I-600(A) Public Comments_Response Matrix

Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
Comment Public Comments
#
Comment Commenter: Jean Publiee
1.
if there are u.s. citizens who want to adopt and take the
full financial responsibility of these "orphans", then its ok,
but they must show that they have financial resources to
pay for the full care and education of this child. we cannot
allow into this country "orphans" who show up at the
border and claim to be parentless when we know that isnt
true or honest and that they lie to come into this country
to make the working people of this country pay for their
care instead of their own parents. we are sick of being
played for chumps. we have our own children to take care
of and the economic realities of life in the usa for most
people is not cushy as is claimed. it is hand to mouth day to
day. we cannot continmue to absorb all of these migrating
people invading our country. we shoudl be taking care of
our own american citizens first, our old people, our infirm,
our disadvantaged. we are in fact neglecting them at the
present time with all available money going to the worlds
citizens. and WE ARE FORGETTING ABOUIT OUR OWN
AMERICAN CITIZENS. THEY GET NOTHING ANYMORE. THEY
ARE DISADVANTAGED TO THE MAX. WE CANNOT
CONTINUE TO DO THAT TO OUR OWN CITIZENS. SHUT THE
GODDAM DOOR. DONT LET ANY FOREIGN IN ANY MORE.
WE HAVE MILLIONS MORE THAN WE KNOW WHAT TO DO
WITH. WE SHOULD BE DEPORTING ALL THE LIARS,
CRIMINALS, PROSTITUTES, DRUGGES, ETC. WE GET THE
CHINESE 90 YEARS OLDS TO TAKE CARE OF. WE SEEM TO
BE THE DUMPING GROUND FOR ALL THE WORLDS
NEGLIGNET PARENTS AND FAMILY PEOPLE. THAT NEEDS
TO STOP.; WE NEED TO FOCUS ON AMERICANS. WE NEED

USCIS Response

Response:
Thank you for your comment. Since no substantive issues regarding
the information collection were raised, no changes will be made as
a result of this comment.

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
TO TAKE CARE OF OUR OWN CITIZENS. SHUT THE GODDMA
DOOR TO THESE FOREIGNERS, ORPHAN OR NOT. IF THEY
ARE MEXICAN ORPHAN, THEY BELONG IN MEXICO. IF A
GUATEMALAN ORPHAN, THEY BELNG IN GUATAMALA.
NOT HERE. ITS TIME TO SHUT THE DOOR. AND TO TAKE
STEPS TO STOP PREGNANT WOMEN FROM FLYING OR
SNEAKING IN HERE TO HAVE ALLEGEDLY "AMERICAN" KIDS
WHEN THESE PEOPLE ARE FOREIGNERSS AND NOT
AMERICANS AT ALL. WE NEED TO PRESERVE OUR
AMERICAN HERITAGE. NOW. NO MORE FOREIGN
"ORPHANS" AND NO CRIMINIALITY SCHEMES BY ILLEGAL
IMMIGRANTS SNEAKING HERE TO TAKE IN THEIR ALLEGED
"ORPHANS". THAT IS NOTHING BUT A CRIMINAL SCHEME.
Comment Commenter: Deborah Huebner
2.
Thank you for adding the Supplement 2, Consent to
Release.
Comment Commenter: Irene Steffas
3., Issue
1.
See attached file(s)
Thank you for the opportunity to review and comment. In
brief:

Response: Thank you for your comment.

Response: Thank you for your comment. Detailed responses are
provided in the other Comment 3 Issue rows.

1. This is an opportunity to distinguish between primary
providers, accredited agencies, accredited representatives
and legal service providers. If done this would protect
PAPs.
2. The form uses the term "birth siblings". However, USCIS
has suggested that children who were adopted by the
same parents would also qualify. Hence, legal siblings is
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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
more accurate and inclusive.
3. Signatures on USCIS forms and signature on documents
should be distinguished. Signatures on Forms and on
Statements re criminal history are the only ones that
require original signatures.
4. Re Translations - USCIS should accept official
government translations from other countries.
5. Consider adding secondary evidence for Death
Certificates.
6. This is a great opportunity to enlighten adoptive parents,
attorneys and the public about the requirements of the
Universal Accreditation. This was not done.
7. Forms appear very simple and USCIS implies that
adoptive parents can complete them on their own. This is
not true. The Primary Provider for PAPs should be the ones
completing these forms.
8. The amount of duplicity in the questions on the form
make it longer and more confusing.
Comment I-600 Instructions, TOC pg. 5:
3., Issue
Legal Service Provider
2.
ADD
A Legal Service Provider is not the same as an Approved
Person who is an attorney.
Comment I-600 Instructions, TOC pg. 9:
3., Issue
Regarding signatures: ADD
3.
USCIS requires the original signatures of Petitioner,
Petitioner’s spouse and all adult household members on
all USCIS forms: I-600A, I-600, Supplement 1, Supplement
3, G-28, I-864, I-864W, Home Study etc

Response:
This comment applies to language that no longer exists in this place
on the proposed revision of the form. The language in question has
been moved to Part 9.
USCIS has considered the comment in the context of the language’s
new placement and made an edit to explain that not all attorneys
are approved persons authorized to provide adoption services
under 22 CFR 96.2.
Response:
USCIS declines these edits. The instructions regarding signatures
are clear.

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
Distinguish signatures on forms and signatures on
documents:
Photocopies of documents that include a signature are
acceptable.
Comment I-600 Instructions, TOC pg. 11:
3., Issue
ADD:
4.
Official Translations that is issued by a foreign
sovereignty are acceptable.

Response:
USCIS will make determinations regarding translations after
reviewing the documents submitted.

Comment I-600 Instructions, TOC pg. 21:
3., Issue
Last paragraph – NOTE: This paragraph explains what the
5.
requirements are for a non US citizen.

Response:
USCIS declines this edit. There is nothing in USCIS regulations that
prohibit us from adjudicating and considering cases under these
circumstances.

ADD: You should not file form I-600 under the following
circumstances: a) your spouse is a conditional resident
and USCIS has not been adjudicated his or her status; b)
your spouse is in removal proceedings; and or USCIS had
not adjudicated your spouse’s claim for asylum.
Comment I-600 Instructions, TOC pg. 22:
3., Issue
Copies of Death Certificates of Child’s Parents if applicable.
6.
ADD: If Death Certificates are not available, an
explanation along with Secondary evidence can be
included, such as medical records, obituaries, gravesites,
statements from funeral home and crematorium and
family and clergy that helped bury the dead.
Comment I-600 Instructions, TOC pg. 27:
3., Issue
ADD language in bold:
7.

Response:
USCIS declines the edit. The I-600 Instructions explain secondary
evidence in the Affidavits section.

Response:

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
Petitioner should disclose all changes in circumstances to
this Home Study Provider and Primary Provider.

USCIS declines this edit. USCIS regulations do not require disclosure
to the Primary Provider.

A Home Study Update may be needed in the following:
change of address or a change of employment.

USCIS declines this edit. A home study update is required in the
circumstances listed in the instructions.

Comment I-600 Instructions, TOC pg. 31:
3., Issue
ADD language in bold:
8.
1.
Provide true and complete information to your
home study preparer and primary provider.
Comment I-600 Instructions, TOC pg. 32:
3., Issue
ADD – onto the last line
9.
such as a first offender’s program.

Response:
USCIS declines this edit. USCIS regulations do not reference the
primary provider, only the home study preparer.

Comment I-600 Instructions, TOC pg. 32:
3., Issue
ADD primary provider in 5.
10.
5. Notify your home study preparer, primary provider and .
..
Comment I-600 Instructions, TOC pg. 32:
3., Issue
After Warning, 1. ADD primary provider
11.
Conceal, misrepresent, or fail to disclose any facts to the
home study preparer, primary provider and USCIS
Comment I-600 Instructions, TOC pg. 43:
3., Issue
Paperwork Reduction Act 1 hour per response. Not
12.
accurate. Every response does not require 1 hour. The
entire form may require 1-2 hours to prepare.

Response:
USCIS declines this edit. USCIS regulations do not reference the
primary provider, only the home study preparer.

Response:
USCIS declines the edit. The language in this paragraph clearly
explains that any possible offenses should be disclosed, regardless
of “the fact that an arrest or conviction or other criminal history
was expunged, sealed, pardoned, or the subject of any other
amelioration.”

Response:
USCIS declines this edit. USCIS regulations do not reference the
primary provider, only the home study preparer.
Response:
Under the Paperwork Reduction Act, the time burden per response
is the estimated time required to fill out the entire form.

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
Comment General Comment A.
3., Issue
Siblings This section is incorrect: the Sibling exception to
13.
age is found in all 3 definitions of INA 101(b)(1)(E), INA
101(b)(1)(F) and INA 101(b)(1)(G),
Secondly, the adopting parents do not need to adopt both
children under the same adoption. For example, adopting
parent adopts child under INA 101(b)(1)(F). Years later,
adopting parent adopts sibling and uses INA 101(b)(1)(E) or
(G).
The sibling exception also applies when the PAPs adopt 2
children simultaneously and one child is under the age of
16 and the other child is under age 18, but over the age of
16 WHEN THE I-600A or I-600 are filed.
This exception only includes “birth siblings”. At the last
Symposium by the Office of Children’s Issues and the
Council on Accreditation, (2015 or 2016) a representative
from USCIS, International Operations said that the sibling
exception should not exclude siblings who were adopted
by the same adopting family. Hence the sibling exception
includes children who were adopted by the same family.
Instead of saying birth siblings, USCIS should consider legal
siblings
Comment General Comment B.
3., Issue
Although the definitions of an eligible child, 8 CFR 204.3b
14.
are not the subject of these comments, it is appropriate for
USCIS, DOS and others to review the antiquated definitions
under this regulation.

Response:
The sibling exception for Form I-600 applies if the beneficiary was
adopted while under age 18, is the natural sibling of a child
described in 101(b)(1)(F)(i) or (E)(i), and was adopted by the same
adoptive parents as this sibling. Note: INA §101(b)(1)(G)(i) is not
included in the older sibling exception at INA 101(b)(1)(E)(ii) or
(F)(ii).
The sibling exceptions in sections 101(b)(1)(E), (F), and (G) of the
Immigration and Nationality Act (INA) do not include adoptive
siblings in light of the statutory language Congress chose, which
states that the exception applies to “natural siblings.” USCIS does
not have the authority to interpret a statute contrary to its plain
meaning and Congressional intent.

Response:
Thank you for the comment regarding 8 CFR 204.3. This Federal
Register Notice is a request for public comments on a form revision,
not on a proposed regulation.

No parents because of the death or disappearance of,
abandonment or desertion by, or separation or loss from
both parents.
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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
The U.S. is the only country that defines abandonment in
this matter.
There is no category for orphans whose parents do not in
writing surrender their children to a government body.
Many country do not have the infra structure to accept
such children.
There is no definition for an eligible when his or her birth
parents never bonded with the child and simply to do not
want to parent the child.
Language used in these regulations was appropriate in
1950-1970. Using the term natural parents is considered
as derogatory and outdated.
Comment General Comment C.
3., Issue
There is no mention of the Universal Accreditation Act,
15.
which now requires:
• Need for a Primary Provider
•

Home Study by an Accredited Agency (or if a non
Accredited Agency conducts the Home Study, then
an Accredited Agency must review and approve
the Home Study.

•

Primary Provider collaborates or supervises
Foreign Adoption Service Provider

• PAPs must document fees paid
Comment General Comment D.
3., Issue
This form makes it appear that USCIS will be interviewing
16.
PAP. This is not the current practice. Is this a change for
future filings of I-600s?

Response:
While USCIS has removed reference to the Universal Accreditation
Act, the requirements have been incorporated through questions in
the revised forms.

Response:
While this form update is not intended to convey changes to
current interviewing practices or requirements for Form I-600
filings and adjudication. Still, the instructions note that 8 CFR
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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
103.2(a)(9) authorizes USCIS to require interviews or biometrics
from petitioners at any time.
Comment General Comment E.
3., Issue
There is no place that distinguishes between a Primary
17.
Provider, Accredited Agency, Accredited Representative
and Legal Service Provider. These are all different. It is a
shame to see PAPs waste money on a Home Study by an
Unaccredited Agency that does not even follow the
requirements of 8 CFR 204.311. Or an immigration
attorney that does not advise PAPs that they need a
Primary Provider and a Home Study by an Accredited
Agency.
Comment Commenter: Irene Steffas
4., Issue
1.
On the whole the changes are clear and appropriate.
Concerned about the word Investigation -- investigation of
applicant, petitioner's spouse and adult household
member.

Response:
USCIS reformatted questions related to home study preparers in
Part 2. of Form I-600A to further distinguish roles.

Response:
USCIS views any investigation of the applicant, petitioner, spouse,
and/or adult member of the household as potentially relevant to a
suitability determination.

Word is too broad and should be limited.
Glad to see applicant's residing abroad addressed.
Thank you
Comment Form I-600A, TOC pg. 7:
4., Issue
Under Question 31
2.
Type of Application/Petition Filed:
ADD: I-130 for an adopted child
Comment Form I-600A, TOC pg. 7:
4., Issue
Under Question 32.
3.
ADD: words in bold:

Response:
USCIS has made the requested edit to Form I-600A.
Response:

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
State and County where adoption was finalized?
Case Number of Your Petition for Adoption

Comment Form I-600A, TOC pg. 9:
4., Issue
Under Duty of Disclosure, new phrase 37. A and 38. A
4.
Investigated: This needs to be defined. Too broad and
overreaching.
Students applying to law school are investigated by the law
schools. Graduates of law school are investigated when
they apply to a State Bar Association.
Teachers are investigated when they apply for a state
license to teach.
Applicants to the FBI, Secret Service, DOD etc.

USCIS has added “County” to the Item Number 32. on both the
Form I-600 and the Form I-600A. We decline the request to add a
case number field.
Response:
USCIS views any investigation of the applicant, petitioner, spouse,
and/or adult member of the household as potentially relevant to a
suitability determination. The language under Duty of Disclosure,
Item Numbers 37.A. and 38.A. specifically states and relates to
investigations “for breaking or violating any law or ordinance.”

Comment Form I-600A, TOC pg. 12:
4., Issue
ADD to Item 5 the words in bold
Have you identified another accredited agency or
5.
approved person to serve as your primary adoption service
provider?
Comment Form I-600A, TOC pg. 15:
4., Issue
ADD INSERT into paragraph
6.
9. If known, are the children you seek to adopt siblings?

Response:
USCIS accepts the comment and has made the requested edits.

Comment Form I-600A, TOC pg. 18:
4., Issue
Applicant’s Duty to Disclose: ADD the language in Bold
. . . I agree to notify my home study prepare, my primary
7.
adoption service provider and USCIS . . .
Comment Form I-600A, TOC pg. 21:
4., Issue
Your Spouse’s Duty to Disclose: ADD the language in Bold
8.

Response:
USCIS declines this edit. USCIS regulations do not require disclosure
to the Primary Provider.

Response:
USCIS declines this edit. The information is not needed to
adjudicate Form I-600A.

Response:
USCIS declines this edit. USCIS regulations do not require disclosure
to the Primary Provider.
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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
. . . I agree to notify my home study prepare, my primary
adoption service provider and USCIS . . .
Comment General comments:
4., Issue
1. Delighted that you added Primary Adoption Service
9.
Provider.
2. Define and distinguish between a Primary Adoption
Service Provider, Accredited Agency, Accredited
Representative and Legal Service Provider. These terms
should be explained in greater detail at the onset on the
case.
Consider allowing Accredited Agencies or Approved
Persons to Prepare Immigration Forms such as I-600A, I600, Supplement 1, and Supplement 2.
Comment I-600A Instructions, pg. 1:
4., Issue
Add a 3rd item:
10.
The child’s adoption is not governed by the Hague
Adoption Convention, even though after the Hague
Adoption Convention entered into force. For Example,
the case meets requirements agreed upon by the United
States and the child’s country o foreign to proceed as a
non-Convention case during the country’s transition to
the Hague Process.
Comment I-600A Instructions, pg. 2:
4., Issue
Glad to see that you are addressing Applicants Residing
11.
Abroad
Comment I-600A Instructions, pg. 3:
4., Issue
Under Affidavits: ADD
USCIS accepts Statements when the person providing the
12.
Statement is clearly identified [DOB, A#, address, e-mail,
mobile phone]. Such Statements may be made before a
Notary Public or the statement includes the following
language: Under penalties of perjury of the laws of the
United States, I affirm that the matters contained in this

Response:
Please see responses to specific comments.

Response:
USCIS declines the comment. The two exceptions noted in the
instructions apply only to non-transition cases. In the instance of
transition cases, a prospective adoptive parent would already have
an approved Form I-600A and transition cases would only occur in
the context of Form I-600. Form I-600 petition instructions address
processing of transition cases.
Response:
Thank you.
Response:
USCIS declines this edit.

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
statement are true and correct. Such statements must be
signed and dated
Comment I-600A Instructions, pg. 7:
Response:
4., Issue
What is USCIS referring to on page 7, 3rd paragraph that
USCIS is referring to the UAA. The sentence immediately following
13.
states:
says “For more information…”
If your case meets certain criteria, you home study may not
be required to meet some of the above requirements.
If USCIS is referring to Applicants residing abroad, it should
state so. Otherwise, this paragraph will lead to confusion
and errors by
Applicants.
Comment I-600A Instructions, pg. 1:
4., Issue
Under the Section of Who May Not File Form I-600A:
14.
consider
the following additions:
a) Your spouse is a conditional resident and USCIS has
not been adjudicated his or her immigration status;
b) Your spouse is in detention or in removal proceedings;
c) USCIS had not adjudicated your spouse’s claim for
asylum: and
d) Your spouse is on probation.
Comment Form I-600A Supplement 1:
4., Issue
15.
1. Page 3, Adult Member of Household’s Duty of
Disclosure, ADD words in bold
. . . I agree to notify the applicant, petitioner, home study
prepare, primary adoption service provider and USCIS . . .

Response:
USCIS declines this edit. There is nothing in USCIS regulations that
prohibit us from adjudicating and considering cases under these
circumstances.

Response:
USCIS declines this edit. USCIS regulations do not require disclosure
to the Primary Provider.

2. Concerns raised above regarding the word Investigation.
Too broad, not clear and could be very invasive.

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018
Comment Commenter: Ryan Hanlon on behalf of National Council For
5., Issue
Adoption (NCFA)
1.
I-600A Instructions:
We suggest adding clarity regarding I-600A Part 3, question
6 so that applicants know the differences/merits of filing
stateside vs. filing at a foreign consulate
Comment I-600A Instructions:
5., Issue
On page 10, the instructions indicate that two separate
2.
checks or money orders are required for the filing and
biometric fees. This seems to be unnecessarily
burdensome. We suggest allowing applicants to submit just
one check or one money order to pay for these services.
Comment I-600A Instructions:
5., Issue
Also on page 10, the proposed changes include information
3.
about paying via credit card. NCFA welcomes this change in
the instructions and supports the concept of more options
and electronic options for prospective adoptive parents.
We suggest adding more to the instructions here for users,
instead of just sending them to a link for form G-1450.
Specifically, we suggest:

Response:
There is generally no advantage to file Form I-600, Petition to
Classify Orphan as an Immediate Relative, abroad or domestically.
Response:
USCIS currently requires these fees to be submitted separately.

Response:
USCIS declines this edit. Instructions for filing Form G-1450 are
provided in the context of that form.

a) Making it clear if they need to do two separate forms
(one for biometrics, one for the filing fee) or if they can just
do one form G-1450 to cover all expenses.
b) Making it explicit how they submit G-1450 with the I600A (e.g. included completed form G-1450 as
supplemental doc
Comment Form I-600A:
5., Issue
In Part 10, Question 7b we suggest adding clarity to this to
4.
indicate if “does not extend” includes or does not include
USCIS issuing a Request for Evidence (RFE) or Notice of
Intent to Deny (NOID). If they do not, can clarity be given if

Response:
USCIS declines this edit. This does not seem to be a point of
confusion for applicants.

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Responses to 60-day FRN Public Comments
Form I-600 Revision, posted July 17 – September 17, 2018

Comment
5., Issue
5.

Comment
5., Issue
6.

Comment
5., Issue
7.
Comment
5., Issue
8.

in such situations, the Hague-accredited Primary Provider
would then have responsibility of responding?
One suggested solution would be to eliminate the option
of partial representation. This would be consistent with
USCIS Form G28 which does not allow attorneys to limit
their representation to just completing the I-600A
application.
I-600 Instructions:
We welcome the change regarding the validity of
signatures in the general instructions and believe this will
enable prospective adoptive families and USICS to utilize
commonplace technology (e.g. scanning) while still
ensuring the authenticity of the original signature (i.e. by
requiring it to be a scan/photocopy of the original).
I-600 Instructions:
On page 7 of the proposed changes, under the section
“Initial Evidence” under “1. Proof of Petitioner’s U.S.
Citizenship” under point A. (5) we suggest clarifying that
this does not require the passport to have 10 years of
validity at time of displaying as evidence, but rather that it
had 10 years of validity at the time of issuance. This could
be clarified by adding the word “originally” between the
words “passport” and “issued”.
I-600 Instructions:
In the WARNING section, please add “Primary Provider” so
that they are listed in addition to Home Study Preparers
and USCIS.
Addition of new Supplement 2, Consent to Disclose
Information: We welcome the new addition of the
Supplement 2 for forms I-600A/I-600 and hope it will allow
USCIS and adoption services providers to communicate in a
more efficient manner in their joint service to prospective
adoptive families.

Response:
Thank you for your comment.

Response:
USCIS declines this edit.

Response:
USCIS declines this edit. USCIS regulations do not require disclosure
to the Primary Provider.
Response:
Thank you for the comment.

13