Your Agency 


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Immigrant-Led Organizers in Their Own Voices

The United States is experiencing historically unprecedented levels of immigration. As of March immigrantorganizersvoice2005, there were 37 million foreign-born persons in the United States, making up 12 percent of the population. Approximately 14 million immigrants arrived during the 1990s.2 From the early 1990s to 2000, the number of immigrants increased by 61 percent. Today, immigrants are changing the face of the cities in which they settle. Some have argued that immigration policies, including immigrant integration, are necessary to ensure our nation’s security and domestic harmony.3 While society as a whole should be responsible for addressing the integration needs of immigrant communities, in many cases immigrants themselves have taken the primary initiative to integrate into U.S. society. Many have chosen organizing as a powerful way of doing this.


To download the entire publication, please click here.