N-600K 30-day Public Comment Response Matrix

N-600K-010-REV_30-DayPublicCommentMatrix.pdf

Application for Citizenship and Issuance of Certificate Under Section 322

N-600K 30-day Public Comment Response Matrix

OMB: 1615-0087

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Comment
ID/Link
USCIS-20070019-0076

Immigrant Legal
Resource Center

USCIS-20070019-0077
#1.1

Comment

USCIS Response

us ciizens to not want mor eillegal imigrant made into ci�zens.
most of them are here for money, solely for money. they should
be stopped at teh us southern border and told to go back to their
own country. this overwhelming invasion of foreigners to the
cmplete and total depredaton of american ci�zens haveini to pay
in massive amounts for their food, their rent, their telephones,
their transport, their medical care, their schooling is causing
excessively high taxes for american ci�zesn who are being force
dinto porverty. this is an an� american move by a demented
president who seeks to change the character of this country into
ne divided into litle pots of people ﬁgh�ng with each other frm all
ove rth eworld. knid of like th ebalkan states. it is a bad move and
there is no homogeneity i america le� anymore. it will be
destroyed with such a destruc�ve plan as joe biden has in mind. it
needs to be stopped. it is completely detrmental for any counrry
to be so disorganized and have nothin in common. this cpmment
is for the public rcord.
1) USCIS should include on the form a way to alert applica�on
processors and adjudicators that the child at issue for the N600K is about to turn 18 years old such that those
applica�ons can be given priority before the child loses
eligibility.

The commenter expressed an opinion on immigration issues
generally. USCIS is making no changes to the form or instructions
as a result of this comment.

Such a change could include a check box on the form in Part 1,
Informa�on about the Child’s Eligibility, and ﬁling instruc�ons on
how to dis�nguish the applica�on for adjudicators. We note with
gra�tude that the instruc�ons now include a note that all aspects
of the N-600K and related oath must be completed before the
child turns 18, however, given the importance of this informa�on
to applicants, the form should also include a similar measure.
Given the current USCIS backlogs, N-600K applicants about to turn
eighteen will be unfairly disadvantaged if their cases are not
priori�zed. Further, processing �mes across the board for the form

USCIS has internal procedures that use the child’s date of birth to
provide alerts when a child is nearing 18 years of age which is
cause for expediting the application. Therefore, such an alert is
unnecessary in the form itself. USCIS will not make any changes to
the form based on this recommendation.

Immigrant Legal
Resource Center

USCIS-20070019-0077
#1.2

Immigrant Legal
Resource Center

USCIS-20070019-0077
#2

N-600K are inconsistent. The Fiscal Year 2023 USCIS historic case
processing �me for the N-600K is currently seven months, which is
four months longer than the disclaimer on the current and
proposed form that indicates the applica�on should be ﬁled at
least 90 days before the child’s 18th birthday. However, current
processing �mes vary according to USCIS, such that an applicant
would poten�ally need to ﬁle the N-600k several years before
the child at issue turns 18, depending on the ﬁeld oﬃce.
1 Con�nued:
Further, USCIS should update the Policy Manual at 12 USCIS-PM H
to include language priori�zing these applica�ons. Previous
guidance by the Immigra�on and Naturaliza�on Services (INS)
instructed local USCIS oﬃces that immediate priority should be
given to § 322 applica�ons for children approaching their
eighteenth birthdays. We encourage USCIS to add similar
language in USCIS Policy Manual in Volume 12, Part H, Chapter 5:
H. Ci�zenship Interview and Waiver In general, an applicant must
appear in person for an interview before a USCIS oﬃcer a�er ﬁling
an Applica�on for Ci�zenship and Issuance of Cer�ﬁcate Under
Sec�on 322 (Form N600K). This includes the U.S. ci�zen parent or
parents if the applica�on is ﬁled on behalf of a child under 18
years of age.[22]USCIS, however, waives the interview
requirement if all the required documenta�on necessary to
establish the applicant's eligibility is already included in USCIS
administra�ve records or if any of the following documenta�on is
submited along with the applica�on.[23] Adjudicators should give
immediate priority to § 322 applica�ons for children approaching
their eighteenth birthdays.
2) USCIS should include gender-neutral language on the form
and instruc�ons for the child who is the subject of the form.
The proposed form does not include a gender-neutral marker
op�on for the child in Part 3, such as “Another Gender Iden�ty.”
Other recent form revisions from USCIS have included a nonbinary op�on, and the proposed N-600K should follow suit. We
note that the instruc�ons replace binary op�ons “he or she” with
the gender neutral “they” and that the terms “mother” and
“father” have been replaced by “parent” and the form should be

This comment is outside of the scope and USCIS will not make any
changes based on this recommendation.

USCIS made changes to include gender-neutral marker option.

Form N-600K-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regula�ons.gov): USCIS-2007-0019
60-day FRN Cita�on (federalregister.gov): 88 FR 71585
Publish Dates: October 17, 2023 – November 16, 2023
updated accordingly. USCIS should amend the form to include an
op�on for nonbinary gender iden��es and should con�nue this
prac�ce in all form revisions in the future.
Immigrant Legal
Resource Center

USCIS-20070019-0077
#3

3) USCIS should remove redundant informa�on requests
regarding adop�on informa�on.
The informa�on about the adop�on in Part 4 – including the city,
state, and country – is unnecessary on the form itself. Applicants
have to provide proof of the legal adop�on as part of the
applica�on, so the informa�on on the form is redundant.

Immigrant Legal
Resource Center

USCIS-20070019-0077
#4

4) The note in Part 7 should be amended to instruct the
applicants that they should skip Part 7 if the child’s parent is
not deceased.

USCIS considered the comment but will not make changes to the
form based on it. The information requested in the form is
needed for accurate adjudication of the application even if
supporting documentation is provided as proof for it.

USCIS considered the comment and made changes as suggested.
Additionally, similar instructions were added to the Form
Instructions.

If the child’s U.S. ci�zen parent is deceased and you are the child’s
U.S. ci�zen grandparent or the child’s U.S. ci�zen legal guardian,
provide informa�on about yourself in Part 7. If you are the U.S.
ci�zen parent, and you will rely on your U.S. ci�zen parent’s
physical presence in Part 8., please provide your U.S. ci�zen
parent’s (the child’s grandparent’s) informa�on in Part 7. If neither
of these scenarios apply, skip to Part 8.
Immigrant Legal
Resource Center

USCIS-20070019-0077
#5

5) The new ques�ons included in Part 1 regarding the eligibility
of the child should be condensed to aﬀord clarity for U.S.
families sta�oned abroad. We acknowledge the agency’s
eﬀorts to ensure that only those who are eligible ﬁll out the
form and recognize that the aim with these ques�ons is to
determine if the child has already derived U.S. ci�zenship
automa�cally. However, the addi�onal ques�ons may end up
confusing applicants rather than clarifying anything. We
suggest that the ques�ons be condensed to cover all
situa�ons without adding unclear op�ons.

USCIS considered the comment but will not make changes to the
form based on it. The information requested in these questions is
specific to establishing whether the child may have already
acquired U.S. citizenship under INA 320(c), as well as, whether the
child is eligible for naturalization under INA 322(d).

Form N-600K-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regula�ons.gov): USCIS-2007-0019
60-day FRN Cita�on (federalregister.gov): 88 FR 71585
Publish Dates: October 17, 2023 – November 16, 2023
4. Is the child a lawful permanent resident?
5. Are either of the child’s parents (or the spouse of either of the
child’s parents) currently a member of the U.S. armed forces
sta�oned outside the US or a U.S. government employee
sta�oned outside the U.S.?
6. Does the member of the US armed forces have oﬃcial orders
that authorize the child to accompany and reside with the
member of the U.S. armed forces?
7. If the child’s U.S. ci�zen parent is the spouse of the member of
the U.S. armed forces, is the U.S. ci�zen parent authorized to
accompany and reside with the U.S. armed forces member as
provided by the member’s oﬃcial orders?
8. Are either of the child’s parents (or the spouse of either of the
child’s parents) currently a U.S. government employee sta�oned
outside the U.S.?
Immigrant Legal
Resource Center

USCIS-20070019-0077
#6

6) USCIS should amend the language on the proposed
instruc�ons on Page 2, Item 1 to ensure that those who
acquire ci�zenship at birth are accounted for, as well as those
who may have derived ci�zenship through “residing
permanently” instead of admission as a lawful permanent
resident.
Many who acquire U.S. ci�zenship are not lawful permanent
residents as they acquire ci�zenship at or a�er birth depending
upon the law at the �me of their birth. The language should be
amended as follows:
If the child has already acquired ci�zenship automa�cally under
the INA through a U.S. ci�zen parent at birth or a�er birth. If the
child was admited to the United States as a lawful permanent
resident, they may have already acquired ci�zenship; See USCIS

USCIS considered the comment and made changes to the Form
Instructions. USCIS added more general instructions to cover the
situations of acquisition at the child’s birth and after birth.

Naturaliza�on
Working Group

USCIS-20070019-0078
#1.1

While these changes are commendable, the agency can s�ll
improve upon the form. USCIS should include on the form a way
to alert applica�on processors and adjudicators that the child at
issue for the N-600K is about to turn 18 years old such that those
applica�ons can be given priority before the child loses eligibility.
Given the current USCIS backlogs, N-600K applicants about to turn
eighteen will be unfairly disadvantaged if their cases are not
priori�zed. Processing �mes across the board for the form N-600K
are inconsistent. USCIS reports a historic case processing �me for
the N-600K as seven months. However, current processing �mes,
which vary by ﬁeld oﬃce, exceed that es�mate; substan�ally in
some cases. Without a process for priori�za�on, applicants would
need to submit their applica�on several months or even years
before their 18th birthday, which will not be possible for all
applicants.

Naturaliza�on
Working Group

USCIS-20070019-0078
#1.2

In addi�on to amending the form itself, USCIS should update the
Policy Manual at 12 USCIS-PM H to include language priori�zing
these applica�ons. Previous guidance by the Immigra�on and
Naturaliza�on Services (INS) instructed local USCIS oﬃces that
immediate priority should be given to § 322 applica�ons for
children approaching their eighteenth birthdays. We encourage
USCIS to add similar language in USCIS Policy Manual in Volume
12, Part H, Chapter 5 (cita�ons omited):

This comment is outside of the scope and USCIS will not make any
changes based on this recommendation.

H. Ci�zenship Interview and Waiver In general, an applicant must
appear in person for an interview before a USCIS oﬃcer a�er ﬁling
an Applica�on for Ci�zenship and Issuance of Cer�ﬁcate Under
Sec�on 322 (Form N600K). This includes the U.S. ci�zen parent or
parents if the applica�on is ﬁled on behalf of a child under 18
years of age. USCIS, however, waives the interview requirement if

Form N-600K-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regula�ons.gov): USCIS-2007-0019
60-day FRN Cita�on (federalregister.gov): 88 FR 71585
Publish Dates: October 17, 2023 – November 16, 2023
all the required documenta�on necessary to establish the
applicant's eligibility is already included in USCIS administra�ve
records or if any of the following documenta�on is submited
along with the applica�on. Adjudicators should give immediate
priority to § 322 applica�ons for children approaching their
eighteenth birthdays.
Naturaliza�on
Working Group

USCIS-20070019-0078
#2

In addi�on, USCIS should amend the form to include an op�on for
nonbinary gender iden��es. The agency has made strides in this
area by allowing nonbinary gender markers in other proposed
forms including the Form I-485, Applica�on To Register Permanent
Residence or Adjust Status, and the Form N-400, Applica�on for
Naturaliza�on. Adding an op�on for those who do not iden�fy as
male or female is consistent with these changes and should be
incorporated into the proposed N-600K as well.

Naturaliza�on
Working Group

USCIS-20070019-0078
#3

Finally, we want to note that as strong advocates for access to the
beneﬁts of U.S. ci�zenship, many of our organiza�ons previously
have expressed our opposi�on to the $215 fee increase proposed
for Form N-600K in USCIS’s Fee Schedule, published at 88 FR 402
on Jan. 4, 2023. The present ﬁling cost of $1,170 already poses a
signiﬁcant hurdle to poten�al applicants not qualiﬁed for full
waivers. We urge USCIS to give appropriate weight to the
importance of ci�zenship in its fee-se�ng process, and to
reconsider the elevated fees it charges N-600K ﬁlers.

USCIS considered the comment and made changes as suggested
to include a gender-neutral marker option.

This comment is out of scope and USCIS will not make any
changes based on this recommendation as part of this revision
action. For additional information see the fee rule.

File Type	application/pdf
Author	D'Amico, Michael J
File Modified	2023-12-04
File Created	2023-12-04