Privacy Impact Assessment

Privacy Impact Assessment
for the
Benefit Request Intake Process
DHS/USCIS/PIA-061
March 15, 2016
Contact Point
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
(202) 272-8030
Reviewing Official
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security
(202) 343-1717

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Abstract
The U.S. Citizenship and Immigration Services (USCIS) is publishing the Benefit Request
Intake Processing Privacy Impact Assessment (PIA) to discuss the process for initial intake and
receipt of benefit requests submitted by individuals seeking immigration-related benefits provided
in the Immigration and Nationality Act. This PIA considers the privacy risks and applicable
mitigation strategies associated with the collection, use, and maintenance of personally identifiable
information (PII) provided by benefit requestors on all types of benefit request forms and the
associated USCIS data systems used to support the initiation, receipt, and review of all USCIS
paper and electronic filings.

Overview
On March 1, 2003, the U.S. Citizenship and Immigration Services (USCIS) officially
assumed responsibility for the immigration service functions of the U.S. Federal Government. The
Homeland Security Act of 2002 1 dismantled the former Immigration and Naturalization Service
(INS) and separated the agency into three Components within the Department of Homeland
Security (DHS). 2 USCIS was formed to enhance the security and improve the efficiency of
national immigration services by focusing on the administration of benefit applications and
petitions (hereinafter collectively referred to as “benefit request forms”) for immigrants 3 and
nonimmigrants. 4
USCIS oversees lawful immigration and non-immigration to the United States and is
responsible for the administration of immigration, non-immigration, and naturalization
adjudication functions and for establishing immigration, policies, and priorities. In executing its
mission, USCIS performs functions that include the intake, review, and adjudication of the
following types of benefits:
1) Family-Based; 5
2) Employment-Based; 6

1

Pub. L. No. 107-296, 116 Stat. 2135.
U.S. Immigration and Customs Enforcement (ICE) and U.S. Customs and Border Protection (CBP), components
within DHS, now handle immigration enforcement and border security functions.
3
An immigrant is a person who wishes to live in the United States permanently.
4
A nonimmigrant is a person with a permanent residence outside the United States but who wishes to be in the
United States on a temporary basis (i.e., tourism, medical treatment, business, temporary work, or study).
5
An individual may petition for relatives (or future relatives such as a fiancé(e) or a prospective adopted child) to
immigrate to the United States.
6
All foreign workers must obtain permission to work legally in the United States. Each employment category for
admission has different requirements, conditions, and authorized periods of stay. USCIS offers the following
employment-based categories: temporary (nonimmigrant) worker, permanent workers, students and exchange
visitors, and temporary visitors for business.
2

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3) Humanitarian-Based; 7
4) Adoption-Based; 8 and
5) Citizenship and Naturalization-Based. 9
USCIS processes hundreds of different types of forms for the five types of benefit requests above.
However, the intake process is the same for all forms, regardless of benefit request. USCIS is
conducting this programmatic PIA to describe the overall intake process that applies to all benefit
forms.
Because the processing and adjudication of benefit request forms occurs in various stages,
this PIA only addresses the initial intake of information provided by benefit requestors on benefit
request forms and supporting documentation. This includes the receipt and preliminary review of
the benefit request form.
Application Initiation by Benefit Requestor:
In order to begin the benefit request process, an applicant or petitioner (collectively referred
to as “benefit requestor” for the purposes of this document) must complete a benefit request form.10
Individuals have the option to complete the benefit request form by paper or file the form
electronically (if available); both methods collect the same information and payment fee. Upon
completion, individuals submit the completed benefit request form, required supporting
documents, and applicable fee payment or fee waiver. Individuals may submit benefit request
forms electronically or by mail at one of USCIS Service Centers, USCIS domestic and
international Field Offices, or at a USCIS Lockbox (described below). 11
Paper Filings:
A benefit requestor (or his or her representative) mail paper-based forms, required
supporting documents, and applicable fee payment or fee waiver to either a USCIS Lockbox or
USCIS Service Center, depending on the form. Each USCIS form has specific instructions
regarding how and where to file the completed form. Benefit requestors or representatives must

7

USCIS provides a number of humanitarian programs and protection to assist individuals in need of shelter or aid
from disasters, from oppression, for emergency medical issues, and for other urgent circumstances, including:
asylum; refugee; parole; deferred action; temporary protective status; battered spouse, children, and parents; and
victims of human trafficking and other crimes.
8
USCIS is responsible for determining the eligibility and suitability of the Prospective Adoptive Parents
(individuals) looking to adopt and determining the eligibility of the child to immigrate to the United States.
9
Naturalization is the manner in which a person not born in the United States voluntarily becomes a U.S. citizen.
10
Available at www.uscis.gov/forms.
11
International field offices may accept benefit request forms filed in-person by the benefit requestor (such as I130s, I-360, I-600s). These forms are adjudicated overseas and do not get routed through the Lockbox or Service
Centers. They are not issued receipt numbers similar to those filed with the Lockbox/Service Center. Fees are paid
through the US Embassy/Consulate’s State cashier at post.

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file benefit request forms according to the specific instructions provided for each particular form.
Different USCIS facilities accept different types of benefit request forms, so it is important that
forms are submitted to the proper location.
USCIS Service Centers and the National Benefit Center are the USCIS entities that receive
and are responsible for processing the largest variety of benefit request forms. These centers handle
the filing, data entry, and adjudication of certain forms for immigration services and benefits. In
addition, fee receipting is performed by keeping track of fees charged and collected.
Lockbox facilities are operated by a specialized contractor authorized by the Department
of Treasury (Treasury). 12 This contractor manages the intake of USCIS benefit applications and
the collection of associated fees submitted directly by mail. It provides the mechanisms to capture
information electronically from USCIS benefit request forms, deposit associated fees, move the
information to USCIS systems via a system interface, and generate acceptance and rejection
notices to applicants. The contractor is also responsible for preparing the application-related files
in accordance with USCIS guidance and sending the files to the next processing site (i.e., Service
Center). The contractor does not approve or deny benefit request forms received by the USCIS
Lockbox. 13
Electronic Filing:
The benefit requestor and/or his or her representative may choose to submit the benefit
request form online. USCIS allows certain benefit requests forms to be completed and filed by
benefit requestors and/or representatives. To complete the benefit requests process, the individual
must enter valid data into all required fields, pay for the fees associated with the benefit request(s),
and certify that the information that has been submitted is accurate. Prior to completing the online
form, users must establish a unique user account. 14
USCIS Receipt of Application:
USCIS receives paper or electronic benefit request filings depending on the method used
to submit the benefit request form. Every form must also include the correct fee.

12

Not all USCIS forms are submitted directly to a Lockbox facility. Lockbox intake is prioritized for fee-bearing
forms and therefore, not all forms are submitted directly to the Lockbox. Lockbox intake includes a) a secure
environment for fee collections, resulting in improved internal controls; b) centralized and expedited applicationand fee-collection intake; c) reduced operational costs, as Treasury funds a significant portion of the Lockbox
activities; and d) flexibility in addressing issues related to unanticipated surges in volume. The handful of feebearing forms that do not come through Lockbox are based on low-volume or business need (e.g., I-129 cap, I-907
time-sensitivity).
13
See Department of Treasury Financial Management Service Privacy Impact Assessment, available
at https://www.fms.treas.gov/pia/ECP_PIA.pdf.
14
See DHS/USCIS/PIA-056 USCIS Electronic Immigration System (USCIS ELIS) for more information on
electronic filing, available at www.dhs.gov/privacy.

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Paper Filings:
Incoming paper-based forms are received and reviewed by USCIS personnel at a Service
Center,
National
Benefits
Center,
or
Lockbox
facility.
There forms are maintained in a secure area with access limited to specified personnel who sort,
open, and log the forms, and deposit associated fees.
As part of the receipting process, USCIS Service Center, National Benefits Center, and
Lockbox personnel review incoming benefit request forms for basic information only, including
the completion of the following items:
•

Basic biographical information

•

Signature on the form

•

Appropriate USCIS office of the submitted form

•

Correct fee

•

Basic Eligibility (including visa availability) of individual

USCIS rejects improperly filed benefit request formswith a written explanation as to why the form
was rejected and any corrective action needed.
The Lockbox scans an image of the benefit request form and supporting documentation
into an electronic format, as well as performs manual data entry. Lockbox personnel perform data
entry on an as needed basis for forms that do not convert properly in electronic format. Lockbox
personnel compare the physical benefit request form and payment against the data in electronic
format and make corrections as needed. Once the physical form is converted into electronic format,
it is sent to the appropriate case management system. Some files are transmitted via the Electronic
Service Bus 15 and are also ingested into the EDMS Receipt File Repository. 16 The physical benefit
request form is also sent to the appropriate USCIS office to be stored in the paper A-File or Receipt
File. 17 After adjudication, the EDMS A-File Repository retains the electronic copy of the A-File. 18
Electronic Filings:
After preparing a benefit request, the individual or his or her representative formally
submits the benefit request by electronically signing the form and providing payment through an
embedded pay.gov screen. 19 Individuals use pay.gov to make a fee payment directly to Treasury.
15

See DHS/USCIS/PIA-008 Enterprise Service Bus (ESB), available at www.dhs.gov/privacy.
See DHS/USCIS/PIA-003(a), Integrated Digitization Document Management Program and subsequent updates for
more information, available at www.dhs.gov/privacy.
17
Receipt Files are files of immigrant and nonimmigrant benefit request forms that USCIS receives.
18
See supra note 11.
19
The collection of payment information is collected by the Department of Treasury’s Pay.gov system (see
Financial Management Service (FMS) PIA and Revenue Collection Records – Treasury/FMS.017 SORN, 68 FR
16

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USCIS receives payment confirmation information from pay.gov. If pay.gov indicates the payment
information is valid, USCIS accepts the benefit request.
Accepted Filings – Paper and Electronic:
If the benefit requestor properly filed the benefit request form, and the applicable fee
payment is correct, USCIS generally assigns the benefit requestor, an Alien Number (A-Number)20
or matches it with existing A-Number; 21 assigns the application a Receipt Number; and forwards
the benefit request form, to be consolidated in the A-File or Receipt File, to the appropriate USCIS
office. 22 Once successfully filed, the paper and electronic benefit request form is transferred to the
appropriate USCIS case management system for processing. USCIS permanently retains A-Files
– whether paper or electronic.
Regardless of the method used to submit the benefit request form, USCIS sends Form I797C, Notice of Action, to the benefit requestor or his or her representative to confirm receipt of
the form. The Form I-797C is used throughout the benefit request process to communicate receipt,
rejection, transfer, re-open, and appointment notices (fingerprint, biometric capture, interview, or
rescheduled notices). The online filing system also displays a Confirmation Receipt Number, a
link to a PDF version of the form the individual filed, and a Confirmation Receipt Notice.
Benefit requestors may also request text messages or emails to be notified when USCIS
accepts his or her benefit request form. Benefit requestors may request this communication by
submitting the G-1145, E-Notification of Application/Petition Acceptance. 23 The email and text
message alerts the customer that a change has been made to the case and provides the receipt
number of the case that was updated. The email or text message advises the customer to login to
his or her Case Status Service Online (CSSO) portfolio account for more detailed information. 24

5691 published on February 4, 2003), which acts as the clearing-house to collect and process automated clearinghouse and credit-card information.
20
The A-Number is a unique seven-, eight-, or nine-digit number assigned to a non-citizen at the time his or her Afile is created.
21
As a general matter, USCIS does not create an A-Number on a native born U.S Citizen. However, in the event that
a person (native born or naturalized) decides that he or she does not want to be a U.S. citizen, he or she may
formally renounce his or her citizenship through Department of State (DOS). DOS sends a Certificate of Loss of
Nationality to USCIS to be filed in an A-File for this purpose. In such circumstance an A-File will be created.
22
The receipt number is a unique 13-character identifier that USCIS provides for each application or petition it
receives. The agency uses it to identify and track its cases. The receipt number consists of three letters-for example,
EAC, WAC, LIN, SRC, NBC, MSC, YSC, AAO, or IOE-and 10 numbers.
23
The G-1145 is available at www.uscis.gov/forms.
24
See DHS/USCIS/PIA-019(a) Customer Relationship Interface System (CRIS) Update available at
www.dhs.gov/privacy.

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Preliminary Review of Benefit Request Form:
To initiate the adjudication process, USCIS adjudicators review the benefit request form
and supporting evidence to determine benefit eligibility. USCIS may issue written notices to
request missing or additional evidence from individuals who filed for immigration benefits.
To begin the substantive analysis of a benefit request form, the adjudicators verify the
accuracy of the information provided in the benefit request form and ascertain the applicant’s
eligibility for the benefit sought by querying other USCIS, DHS, and external systems. USCIS
may also require an in-person interview with the applicant for certain benefits.
Other published USCIS PIAs available on the DHS Privacy Office webpage cover the
benefit request form analysis and case management, biometric collection, background check
process, and the fraud detection and national security investigation process. These published PIAs
provide an in-depth discussion of these separate processes and evaluate the privacy risks and
mitigation strategies built into each process.

Section 1.0 Authorities and Other Requirements
1.1

What specific legal authorities and/or agreements permit and
define the collection of information by the project in question?

Section 103, et. seq. of the Immigration and Nationality Act (INA) provide the legal
authority for USCIS’s management of the entire benefit request intake process for every type of
benefit request. 25 Each benefit request will have its own specific authority, described in the SORNs
below.

1.2

What Privacy Act System of Records Notice(s) (SORN(s)) apply
to the information?

The following SORNs cover the collection, maintenance, and use of the information of the
benefit request intake and receipt process:
•

25

Alien File, Index, and National File Tracking System, 26 which covers the collection,
use, and maintenance of benefit requests forms and supplemental evidence;

8 U.S.C. § 1103, et. seq.
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 78 FR 69864 (Nov.
21, 2013). The A-File is a paper or electronic-based file which contains official immigration records of aliens or
persons who are not citizens or nationals of the United States (U.S.), as well as U.S. born citizens involved in certain
immigration crimes. A-Files contain all records pertaining to naturalized citizens and any active case of an alien not
yet naturalized, including records created as he or she passes through the U.S. immigration and inspection process
and, when applicable, records related to any law enforcement action against or involving the alien.
26

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•

Inter-Country Adoptions Security, 27 which covers the collection and use of adoption
forms, decisional data, and associated fees for adjudication;

•

Benefits Information System, 28 which covers the collection and use of immigrant and
nonimmigrant benefit request forms, decisional data, and associated fees for
adjudication;

•

Asylum Information and Pre-Screening, 29 which covers the collection and use of
affirmative asylum applications, applications filed with USCIS for suspension of
deportation, special rule cancellation of removal pursuant to the Nicaraguan
Adjustment and Central American Relief Act, 30 credible fear screening cases, 31 and
reasonable fear 32 screening cases; and

•

Collections Records--Treasury/Financial Management Service 33 covers the collection
and use of the benefit request form fees by Lockbox.

1.3

Has a system security plan been completed for the information
system(s) supporting the project?

Yes. The benefit request form intake and receipt process is supported by multiple systems
that are primarily owned by USCIS. Treasury oversees the security authorization process of the
Lockbox Database. The USCIS-owned systems have completed security assessment and
authorization documentation to operate under the Ongoing Authorization program.

1.4

Does a records retention schedule approved by the National
Archives and Records Administration (NARA) exist?

Yes. USCIS uses multiple systems to manage the paper and electronic benefit request form
intake and receipt process.
Paper Filings
The Lockbox Database and associated USCIS case management systems support the
physical benefit request forms. The Lockbox Database retains forms and supporting
documentation for 180 days. Check and money order images are retained up to two years, with an

27

DHS/USCIS-005 Inter-Country Adoptions Security, 72 FR 31086 (June 5, 2007).
DHS/USCIS-007 Benefits Information System, 73 FR 56596 (Sept. 29, 2008).
29
DHS/USCIS-010 Asylum Information and Pre-Screening, 75 FR 409 (Jan. 5, 2010).
30
See Nicaraguan Adjustment and Central American Relief Act, Pub. L. No. 105-100, § 203, 111 Stat. 2193, 2196200 (1997).
31
See 8 U.S.C. § 1225(b)(1)(B).
32
See 8 CFR § 208.31.
33
Treasury/FMS.017 - Revenue Collections Records, 74 FR 23006 (May 15, 2009).
28

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additional five years in archive. Lockbox may also retain data for periods required by a court order,
litigation, or statute.
Information from forms and supporting documentation is also retained in accordance with
the respective case management system retention schedules. Please see the system-specific, USCIS
case management PIAs for relevant retention schedules at www.dhs.gov/privacy.
The paper benefit request form and any supplemental evidence submitted along with the
benefit request is also stored in both the physical [N1-566-08-11] and electronic A-File in
Enterprise Document Management System (EDMS) [N1-566-08-17] because they hold historical
value. A-File records are permanent, whether hard copy or electronic. DHS transfers A-Files to
the custody of NARA 100 years after an individual’s date of birth.
Electronic Filings
NARA approved N1-566-11-02, (October 17, 2011) and N1-566-12-05, (April 17, 2013)
retention schedules to cover USCIS online accounts. Each immigration benefit type processed by
USCIS online has an additional existing retention schedule, which Electronic Immigration System
(USCIS ELIS) applies to each particular case. 34

1.5

If the information is covered by the Paperwork Reduction Act
(PRA), provide the OMB Control number and the agency number
for the collection. If there are multiple forms, include a list in an
appendix.

Information collected through this process is covered by the PRA. A full list of the
immigration forms along with the OMB Control Numbers is available in Appendix A.

Section 2.0 Characterization of the Information
The following questions are intended to define the scope of the information requested and/or collected, as
well as reasons for its collection.

2.1

Identify the information the project collects, uses, disseminates, or
maintains.

USCIS collects information from benefit requestors for immigrant and non-immigrant
benefits. The information collected varies for each form. Generally, USCIS collects the
following:

34

See DHS/USCIS/PIA-056 USCIS Electronic Immigration System (USCIS ELIS) for updated information on
approved schedules available at www.dhs.gov/privacy.

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Information about benefit requestors, beneficiaries, and family members may include, if
applicable:
•

Full Name;

•

Alias(es);

•

Physical and Mailing Addresses;

•

Alien Number;

•

USCIS Online Account Number;

•

Social Security number;

•

Date of Birth;

•

Nationality;

•

Country of Citizenship;

•

Place of Birth;

•

Gender;

•

Marital Status;

•

Military Status;

•

Phone Numbers;

•

Email Address;

•

Immigration Status;

•

Government-issued Identification (e.g., passport, driver’s license):
o Document Type;
o Issuing Organization;
o Document Number; and
o Expiration Date.

•

Signature; and

•

Pay.gov Payment Tracking Number.

Benefit-specific eligibility information about benefit requestor, beneficiaries, and family
members may include:
•

Other Unique Identifying Numbers (e.g., Department of State (DOS)-issued

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Personal Identification Number, ICE Student and Exchange Visitor Number,
USCIS E-Verify Company Identification Number);
•

Arrival/Departure Information;

•

Immigration History (e.g., citizenship/naturalization certificate number, removals,
explanations);

•

Family Relationships (e.g., parent, spouse, sibling, child, other dependents) and
Relationship Practices (e.g., polygamy, custody, guardianship);

•

USCIS Receipt/Case Number;

•

Personal Background Information (e.g., involvement with national security threats,
criminal offenses, Communist party, torture, genocide, killing, injuring, forced
sexual contact, limiting or denying others religious beliefs, service in military or
other armed groups, work in penal or detention systems, weapons distribution,
combat training);

•

Health Information (e.g., vaccinations, referrals, communicable diseases, physical
or mental disorders, prostitution, drug or alcohol abuse);

•

Travel History;

•

Education History;

•

Work History;

•

Professional Accreditation Information;

•

Financial Information (e.g., income, expenses, scholarships, savings, assets,
property, financial support, supporter information, life insurance, debts,
encumbrances, tax records);

•

Supporting documentation as necessary (e.g., birth, marriage, or divorce
certificates, licenses, academic diplomas, academic transcripts, appeals or motions
to reopen or reconsider decisions, explanatory statements, criminal history
documents, and unsolicited information submitted voluntarily by the applicants or
family members in support of a benefit request);

•

Physical Description (e.g., height, weight, eye color, hair color, race, ethnicity,
identifying marks like tattoos or birthmarks);

•

Photographs from Government-issued Identification (i.e., passport, Driver’s
license, and other identification card);

•

Relationships to petitioners, representative, preparers, family members, and

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applicants; and
•

Case processing information such as date applications were filed or received by
USCIS, application/petition status, location of record, other control number when
applicable, and fee receipt data.

Information about Benefit Sponsors may include:
•

Full Name;

•

Gender;

•

Physical and Mailing Addresses:

•

Phone Numbers;

•

Country of Domicile;

•

Date of Birth;

•

Place of Birth;

•

Citizenship Information;

•

Social Security number;

•

Alien Number;

•

USCIS Online Account Number;

•

Employment Information;

•

Financial Information (e.g., income, expenses, scholarships, savings, assets,
property, financial support, supporter information, life insurance, debts,
encumbrances, tax records);

•

Position and Relationship to an Organization (e.g., manager of a company seeking
formal recognition by USCIS);

•

Family Relationships (e.g., parent, spouse, sibling, child, other dependents); and

•

Relationship Practices (e.g., polygamy, custody, guardianship).

Information about Representatives includes:
•

Name;

•

Law Firm/Recognized Organization;

•

Physical and Mailing Addresses:

•

Phone and Fax Numbers;

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•

Email Address;

•

Attorney Bar Card Number or Equivalent;

•

Bar Membership;

•

Accreditation Date;

•

Board of Immigration Appeals Representative Accreditation;

•

Expiration Date;

•

Law Practice Restriction Explanation; and

•

Signature.

Information about Preparers and Interpreters may include:
•

Full Name;

•

Organization;

•

Business State ID Number;

•

Physical and Mailing Addresses:

•

Email Address;

•

Phone Numbers;

•

Relationship to Applicant; and

•

Signature.

Information about Physicians may include:
•

Full name;

•

Physical and Mailing Addresses;

•

Professional Experience;

•

License Number;

•

Other Physician Identifying Number(s);

•

Licensing State and Date of Issuance;

•

Type of Degree/License (i.e., medical doctor, doctor of osteopathy, or clinical
psychologist);

•

Type of Medical Practice;

•

Examination Dates of the Applicant;

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2.2

•

Clinical methods Used to Diagnose Applicant;

•

Email Address; and

•

Signature.

What are the sources of the information and how is the
information collected for the project?

The information collected as part of the benefit request intake and receipt process is
provided by the benefit requestor, accredited representative, form preparer, or interpreter on the
completed benefit request form and from supplemental documentation. The information is either
automatically or manually entered into the appropriate case management system. Please see
Appendix A for a full list of immigration forms and associated systems.

2.3

Does the project use information from commercial sources or
publicly available data? If so, explain why and how this
information is used.

No.

2.4

Discuss how accuracy of the data is ensured.

USCIS relies on the benefit requestor, accredited representative, form preparer, sponsor,
or interpreter to provide accurate information. The aforementioned individuals are required to sign
a statement certifying, under penalty of perjury, that the information included in the benefit request
form and any submitted document are complete, true, and correct.
The Lockbox converts the data on the benefit request form into an electronic format.
Lockbox staff compares the physical benefit request form and payment against the data in
electronic format and makes corrections as needed. Once assigned to a USCIS office, USCIS staff
re-reviews the benefit request form for accuracy.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk that USCIS will manually input data incorrectly.
Mitigation: USCIS has mitigated this risk by developing separate, detailed Standard
Operating Procedures (SOP) for handling information provided by benefit requestors on each
USCIS form. These SOPs include detailed quality control reviews that help to ensure that the
information has been accurately transferred from the paper forms submitted by individuals into the
associated case management systems. These procedures ensure that all data fields are completed
and describe how data entry personnel handle inconsistencies during data entry. The SOPs cover

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every stage of data entry from the time the envelope is opened until the time the data entered into
the associated case management systems is saved.
USCIS allows applicants to make changes to their information in the associated case
management systems during the application analysis and case management process. If an applicant
later determines that a transcription error occurred during the data input process, the individual
may contact the USCIS office where the application was filed and request correction. In addition,
USCIS mitigates this risk by accepting some applications electronically in order to remove the
possibility of data transcription errors. This mitigation is further discussed in the applicable case
management system PIAs.
Privacy Risk: There is a risk of over collection of information for making a benefit
determination.
Mitigation: The USCIS Privacy Office reviews each immigration form during the
development and revision process to ensure that only the minimum amount of information is
collected to determine benefit eligibility through the paper-based and electronic forms. USCIS
requires the information collected to establish identity and determine benefit eligibility of the
applicant, petitioner, or beneficiary. All data elements collected are negotiated with and approved
by the Office of Management and Budget (OMB) during PRA collection review. Furthermore,
USCIS designed its case management systems to collect and store only the information that is
necessary to adjudicate the applications processed by USCIS.
Privacy Risk: There is a risk of inaccurate information provided by the benefit requestor,
representative, form preparer, and interpreter.
Mitigation: USCIS collects information primarily from the benefit requestor or his or her
representative so that the most current and accurate information about the benefit requestor and
beneficiary is available to USCIS. The aforementioned individuals are required to sign a statement
certifying, under penalty of perjury, that the information included in the benefit request form and
any submitted document are complete, true, and correct. In order to verify the information provided
by the benefit requestor or representative, USCIS performs necessary background and national
security checks. USCIS personnel may also check other sources to verify information provided by
the benefit requestor or representative. The information verification process is further discussed in
the respective case management system PIAs.

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Section 3.0 Uses of the Information
The following questions require a clear description of the project’s use of information.

3.1

Describe how and why the project uses the information.

The information collected on the benefit request form is used to determine an individual’s
eligibility for the requested benefit and to account for the associated fees.
The information from the accepted benefit request form is then either manually entered or
electronically transmitted into the respective case management system. 35 To initiate the
adjudication process, USCIS adjudicators review the benefit request form and supporting evidence
to determine benefit eligibility. USCIS may issue written notices to request missing or additional
evidence from individuals who filed for immigration benefits.
Certain eligibility requirements must be met before USCIS may consider a benefit request
form for possible approval. To begin the substantive analysis of a benefit request form, the
adjudicators verify the accuracy of the information provided in the benefit request form and
ascertain the applicant’s eligibility for the benefit sought by querying other USCIS, DHS, and
external systems. USCIS may also require an in-person interview with the applicant for certain
benefits.
USCIS will also use the information on the benefit request form to generate correspondence
including accept and reject notices.

3.2

Does the project use technology to conduct electronic searches,
queries, or analyses in an electronic database to discover or locate
a predictive pattern or an anomaly? If so, state how DHS plans to
use such results.

No.

3.3

Are there other components with assigned roles and
responsibilities within the system?

No.

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that due to the number of supporting systems, information
is copied across multiple USCIS systems.
Mitigation: This risk is not mitigated. USCIS has made the business decision to develop
35

USCIS owns and uses several case management systems to successfully complete the benefit adjudication
process. Please see www.dhs.gov/privacy for the complete list of USCIS case management PIAs.

Privacy Impact Assessment
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different information technology systems for different benefit request forms and different stages
of the benefit intake process. This business decision has resulted in multiple copies of the A-File
stored across multiple systems and in multiple forms – both electronic and paper. This process
heightens the risk of unauthorized disclosure or loss of sensitive personally identifiable
information.
Privacy Risk: There is a risk that information may be used outside of the original purpose
collection, which is to determine benefit eligibility.
Mitigation: This risk is partially mitigated. In order to process the magnitude of benefit
eligibility requests that USCIS receives, information collected on the benefit request forms is used
not only to verify the completeness of the form, make a payment, and determine the benefit
eligibility of the benefit requestor, beneficiaries, and family members. USCIS also uses the
information to identify and track possible benefit fraud, public safety concerns, and national
security concerns as described in other published PIAs. 36 These uses are consistent with the
purpose of collection for benefit eligibility determination, and consistent with overall USCIS
mission to preserve the integrity of the U.S. immigration process.
All records are protected from unauthorized access and use through appropriate
administrative, physical, and technical safeguards that include restricting access to authorized
personnel who have a need-to-know. USCIS limits access to PII by employing role-based access.
All USCIS employees and contractors are thoroughly trained regarding the use of the database and
the sensitivity of the information. Additionally, all USCIS employees and contractors are required
take the annual security and privacy awareness training.

Section 4.0 Notice
The following questions seek information about the project’s notice to the individual about the information
collected, the right to consent to uses of said information, and the right to decline to provide information.

4.1

How does the project provide individuals notice prior to the
collection of information? If notice is not provided, explain why
not.

The instructions on each benefit request form contain a Privacy Act Statement and
instructions on how to file, where to send, and how to contact USCIS if there is a problem. Each
Privacy Act Statement provides notice to individuals about USCIS’s authority to collect
information, the purposes of data collection, routine uses of the information, and the consequences
of declining to provide the requested information to USCIS. Individuals are provided general
36

See DHS/USCIS/PIA-013-01 Fraud Detection and National Security Directorate, available at
www.dhs.gov/privacy.

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notice through the publication of this PIA and the associated SORNs identified in Section 1.2 of
this PIA. Additional information, including Frequently Asked Questions (FAQ), about certain
benefit types are available on the USCIS webpage or individuals may contact the National
Customer Service Center (NCSC). 37

4.2

What opportunities are available for individuals to consent to
uses, decline to provide information, or opt out of the project?

All USCIS benefit requests are voluntary. However, to intake and receipt the large volume
of requested benefits that USCIS receives, USCIS requires individuals to complete the benefit
request form, provide supplemental evidence, and pay the associated fees, if not waived. This
information is critical for USCIS to accept and process forms in order to make an adjudication
decision to grant or deny an immigration benefit. Failure to provide the requested information
prohibits USCIS from processing and properly adjudicating the benefit request form and thus
precludes the applicant from receiving the benefit.

4.3

Privacy Impact Analysis: Related to Notice

There is no privacy risk associated with notice because USCIS provides notice to
individuals through a Privacy Act Statement, this PIA, associated SORNs, the USCIS website,
benefit specific FAQs, and through the NCSC.

Section 5.0 Data Retention by the project
The following questions are intended to outline how long the project retains the information after the initial
collection.

5.1

Explain how long and for what reason the information is retained.

USCIS uses multiple systems to manage the paper and electronic benefit request form
intake process.
Paper Filings
The Lockbox Database retains forms and supporting documentation up to 180 days for
review and research purposes. USCIS also retains the information for Lockbox to have the
capability to regenerate I-797C notices. Check and money order images are retained up to two
years, with an additional five years of data (i.e., check and money order images and payment
information) in archive. The Lockbox also has the ability to retain data for USCIS that may require
a longer retention due to court order, litigation, or statute.

37

The NCSC serves as the primary method for customers to telephonically request assistance with applications and
petitions, regulatory information, and up-to-date status information on benefit applications and petitions. See
DHS/USCIS/PIA-054 NCSC, available at www.dhs.gov/privacy.

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Information from forms and supporting documentation is also retained in accordance with
the respective case management system retention schedules. Please see the USCIS case
management PIAs for more information about the retention of data.
The paper benefit request form and any supplemental evidence submitted along with the
benefit request is also stored in both the physical [N1-566-08-11] and electronic A-File in EDMS
[N1-566-08-17] because they hold historical value. A-File records are permanent, whether hard
copy or electronic. DHS transfers A-Files to the custody of NARA 100 years after the individual’s
date of birth.
Electronic Filings
USCIS has drafted a series of retention schedules to cover different types of data in USCIS
ELIS. Currently, two of those schedules have been finalized and signed by the Archivist. The
remaining schedules are being actively worked with NARA. 38
The majority of customer data in USCIS ELIS is not yet covered by a finalized retention
schedule. USCIS expects NARA to approve permanent retention for USCIS ELIS customer data
because it replaces data that would have been in the A-File if filed via paper. Data includes
individual customer account data of immigrants, as well as the case data pertaining to their
requests. The A-File is permanently retained for historical purposes.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a risk that USCIS may retain information longer than is necessary
to perform relevant immigration functions.
Mitigation: Although there is always an inherent risk with retaining data for any length of
time, data retention periods for the associated systems are consistent with the concept of retaining
data to maintain a complete and accurate history of an individual’s immigration interaction with
USCIS for future benefit requests. The NARA approved retention schedules ensure that the
agency is not maintaining information longer than necessary.

38

See DHS/USCIS/PIA-056 USCIS Electronic Immigration System (USCIS ELIS) for updated information on
approved schedules available at www.dhs.gov/privacy.

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Section 6.0 Information Sharing
The following questions are intended to describe the scope of the project information sharing external to the
Department. External sharing encompasses sharing with other federal, state and local government, and private sector
entities.

6.1

Is information shared outside of DHS as part of the normal
agency operations? If so, identify the organization(s) and how the
information is accessed and how it is to be used.

Yes. For certain benefits requests, individuals are required to submit their applications to a
USCIS Lockbox facility, which is operated by a Department of Treasury contractor, for initial
processing. USCIS uses Lockbox operations to handle fee collection, data entry, and forms
processing of selected immigration benefit request forms. 39 The physical forms and other
associated evidence received in the transaction are packaged and sent to the respective Service
Centers or National Benefits Center.

6.2

Describe how the external sharing noted in 6.1 is compatible with
the SORN noted in 1.2.

The USCIS Lockbox operations provide a facility with the means to receive and perform
initial processing of USCIS benefit request forms submitted by benefit requestors. The sharing of
data with the Lockbox is covered by Routine Use F of the Benefits Information System 40 SORN,
which permits the sharing of data to contractors and their agents to accomplish the benefit receipt
and intake process.
However, USCIS will include a specific Routine Use for sharing with Treasury in the
forthcoming Benefits Information System SORN update.

6.3

Does the project place limitations on re-dissemination?

Yes. USCIS has a Memoranda of Understanding (MOU) in place with the Department of
Treasury, as well as the designated contractor, which places limitations on re-dissemination. The
Lockbox processes confidential information the disclosure of which to unauthorized individuals
could cause substantial harm to the benefit requestor. When sharing information with parties
outside of USCIS, the same specifications related to security and privacy that are in place apply to
Lockbox. Access to records is governed by need-to-know criteria that demand the Lockbox
39

Pursuant to 12 U.S.C. §§ 265, 266, 1464(k), 1725(d), 1789a, the Secretary of the Treasury has the authority to
designate financial institutions to be depositaries and financial agents of the U.S. Government. Pursuant to 31 U.S.C.
§ 3720(a), executive agencies of the government are required to provide for the collection and timely deposit of
money by the use of procedures which may include lockbox collection services. Financial Management Service
(FMS) is exercising its authority by using designated depositaries to support government-wide lockbox collection
services.
40
DHS/USCIS-007 Benefits Information System, 73 FR 56596 (Sept. 29, 2008).

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demonstrate the mission related need for the data before access is granted. The reason for the
access, an intended use consistent with the receiving agency’s purpose, USCIS’s justification for
collecting the data, and an acknowledgement that the receiving agency will not share the
information without USCIS’s permission are included in the terms of the MOU.

6.4

Describe how the project maintains a record of any disclosures
outside of the Department.

USCIS requires Lockbox personnel to sign a non-disclosure statement before the
information is accessed and released. Additionally, USCIS maintains audit trail logs and uses them
to identify transactions performed. A file is created for each form type. A header file is created
containing the count of records for each form type. A manifest file is generated containing an
accounting records for each transaction processed in the batch. A remittance file is generated
containing a record for each remittance received. A history file is created containing a record for
each history action performed by the Lockbox.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: Sharing can increase the risk of misuse, unauthorized access to, or
disclosure of information.
Mitigation: USCIS and Treasury conduct electronic sharing of benefit request data over
secure Government networks to facilitate Lockbox services, including the collection of fees and
receipting of benefit request forms. All Lockbox personnel are trained on the appropriate use and
the safeguarding of data. In addition, USCIS policies and procedures are in place to prevent the
unauthorized dissemination of the information, thereby reducing these risks. Further, any
disclosure must be compatible with the purpose for which the information was originally collected
and only authorized users with a need-to-know may have access to the information associated with
the benefit request intake and receipt process. As discussed above, the associated systems (i.e.,
Lockbox Database and ESB2 LIS) maintain a record of disclosure of information in accordance
with the routine use or an information sharing agreement. USCIS keeps a record in system audit
trail logs, which are maintained to identify all user transactions.

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Section 7.0 Redress
The following questions seek information about processes in place for individuals to seek redress which may
include access to records about themselves, ensuring the accuracy of the information collected about them, and/or
filing complaints.

7.1

What are the procedures that allow individuals to access their
information?

USCIS gives benefit requestors numerous opportunities during and after the completion of
the benefit request process to update and correct information they have provided and to respond to
information received from other sources. In addition, USCIS provides all benefit requestors an
opportunity to refute benefit determinations during the in-person interview process.
A benefit requestor may also gain access to his or her USCIS records by filing a Privacy
Act request. If an individual would like to file a Privacy Act request to view his or her USCIS
record, he or she may mail the request to the following address:
National Records Center
Freedom of Information Act (FOIA)/Privacy Act Program
P. O. Box 648010
Lee’s Summit, MO 64064-8010
Further information about Privacy Act and FOIA requests for USCIS records is available at
http://www.uscis.gov.

7.2

What procedures are in place to allow the subject individual to
correct inaccurate or erroneous information?

Individuals should submit requests to contest or amend information as discussed in Section
7.1. The requestor should clearly and concisely state the information being contested, the reason
for contesting or amending it, and the proposed amendment. The requestor should also clearly
mark the envelope, “Privacy Act Amendment Request.” The record must be identified in the same
manner as described for making a request for access.

7.3

How does the project notify individuals about the procedures for
correcting their information?

USCIS notifies individuals of the procedures for correcting their information in this PIA,
Privacy Act Statements, and through the USCIS website. Specifically, the SORNs set forth in
Section 1.2 provide individuals with guidance regarding the procedures for correcting information.
The Privacy Act Statements, including notice of an individual’s right to correct information, are
also contained on the instructions to immigration forms published by USCIS.

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7.4

Privacy Impact Analysis: Related to Redress

There is no risk associated with redress in relation to the Benefit Intake and Receipt. USCIS
provides individuals with access, amendment, or correction to their records when requested
through a FOIA or Privacy Act request.

Section 8.0 Auditing and Accountability
The following questions are intended to describe technical and policy based safeguards and security
measures.

8.1

How does the project ensure that the information is used in
accordance with stated practices in this PIA?

USCIS ensures that practices stated in this PIA comply with internal USCIS policies,
including the USCIS privacy policies, SOPs, information sharing agreements, orientation and
training, rules of behavior, and auditing and accountability.

8.2

Describe what privacy training is provided to users either
generally or specifically relevant to the project.

USCIS employees and contractors are required to complete annual Privacy and Computer
Security Awareness Training to ensure their understanding of proper handling and securing of PII.
Privacy training addresses appropriate privacy concerns, including Privacy Act obligations (e.g.,
SORNs, Privacy Act Statements). The Computer Security Awareness Training examines
appropriate technical, physical, and administrative control measures. Leadership at each USCIS
office is responsible for ensuring that all federal employees and contractors receive the required
annual Computer Security Awareness Training and Privacy Training.

8.3

What procedures are in place to determine which users may
access the information and how does the project determine who
has access?

USCIS uses role-based access controls and enforces a separation of duties to limit access
to only those individuals who have a need-to-know in order to perform their duties. Each
operational role is mapped to the set of system authorizations required to support the intended
duties of the role. The mapping of roles to associated authorizations enhances adherence to the
principle of least privilege. Authorized users are broken into specific classes with specific access
rights. This need-to-know is determined by the respective responsibilities of the employee. These
are enforced through DHS and USCIS access request forms and procedures.

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8.4

How does the project review and approve information sharing
agreements, MOUs, new uses of the information, new access to the
system by organizations within DHS and outside?

USCIS has a formal review and approval process in place for new sharing agreements. Any
new use of information or new access requests for the system must go through the USCIS Change
Control Process and must be approved by the proper authorities of this process, such as the USCIS
Privacy Officer, Chief of Information Security Officer, Office of Chief Counsel, and the respective
Program Office.

Responsible Officials
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
Department of Homeland Security

Approval Signature

Original signed copy on file with the DHS Privacy Office.
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security

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Appendix A
USCIS Immigration Forms and Associated OMB Control Numbers

Form
Number

Form Name

OMB Control
Number

Case
Management
System

I-102

Application for Replacement/Initial Nonimmigrant
Arrival-Departure Document

1615-0079

CLAIMS 3

I-129

Petition for Nonimmigrant Worker

1615-0009

CLAIMS 3

Petition for CNMI-Only Nonimmigrant Transition
Worker

1615-0111

CLAIMS 3

I-129F

Petition for Alien Fiancé(e)

1615-0001

CLAIMS 3

I-129S

Nonimmigrant Petition Based on Blanket L Petition

1615-0010

CLAIMS 3

I-130

Petition for Alien Relative

1615-0012

CLAIMS 3

1615-0013

CLAIMS 3 &
CAMINO

I-129CW

I-131

Application for Travel Document

I-134

Affidavit of Support

1615-0014

CAMINO

I-140

Immigrant Petition for Alien Workers

1615-0015

CLAIMS 3

I-191

Application for Advance Permission to Return to
Unrelinquished Domicile

1615-0016

CLAIMS 3

I-192

Application for Advance Permission to Enter as
Nonimmigrant

1615-0017

CLAIMS 3

I-193

Application for waiver of Passport and/or Visa

1651-0107

CLAIMS 3

I-212

Application for Permission to Reapply for
Admission into the U.S. after Deportation or
Removal

1615-0018

CLAIMS 3

Notice of Appeal to the Administration

1615-0095

CLAIMS 3

I-360

Petition for Amerasian, Widower or Special
Immigrant

1615-0020

CLAIMS 3

I-361

Affidavit of Financial Support and Intent to Petition
for PL 97-359 Amerasian

1615-0021

A-File

I-363

Request to Enforce Affidavit of Financial Support
and Intent to Petition under PL 97-359

1615-0022

A-File

I-407

Record of Abandonment of Lawful Permanent
Resident Status

1615-0130

CLAIMS 3 &
CAMINO

I-290B

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I-485
I-485
Supplement
A

Application to Register Permanent Residence or
Adjust Status and Supplement A to Form I-485

CLAIMS 3

1615-0023

CLAIMS 3

1115-0221

CLAIMS 3

1615-0024

CLAIMS 3

1615-0023

CLAIMS 3

Adjustment of Status Under Section 245(i)

I-485
NACARA Supplement to Form I-485 Instructions
Supplement B
I-485C

1615-0023

HRIFA Supplement to Form I-485

I-485
Instructions for I-485, Supplement E
Supplement E
I-508

Waiver of Rights, Privileges, Exemptions and
Immunities

1615-0025

A-File

I-526

Immigrant Petition by Alien Entrepreneur

1615-0026

CLAIMS 3

I-539

Application to Extend/Change Nonimmigrant Status

1615-0003

CLAIMS 3

I-566

Inter-Agency Record of Individual requesting
Change/Adj. To or from A or G Status

1615-0027

CLAIMS 3

I-600, I-600A
and
Supplement 1

Petition to Classify Orphan as an Immediate Relative
and Application for Advance Processing of Orphan
Petition

1615-0028

ACMS &
CAMINO

I-601

Application for Waiver of Grounds of Inadmissibility

1615-0029

CLAIMS 3

Application for Provisional Unlawful Presence
Waiver

1615-0123

CLAIMS 3

I-602

Application by Refugee for Waiver of Grounds of
Excludability

1615-0069

CAMINO

I-612

Application for Waiver of Foreign Residence
Requirement of Sec. 212(e) of the INA

1615-0030

CLAIMS 3

I-643

HHS Statistical Data for Refugee/Asylee Adjusting
Status

16150070

CLAIMS 3

I-687

Application for Status as a Temporary Resident
under Sec. 245A of the INA

1615-0090

CLAIMS 3

I-690

Application for Waiver of Grounds of Inadmissibility

1615-0032

CLAIMS 3

I-693

Report of Medical Examination and Vaccination
Record

1615-0033

A-File

I-694

Notice of Appeal of Decision

1615-0034

CLAIMS 3

I-698

Application to Adjust Status from Temporary to
Permanent Resident

1615-0035

CLAIMS 3

I-601A

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I-730

Refugee/Asylee Relative Petition

1615-0037

CLAIMS 3

I-751

Petition to Remove Conditions on Residence

1615-0038

CLAIMS 3

1615-0040

CLAIMS 3
USCIS ELIS

1615-0042

A-File

I-765, I765WS

Application for Employment Authorization

I-777

Application for Issuance or Replacement of Northern
Mariana Card

I-800

Petition to Classify Convention Adoptee as an
Immediate Relative

ACMS

Application for Determination of Suitability to Adopt
a Child from a Convention Country

ACMS

I-800A
I-817

Application for Family Unity

1615-0005

CLAIMS 3

I-821

Application for Temporary Protected Status

1615-0043

CLAIMS 3

Consideration of Deferred Action for Childhood
Arrivals

1615-0124

CLAIMS 3
USCIS ELIS

I-824

Application for Action on an Approved Application
or Petition

1615-0044

CLAIMS 3

I-829

Petition by Entrepreneur to Remove Conditions

1615-0045

CLAIMS 3

I-854

Interagency Alien Witness and Informant Record

1615-0046

A-File

I-864

Affidavit of Support under Section 213A of the Act
and Notification of Reimbursement of Means-Tested
Benefits

1615-0075

CLAIMS 3

I-864A

Contract between Sponsor and Household Member

1615-0075

CLAIMS 3

I-864EZ

Affidavit of Support Under Section 213A of the Act

1615-0075

CLAIMS 3

I-864W

Intending Immigrant’s Affidavit of Support
Exemption

1615-0075

CLAIMS 3

I-865

Sponsor's Notice of Change of Address

1615-0076

CLAIMS 3

I-881

Application for Suspension of Deportation or Special
Rule Cancellation of Removal

1615-0072

RAPS

I-90

Application to Replace Permanent Resident Card

1615-0072

USCIS ELIS

I-905

Application for Authorization to Issue Certification
for Health Care Workers

I-907

Request for Premium Processing Service

I-821D

I-910

Application for Civil Surgeon Designation

CLAIMS 3
1615-0048

CLAIMS 3

1615-0114

NPWR

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I-912

Request for Fee Waiver

1615-0116

CLAIMS 3

I-914

Application for T Nonimmigrant Status; Application
for Immediate Family Member of T-1 Recipient; and
Declaration of Law Enforcement Officer for Victim
of Trafficking in Persons

1615-0099

CLAIMS 3

1615-0099

CLAIMS 3

1615-0099

CLAIMS 3

1615-0104

CLAIMS 3

1615-0104

CLAIMS 3

1615-0104

CLAIMS 3

Notice of Immigration Pilot Program

1615-0061

iCLAIMS

Supplement to Form I-924

1615-0061

iCLAIMS

I-929

Petition for Qualifying Family Member of a U-1
Nonimmigrant

1615-0106

CLAIMS 3

N-300

Application to File Declaration of Intention

1615-0078

CLAIMS 4

N-336

Request for Hearing on a Decision in Naturalization
Proceedings under Section 336

1615-0050

CLAIMS 4

Monthly Report Naturalization Papers

1615-0051

CLAIMS 4

1615-0052

CLAIMS 4
ELIS

Form I-914,
Supplement
A
Form I-914,
Supplement
B,
I-918

Application for Immediate Family Member of T-1
Recipient
Declaration of Law Enforcement Officer for Victim
of Trafficking in Persons
Application for U Nonimmigrant Status Application
for U Nonimmigrant Status; Application for
Immediate Family Member of U-1 Recipient; and U
Nonimmigrant Status Certification

Form I-918,
Petition for Qualifying Family Member of U-1
Supplement
Recipient
A
Form I-918,
U Nonimmigrant Status Certification
Supplement B
I-924
I-924A

N-4
N-400

Application for Naturalization

N-426

Request for Certification of Military or Naval
Service

1615-0053

CLAIMS 4

N-470

Application to Preserve Residence for Naturalization

1615-0056

CLAIMS 4

N-565

Application for Replacement
Naturalization/Citizenship Document

1615-0091

CLAIMS 3

N-600

Application for Certificate of Citizenship

1615-0057

CLAIMS 4

Application for Citizenship

1615-0087

CLAIMS 4

Application for Posthumous Citizenship

1615-0059

CLAIMS 3

N-600K
N-644

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N-648
G-28

Medical Certification for Disability Exceptions
Notice of Entry of Appearance as Attorney or
Accredited Representative

1615-0060

CLAIMS 4

1615-0105

All case
management
systems