60-Day Public Comment Response Matrix

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023
Comment #
1.

Commenter ID
0018

2.
0020

(see attachment)

Comment
Commenter: Jean Publiee
Stop allowing this form at all to
freeloaders. the cost of this application
has bankrupted the American citizenry
who are paying for free food, free
school, free medical and free rent for
these leaches from foreign countries.
keep them out. we have done enough.
taxpayers just paid for one illegal
immigrant in an Atlanta hospital who
had almost two million dollars of free
medical care. that is what is happening
to us. we get no free medical care like
that. what the hell is going on anyway.
the citizens of this country cannot
afford this anymore. where are the
goodies for the working people of
America. they are vanishing. Shut down
this anti American program. let them
pay ten thousand times as much for
this form. yes, ten thousand times as
much for this form. why is this agency
making American citizens the dupes
and jerks here. this program is a horror.
you are playing Americans for suckers.
we have no disposable income left and
becoming penniless and homeless. do
you see the homeless Americans on the
streets who cannot afford a home
anymore. keep the foreigners out. shut
down this program of reduced
anything. stop all benefits for
foreigners now.
Commenter: Coalition of
Organizations within the
Naturalization Working Group
See attached file(s)

USCIS Response
Response: This comment is out
of scope for the proposed
revision. The revisions proposed
through this action were limited
to updating the Certification
section and minor grammar
changes.

Response: See Comment
Responses below labeled with
Commenter ID: 0020. The
information in the attachment
from the public comment (0020)
was separated into different

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023
sections in this comment matrix
to address each portion of
information individually.
3.
0020

Commenter: Coalition of
Organizations within the
Naturalization Working Group
A. Clarifying the Instructions for Part 2,
Item 1, Information About Family
Members Filing This Request With You
and Part 3, Item 3, Your Household Size
NWG Members report applicants
having difficulty understanding which
family members need to
be included in the tables in Part 2, Item
1 and Part 3, Item 3. USCIS proposes no
revisions to the Instructions and the
Form for either of these items. NWG
recommends USCIS clarify the
Instructions and accompanying text on
the Form for both of these items,
because they could confuse and
possibly mislead applicants.
USCIS should change the language in
the Instructions and on the Form for
Part 2, Item 1 to make it clear that it is
requesting the names of all other
family members who are both filing
Form N-400 and requesting the
reduced fee.
For Part 3, Item 3, USCIS seeks to elicit
from the applicant: 1) whether the
applicant provides primary financial
support for the household as the head
of the household, 2) if not the
applicant, who the head of household
is, and 3) who the other members of
the household are. If the applicant is
not the head of the household, to
collect the name of the family member

See Comment # 3. – 5.

Response: The revisions
proposed through this action
were limited to updating the
Certification section and minor
grammar changes. USCIS may
consider these
recommendations in a separate
comprehensive revision action
of the I-942 form and
instructions.

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023

4.
0020

who is, USCIS must rely on the
applicant selecting “no” in response to
Part 3, Item 3 and then listing the name
of the head of the household on the
second line of the accompanying table.
As for the other members of the
household, Part 3, Item 3 of the Form
only mentions listing the applicant’s
name or the applicant’s name and the
head of household’s name—making no
mention of other
members of the household. The Form
language should be changed, along
with conforming changes to the
Instructions, to ensure the three
categories of information USCIS wishes
to collect are clearer to applicants.
Commenter: Coalition of
Organizations within the
Naturalization Working Group
B. Need for Online Filing of Form I-942
Providing an online filing option for
Form I-942 would minimize the burden
of the collection of
information. Currently, applicants can
file Form N-400 online or on paper, but
can only file an accompanying Form I942 on paper. Because an applicant can
only file Form I-942 on paper, they
must also file Form N-400 on paper
(see citation on attachment).
While many low-income applicants may
not have access to the computer
technology or broadband internet
access needed to file Form I-942 online,
where that access exists, low-income
applicants should have the same
opportunity to file their Form N-400
online as higher-income applicants do.
We note that filing the Form N-400
online leads to greater efficiency in
adjudication for both applicants and

Response: USCIS appreciates
that providing an online filing
option for Form I-942 would
create efficiencies. USCIS
continues to add new form
options for electronic filing
based on an internal schedule
and agency priorities. USCIS
hopes to provide an online filing
option for Form I-942 in the
future.

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023

5.
0020

6.

0021

USCIS. Efficiency measures should not
be reserved for those of higher
financial means. We urge USCIS to
move forward with providing online
filing for Form I-942 as swiftly as
possible.
Commenter: Coalition of
Organizations within the
Naturalization Working Group
C. Increase Threshold for Eligibility of
Reduced Fee
When USCIS solicited comments on
changes to its fee schedule in January
2023, it asked for comments on the
appropriate level of income that USCIS
should use to determine eligibility for
the reduced fee. We would like to
reiterate comments made at that time
that the requirement that household
income be less than 200 percent of the
federal poverty guidelines still prevents
a significant number of lower- and
moderate-income LPRs from qualifying
for the reduced cost, making
naturalization unaffordable. Thus, we
recommend that the agency adopt an
income threshold of 250% or less for
applicants to qualify for the reduced
fee (see citation on attachment).
Commenter: Duplicate Comment
Submitted by Coalition of
Organizations within the
Naturalization Working Group
See attached file(s)

Response: USCIS cannot adjust
the income eligibility threshold
for a reduced Form N-400 fee in
a form revision action under the
PRA because that FPG
percentage is codified at 8 CFR
103.7(b)(1)(i)(BBB)(1)(Oct. 1,
2020).USCIS is reviewing the
FPG threshold as part of the
USCIS fee rule. However, we are
unable to make a change for this
version of the form.

Response: This is a duplicate
comment submitted to
Commenter ID: 0020. Please
see Comment Responses
labeled with Commenter ID:
0020 for responses to the
attachment in the duplicate
public comment (0021).

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023

7.

0022

(see attachment)

8.

0022

Commenter: Make the Road New York
See attached file(s)

Commenter: Make the Road New York
A. Form I-942, Request for Reduced Fee
should be as clear as possibly in regards
to the form and its instruction.
There are several parts of the proposed
form that invite confusion. For
example, it is likely that Part 2 in the
form (which provides an opportunity
for “family members” to be listed in
addition to the requester for the
reduced fee) and Part 3 (which requires
“household size” and the listing of the
household members) will be confusing
for our community members. The
agency should add more specificity and
clarity on both the form and
instructions, to make it less confusing
for applicants with diverse living
arrangements, such as applicants in
multi-generational homes.
We have worked on cases where, for
example, a client resided with their
spouse, adult son, and elderly mother.
In a case like this, it is likely that
different applicants would struggle to
understand whether the form’s
proposed instructions. To avoid this
problem and any unnecessary

See Comment # 3. – 5.
Response: See Comment
Responses below labeled with
Commenter ID: 0022. The
information in the attachment
from the public comment (0022)
was separated into different
sections in this comment matrix
to address each portion of
information individually.
See Comment # 8. – 9.
Response: The revisions
proposed through this action
were limited to updating the
Certification section and minor
grammar changes. USCIS may
consider these
recommendations in a separate
comprehensive revision action
of the I-942 form and
instructions.

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023

9.

0022

rejections and/or delays in the
adjudicative process, USCIS should be
clear on who should and should not be
listed in Part 2 as compared to Part 3,
and to further provide clarity on who
should/should not certify and sign Part
5, in regards to the family certification.
Commenter: Make the Road New York
B. Form I-942, Request for Reduced Fee
should be more inclusive and available
for online filings.
Currently, applicants seeking to
naturalize and use Form I-942 are at a
disadvantage. These applicants are
unable to submit their application
through the USCIS online system, which
is available to individuals seeking to
naturalize by paying the associated fee
of $725.00.
This limitation is harmful to our lowincome communities as it undermines
their ability to take full advantage of an
expeditiously filing for naturalization.
For example, most recently we helped
a family apply for naturalization online,
as they paid the associated fee and
within the same day received the I797C, Notice of Action and in less than
a week they received their biometrics
receipt. 3
By contrast, one of our other recent
clients, who sought to pay the reduced
fee for her naturalization application,
was barred from filing online and
thereby limited in her submission, all
because of her financial situation. In
fact, because she sought to pay the
reduced fee, she incurred an additional
expense by paying for the postage of
mailing her application, and she had to
wait more than two weeks for her I-

Response: Please see Response
under Comment # 8.

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023
797C, Notice of Action and biometrics
receipt. It seems counterintuitive to
deprive applicants with limited means
the opportunity to avail themselves of
a free online filing system.

10.
0019

(see attachment)

11.
0019

As many more low-income immigrants
seek to finalize their immigration
process and seek naturalization, USCIS
should expand and provide fair access
to the online system, and not impose
restrictive systems to those seeking to
pay a reduced fee.
Commenter: Immigrant Legal Resource
Center
Please find attached the Immigrant
Response: See Comment
Legal Resource Center's comment for
Responses below labeled with
Commenter ID: 0019. The
the proposed changes to Form I-942.
information in the attachment
from the public comment (0019)
was separated into different
sections in this comment matrix
to address each portion of
information individually.
Commenter: Immigrant Legal Resource
Center
We note that for the family member
certification, there is only space for one
family member’s signature where Part
2 allows for the inclusion of more
family members as part of the request.
While we are not opposed to the
elimination of the requirement for
multiple family signatures, USCIS
should provide clarification on both the
form and in the instructions of who
should sign the family certification and
provide the required contact
information. Without this clarification,
it is likely that applicants with larger
families may fill this section out

See Comment # 11. – 12.
Response: USCIS only requires a
signature from the applicant
who is certifying their household
income. Therefore, we have
removed Part 5. Family
Member’s Contact Information,
Certification, and Signature
section from the I-942 Form and
Instructions. Additionally, the
section removed during this
revision which required
additional Family Members’
Signatures will remain removed
from the I-942 Form.

Form I-942-007 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2018-0002
60-day FRN Citation (federalregister.gov): 88 FR 14630
Publish Dates: March 9, 2023 – May 8, 2023

12.
0019

incorrectly, potentially resulting in a
rejection of the fee reduction
application and the underlying
naturalization application. Better
clarification from USCIS will avoid
unnecessary denials and requests for
evidence and allow for more
expeditious processing of the fee
reduction request and underlying
naturalization application.
Commenter: Immigrant Legal Resource
Center
Finally, we renew our request to make
both this form and Form I-912, Request
for Fee Waiver, available for online
filing. Currently, low-income
naturalization applicants who require a
fee waiver or a reduced fee are barred
from applying for naturalization online
as associated applications must be filed
in the same manner. It is our
understanding that USCIS seeks to
encourage the online filing of
naturalization applications as a matter
of efficiency and to reduce processing
times and administrative burdens
associated with paper applications.
While the ability to file paper
applications must be maintained,
insofar as an online filing is available as
an efficiency measure, low-income
applicants should not be shut out of
this measure based on their need for a
fee waiver or fee reduction.

Response: USCIS appreciates
that providing an online filing
option for Form I-942 would
create efficiencies. USCIS
continues to add new form
options for electronic filing
based on an internal schedule
and agency priorities. USCIS
hopes to provide an online filing
option for Form I-942 in the
future.