On Dec. 1, 2020, CLINIC submitted comments in connection with USCIS’s recent Policy Manual changes at Volume 12, Part E, Chapter 2, English and Civics Testing. In its comment, CLINIC provides expert analysis of the new naturalization civics test and raises concerns about the process and methodology used in developing and implementing it. CLINIC opposes the new civics test because it will increase burdens on applicants, drive up denial rates, and will exacerbate growing backlogs and processing times for naturalization applications. For these reasons, CLINIC requested that USCIS rescind the new test and associated policy manual changes in their entirety.