Form G-1606-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2023-0020
60-day FRN Citation (federalregister.gov): 89 FR 25893
Publish Dates: April 12, 2024 – June 11, 2024
Comment
#/Topic
1.
Account
access for
third party
representatives

2.
Online
reschedule
limits and
restrictions;
Allow online
rescheduling
for emergency
cases.

3.
Biometric
collection

Comment (Note: Public comments are copied and pasted
here as written by the commenter, except where a letter is
submitted, and a summary is provided.)
Commenter: Rachel Baskin
Commenter ID: USCIS-2023-0020-0004
While this tool appears helpful it provides no way for
representation during this process. The tool is only permitted
for Individual Account holders, not their attorney
representatives. Moreover, while USCIS may have made
improvements to individual accounts, attorneys are still
unable to use their online accounts and cases that are paper
filed rarely, if ever, populate in the attorney online account.
This tool provides no way for attorneys to effectively assist
and counsel their clients regarding biometrics rescheduling
and requirements. Insofar as federal regulations indicate
that applicants may have counsel, this effectively renders
such counsel ineffective.
Commenter: Emma Mahern
Commenter ID: USCIS-2023-0020-0005
I am an immigration lawyer and often assist clients with
rescheduling their biometrics appointment. An online
scheduling tool would be very helpful and reduce the burden
on applicants and the local ASC centers that process
biometrics since they will more easily be able to direct
individuals to reschedule. Current online tools do not allow
an individual to reschedule if it is within 24 hours of their
appointment time or if the appointment time has passed. It
would be helpful if the online tool allowed for rescheduling
for emergent circumstances. Often an individual may be ill
the day of the appointment, have car trouble on the way, or
be involved in a traffic accident. It is currently very difficult
to reschedule in these circumstances.
Commenter: Erica Tatoian
Commenter ID: USCIS-2023-0020-0006
I write to address the burden imposed by USCIS when it
requires applicants to repeat biometrics appointments.
USCIS has required my clients to appear for biometrics three
times in the last year, two of which are less than a month
apart. The USCIS form provides a phone number for the
UCIS Contact Center, but upon calling that number, the
automated system does not allow a caller to speak to a
representative (i.e., a human being). Instead, the automated
system says that it will terminate the call if one asks to speak
to a representative - and then it does just that. In the two
instances where I've been fortunate enough to speak to a
human being in the Contact Center, they could not provide
any help concerning the repeated biometrics appointments.
They referred me to emailing the National Benefit Center
(the representatives provided two differing email addresses,
mind you), which I did, followed with mailings of the same.
More than two months have elapsed and I have yet to hear

USCIS Response

Response: USCIS made no additional changes to this
information collection based on this comment. The biometric
rescheduling tool is available in the myUSCIS representative
account, under the My Account drop down at the top right of
the screen.

Response: USCIS made no additional changes to this
information collection based on this comment. The online
biometrics rescheduling tool cannot be used to reschedule a
biometrics appointment within 12 hours of the appointment
time, or after the appointment time has already passed. In
these cases, the individual or their representative are directed
to call the USCIS Contact Center.

Response: USCIS made no additional changes to this
information collection based on this comment. USCIS
minimizes the number of times an applicant must submit
biometrics in connection with a benefit request and, to the
extent permitted by applicable law or policies. Repeated
biometrics appointments for an applicant for the same
request are very atypical.

Form G-1606-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2023-0020
60-day FRN Citation (federalregister.gov): 89 FR 25893
Publish Dates: April 12, 2024 – June 11, 2024

4.

Online
reschedule
limits and
restrictions;
Allow online
rescheduling
for emergency
cases.

back from USCIS about the repeated scheduling of
biometrics appointments. In the meantime, my clients minors granted SIJS status - have had to travel more than 12
hours to attend a 15 minute appointment at a cost of $300.
They are now being summoned to come back for another
biometrics appointment less than two months later. It is
beyond reason that USCIS cannot use the same biometrics
information it gathered a year ago, much less two months
ago. Instead, it is imposing a significant burden on people
with limited means who do not live near Application Support
Centers to locate and pay for travel. Allowing the
rescheduling of biometrics appointments online is helpful,
but there must also be a system that allows applicants not
only to speak to a human being, but also provide that person
the authority to make decisions. For example, USCIS's
website refers to mobile biomtetrics appointment, but there is
currently no way to request such an appointment absent
emailing the National Service Center (which, after 2 months,
has not responded to that request). The USCIS biometrics
system is deeply flawed and sets applicants up for failure by
making it impossible for them to comply with USCIS's
requirements.
Commenter: Ahsen Kocaman
Commenter ID: USCIS-2023-0020-0007
Note: The commenter uploaded a letter to regulations.gov at
this link USCIS-2023-0020-0007. USCIS provided the
commenter’s recommendations below.
Two significant restrictions of the Biometric Appointment
Rescheduling Tool are that it cannot be used to reschedule
an appointment that 1) is within twelve hours or 2) has been
rescheduled two or more times. USCIS should decrease the
restriction to allow applicants to reschedule biometrics
appointments closer to the time of the original appointment;
in addition, there should not be a set maximum for
appointments rescheduled with good cause. From a public
policy perspective, the Tool can further reduce burdens on
the immigration population by accounting for emergency
situations that may result in a late appointment reschedule or
multiple appointment reschedules.

5.

Commenter: Immigrant Defenders Law Center
Commenter ID: USCIS-2023-0020-0008
Note: The commenter uploaded a letter to regulations.gov at
this link USCIS-2023-0020-0008. USCIS provided the
commenter’s recommendations below.

Online
reschedule
limits and
restrictions;
Allow for

ImmDef has carefully reviewed the new biometrics
appointment rescheduling tool and believes the tool should
be improved by adding the options to reschedule biometrics
appointments that have already been missed and to request a
waiver of biometrics if they have recently been done in

Response: USCIS made no additional changes to this
information collection based on this comment. Any person
required to appear for a biometric services appointment may,
before the scheduled date and time, request that USCIS
reschedule the appointment for good cause. See 8 CFR
103.2(b)(9). The number of requests for rescheduling is not
limited under 8 CFR 103.2(b)(9); however, for processing
reasons, the rescheduling tool may not accommodate the
third and subsequent rescheduling request. Similarly, for
technical reasons, the tool may not update the USCIS
scheduling system in time if the request is made within the
12-hour window. Therefore, customers are directed to call
the USCIS Call Center.

Response: USCIS made no additional changes to this
information collection based on this comment. A benefit
request is considered abandoned and is denied when a
requestor fails to appear for a biometric services appointment
and USCIS has not received a rescheduling request by the

Form G-1606-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2023-0020
60-day FRN Citation (federalregister.gov): 89 FR 25893
Publish Dates: April 12, 2024 – June 11, 2024
online
rescheduling
for missed
appointments;
and Biometric
waivers.

connection with another USCIS application even if beyond
the 15-month period. ImmDef suggests that USCIS
implements these minor changes to the Biometric
Appointment Rescheduling Tool before reauthorizing it.

appointment time. See 8 CFR 103.2(b)(13)(ii). However,
according to USCIS policy guidance, when a benefit
requestor submits a request to reschedule the appointment
after the appointment date has passed, and if the benefit
request remains pending, USCIS may, in its discretion and
based on the applicant’s circumstances, consider whether the
benefit request has been abandoned. USCIS only accepts
untimely rescheduling requests made to the USCIS Contact
Center and does not accept untimely requests through the
myUSCIS online rescheduling tool.