30-Day Public Comment Response Matrix

Form G-1482-004 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2016-0002
30-day FRN Citation (federalregister.gov): 88 FR 41980
Publish Dates: June 28, 2023 – July 28, 2023
Comment #
1.

Commenter ID
0026

(see attachment)

2.
0026

Comment
Commenter: Catholic Legal Immigration
Network, Inc. (CLINIC)
On behalf of the Catholic Legal
Immigration Network, Inc. (CLINIC), we
submit the attached comments
regarding USCIS-2016-0002 [OMB
Control Number 1615-0140], Agency
Information Collection Activities;
Revision of a Currently Approved
Collection: Citizenship and Integration
Direct Services Grant Program

Commenter: Catholic Legal Immigration
Network, Inc. (CLINIC)
I. The Notice of Funding Opportunity
language for the Regional Hub in future
years should be amended to language
in the FY 2022 NOFO.
CLINIC appreciates the reinstatement of
the regional hub grant for Citizenship
and Integration for fiscal year 2022. The
grant represents an opportunity for
community organizations that have
nascent or non-existing citizenship
preparation programs to gain
experience and receive technical
assistance providing citizenship
preparation classes and naturalization
application assistance. The two-year
period allows for programs to work
towards sustainability in their citizenship
preparation programs after the grant
has ended.
While we are encouraged that USCIS has
decided to continue the Regional Hub
Grant into fiscal year 2023, many of the
requirements in the notice of funding
opportunity (NOFO) changed

USCIS Response
Response: See Comment
Responses below labeled with
Commenter ID: 0026. The
information in the attachment
from the public comment
(0026) was separated into
difference sections in this
comment matrix to address
each portion of information
individually.
See Comment # 2. – 3.
Response:
Re: National organizations
should be eligible –
The Regional Hub program is
intended to support growth at
the city, county, state, or
regional levels and it is
expected that the Principal
Applicant will be actively
involved “on the ground” with
subrecipient organizations.
USCIS will take your input
under advisement as we
develop future NOFOs for this
program to ensure that all
organizations with the
demonstrated capacity to
implement the objectives of
program are able to apply.
Re: requirement that subrecipients have experience –
USCIS does not want to limit
the ability to expand citizenship

Form G-1482-004 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2016-0002
30-day FRN Citation (federalregister.gov): 88 FR 41980
Publish Dates: June 28, 2023 – July 28, 2023
significantly. These changes limit the
number of principal applicant
organizations that may apply for the
grant and exclude national organizations
that work to develop naturalization
program assistance capacity building
across the country. Furthermore, the
language restricts sub-applicants to
organizations that already have one of
the two existing components of a
citizenship preparation program already
in-place and thus limits the capacity
building potential of the grant.
The specific language limiting national
organizations from applying as the
principal applicant are found in two
locations. On page three of the NOFO,
the word ‘national’ is excluded from
‘Objective 1’ defining the geographic
scope of a citizenship network. On page
11, the NOFO requires that the principal
applicant have “Experience with and
knowledge of the immigrant community
to be served” and “An office that is
located and operates in the defined city,
county, or state where the network will
be located.” (see citation on attachment
(1)
Many national organizations are
uniquely qualified to provide technical
assistance for citizenship preparation
programs. They have decades of
experience helping to create and sustain
immigration legal support programs,
including the establishment and growth
of naturalization programs.
Organizations dedicate their resources
by providing in-depth training on
program management, specific legal
immigration topics and processes, and in
foundational legal immigration courses
to help build capacity through

preparation programs to
communities that are remote,
rural, and underserved and will,
therefore, take this point into
consideration as future NOFOs
for this program are developed.

Form G-1482-004 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2016-0002
30-day FRN Citation (federalregister.gov): 88 FR 41980
Publish Dates: June 28, 2023 – July 28, 2023
recognition and accreditation.
Furthermore, national organizations
regularly collaborate with local affiliates
and partners, educating one another on
best practices in immigration legal
services, programs, and practice.
National networks are adept at big
picture planning, implementation at the
local level, allowing affiliates to
differentiate according to local needs,
and planning for sustainability. Finally,
national organizations are highly
experienced at managing complex grant
opportunities involving extensive data
reporting and coordination among
multiple entities.
The 2023 NOFO language for the
regional hub program limits the number
of local programs that can be considered
as sub applicants under the grant. It
requests that the subrecipients or
eligible applicants have an existing
citizenship preparation program with a
need for technical assistance and a
minimum of one year of experience of
providing citizenship instruction and/or
naturalization services. (see citation on
attachment (2))
In contrast, the FY 2022 NOFO language
states the ‘Role of the Sub-Applicant”
does not need to be currently providing
citizenship preparation services or have
previous experience doing so.3 By
excluding inexperienced sub-applicants
in FY 2023 grant opportunity, USCIS
significantly limits the ability to expand
citizenship preparation programs to
communities that are remote, rural, and
underserved. Furthermore, it denies
capacity building opportunities to
organizations that may have robust ESL
programs and immigration legal

Form G-1482-004 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2016-0002
30-day FRN Citation (federalregister.gov): 88 FR 41980
Publish Dates: June 28, 2023 – July 28, 2023

3.
0026

services, but which have not extended
into citizenship classes or significant
naturalization application assistance
Commenter: Catholic Legal Immigration
Network, Inc. (CLINIC)
II. National Organizations should be
allowed to apply for the Hub Grant in
consecutive years.
The FY 2023 NOFO for USCIS’s Hub
Grant does not allow national
organizations the opportunity to apply
for funding in consecutive years.4 There
are a range of benefits of obtaining
funding consecutively. These benefits
include the flexibility for applicants to
refine their strategies and techniques to
address new barriers or challenges as
they arise in the community, among
other opportunities. This presents a
challenge to national organizations such
as CLINIC, since it makes it harder to
continue expanding capacity building in
communities where access to
naturalization and citizenship education
is non-existent or intermittent.
Previously, CLINIC received an award for
$1,000,000 for FY 2022 (DHS-22-CIS010-001). Flowthrough funds were given
to four nonprofits in Paterson NJ,
Pomona CA, Hilo HI, and Plano TX.
CLINIC supports and assists the subapplicants as they expand the
availability of high-quality citizenship
preparation services. All sub-applicants
have established partnerships in the
local community to ensure easier access
to the community. For example, Catholic
Charities of Hawaii is partnering with a
few local community centers to host
citizenship and ESL classes. This is
essential as Hilo is rural and access to
such services can be limited.

Response: USCIS does not
currently make awards under
the Citizenship and Integration
Grant Program to an applicant
if it will result in that applicant
having overlapping periods of
performance for the same
grant type (i.e. two Regional
Hub grants, two CINAS grants,
etc.).

Form G-1482-004 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2016-0002
30-day FRN Citation (federalregister.gov): 88 FR 41980
Publish Dates: June 28, 2023 – July 28, 2023
Additionally, Pomona Economic
Opportunity Center is partnering with
the Motivating Action Leadership
Opportunity “MALO” to engage with the
Tongan community and Gente
Organizada to target specifically parents
whose schedule may limit their ability to
attend citizenship preparation classes.
All subapplicants promote integration in
the classroom and participate with
students in activities outside of the
classroom such as having guest
speakers, visits to local museums, and
celebrating common American holidays.
Most recently, CLINIC has direct
experience with the past National
Capacity Building Grant Program. CLINIC
received a competitive award of
$500,000 for FY 2010-2011 (DHS-10CIS010-002). CLINIC provided flowthrough funds to four nonprofits in
Buffalo, Cleveland, Detroit and Stockton,
CA. CLINIC received a second award for
$600,000 for FY 2011-2012 (DHS-11- CIS010-003). For that award, flow-through
funds were given to four nonprofits in
Worcester, Indianapolis, Syracuse and
Los Angeles. Six of the eight sites were
capacity building start-ups whereas two
(Los Angeles and Stockton) were
expansion efforts. Of the eight sites,
seven immigration programs remain and
have grown since the grants, while four
programs went on to successfully
compete for direct grants from the
Office of Citizenship, or OoC. CLINIC’s
previous National Capacity Building
grants are an excellent example of
sustained capacity building using OoC as
a start-up funder.
Through the series of the HUB grant,
CLINIC has been able to assist a total of

Form G-1482-004 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2016-0002
30-day FRN Citation (federalregister.gov): 88 FR 41980
Publish Dates: June 28, 2023 – July 28, 2023
12 organizations to build and expand
their capacity for citizenship education
and naturalization services. USCIS
should strongly consider allowing
organizations apply for funding in
consecutive years. This structure would
allow the opportunity for sub-applicants
to engage in peer-to-peer conversations,
the ability to share best practices and
learned experiences from one cohort to
the next and vice versa. Additionally,
with funding provided consecutively it
would provide organizations flexibility to
refine their strategies and techniques to
address any new barriers or challenges
that arise in the community. Finally,
allowing national organizations to apply
consecutively could potentially result in
lowered administrative costs, such as
providing trainings and technical
assistance to overlapping cohorts,
allowing more flow-through funding for
local organizations