G-1608-001 60 Day FRN Comment Matrix

Form G-1608-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2024-0003
60-day FRN Citation (federalregister.gov): 89 FR 25892
Publish Dates: April 12, 2024 – June 11, 2024
Comment
Comment
(Note:
Public
comments
are
copied and pasted here as written by
Item #
1.

2.

USCIS Response

the commenter, except where a letter is submitted, and a
summary is provided.)

Commenter: jean publie
Commenter ID: USCIS-2024-0003-0010
i am totally against tax[ayes payingt for this program and
do nto think it helps america at all. i find this dept to be
one that works for foreigners and against the interests of
the american people, who 70% of want the borders shut
down and no more foeigners coming across and want the
vandals you have let come into this countty be transportd
all over for their free telephones, free medical care, free
education, free transport, free rent and free food to go back
to teir own country and start paying for those things again.
we have our own american citizens who cant get jobs and
cant get housing or anything because they are being
soaked to pay for these foreign fre3eloaders. where the hell
do you get off hurting american citizens this way with this
high taxation for these foreigners and soaking us all to
death with high taxes and we cant et houwsing, or
prescription drugs. oru food prices are going up up up
because we are being taxed to pay for 20 mlllion
fre3eloaders here taking advantage of us. it all sucks. it
needs change. i am not in favor of this regulatory agency at
all. it is anti american to the max. shut i8t down. and stop
teh border invation.
Commenter: WhoPoo App
Commenter ID: USCIS-2024-0003-0011
Build the wall. At the start of 2023, the net cost of illegal
immigration for the United States – at the federal, state,
and local levels – was at least $150.7 billion. FAIR arrived
at this number by subtracting the tax revenue paid by
illegal aliens – just under $32 billion – from the gross
negative economic impact of illegal immigration, $182
billion. In 2017, the estimated net cost of illegal migration
was approximately $116 billion. In just 5 years, the cost to
Americans has increased by nearly $35 billion. Illegal
immigration costs each American taxpayer $1,156 per year
($957 after factoring in taxes paid by illegal aliens). Each
illegal alien or U.S.-born child of illegal aliens costs the
U.S. $8,776 annually. Evidence shows that tax payments by
illegal aliens cover only around a sixth of the costs they
create at all levels in this country. A large percentage of
illegal aliens who work in the underground economy
frequently avoid paying any income tax at all. Many illegal
aliens actually receive a net cash profit through refundable
tax credit programs.

USCIS has determined that this comment falls
outside the scope of this information collection
based on the criteria published in the Federal
Register Notice.

USCIS has determined that this comment falls
outside the scope of this information collection
based on the criteria published in the Federal
Register Notice.

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Form G-1608-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2024-0003
60-day FRN Citation (federalregister.gov): 89 FR 25892
Publish Dates: April 12, 2024 – June 11, 2024
3.

Commenter: NALEO Educational Fund
Commenter ID: USCIS-2024-0003-0012

(Note: The commenter uploaded a letter to regulations.gov at
this link USCIS-2024-0003-0012 and provided the
commenter’s recommendations below as item numbers 3.a.-3.n.)

3.a.

3.b.

This is particularly concerning because recipients of
USCIS’s Citizenship Instruction and Naturalization
Application Services grants, whose staff will be asked to
respond to these surveys and interviews, already provide
very thorough reports that exceed what is typically
required in exchange for equivalent or greater support
from private sector donors.
In addition, the USCIS envisions that survey respondents
and interview participants will include LPR participants in
grantee recipient programs. Many of them face some of the
most significant hurdles to naturalizing, and are among
those least likely to have the time and other resources,
including secure and reliable on-line connectivity, that the
agency is expecting of respondents.
…Similarly, although a person with immediate and deep
knowledge of the topic and native English ability might
complete one of the proposed instruments in the projected
time, it is very unlikely that most respondents will. The
surveys ask them to recall experiences that are three or
more years past, and for individualized reflection and
assessment rather than rote recitation of facts. Many
prospective respondents were not educated in English and
may read and write more slowly than in their native
languages.
In our organization's experience, providing meaningful and
accurate answers to the range of inquiries included in
USCIS's proposed survey and interview instruments will
frequently require more than the estimated 20 minutes for
each survey and 30 for each interview.
…Three of the four proposed interviews exceed this length
at a glance, and closer inspection reveals that each
includes questions with several parts and follow-ups that
probe into respondents’ answers and will prolong sessions.

USCIS will not make changes to this information
collection based on this comment. USCIS confirms
that no grantee staff or program participant is
obligated or compelled to respond to or participate
in the survey. As voluntary participants, any
respondent may decline to answer any question or
discontinue taking the survey or interview. In the
same manner, the interviewer can skip questions that
are difficult to understand or comprehend. The
evaluation contains no new reporting requirements
and an organization’s and/or individual’s decision to
participate in the voluntary surveys and interviews
will have no impact on any current or future
potential grants that organizations have received
from USCIS or any pending immigration requests
individuals have pending with USCIS.

The estimated time for completion was pre-tested
with program participants and grantees in December
2023 and January 2024. There are several reasons to
believe the timeframe stated in the instruments is
correct: a) pre-testing generated completion time
estimates for the instruments based on experiences
of target audience members providing responses; b)
if the respondent does not have an answer or cannot
recollect the facts, they can skip the survey question
or state do not know or do not remember and move
on, thus maintaining the average duration of the
interviews and surveys as stated in the
documentation; and c) seasoned interviewers
selected for data collection are trained in languages
(Spanish and English) and working with populations
with limited English proficiency.
These interviewers are also trained to be sensitive to
communication and time; they will keep the
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Form G-1608-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2024-0003
60-day FRN Citation (federalregister.gov): 89 FR 25892
Publish Dates: April 12, 2024 – June 11, 2024
interview to the allotted time, and if necessary,
interviewers will wrap up the interview and code it
as "terminated due to time limitations.” At all times,
seasoned interviewers will focus on not causing
more strain on participants. However, USCIS
understands there may be language and
communication issues due to limited English
proficiency, but these issues cannot preclude USCIS
from pursuing the information needed for program
improvement. The probes are presented to stimulate
responses from the interviewee. These questions
may never come up, particularly if the interviewee
does not recall or does not know the issue for the
period in question.

3.c.

As noted, program grantees already provide very detailed
reports to the agency. Where there is a clear overlap
between information already collected from grantee
organizations and information sought in the proposed
instruments, the burden is not justified and should be
reduced, at a minimum, by eliminating duplicative
inquiries.

3.d.

USCIS should also eliminate duplicated inquiries in the
proposed implementation and outcome-focused
instruments.

3.e.

The following question, for instance, appears on both the
implementation and outcome surveys for program staff but
seems more properly confined to the latter: "In your
opinion, what were the most important factors impacting
whether participants completed [CINAS, RAAP, or RAIS]
instruction and naturalization assistance services at your
organization?”

USCIS will update the time burden estimates.
Surveys will be adjusted to 30 minutes, and
interviews will be adjusted to 45 minutes.
USCIS will not make changes to this information
collection based on this comment. USCIS
understands that grantees submit quarterly and final
reports, and some of the requested information may
be available in these documents. However, these
fields in the USCIS quarterly reports are not
mandatory for submission, so not all grant recipients
have provided the requested information. The
instruments are needed to complete a sufficient
evaluation.
All information requested has been documented as
necessary for analysis in the implementation and
outcome of grantees and participant populations.
However, in recognition of the feedback and issues
raised, USCIS has conducted an additional review of
the instruments. USCIS will exclude questions
regarding dropouts in the outcome grantee survey
(questions 6-9) and rely only on the data gathered in
the implementation grantee survey.
USCIS will review the outcome survey and, if
necessary, clarify the distinction between these
instruments. The question on the outcome survey
may refocus on factors impacting the naturalization
of program participants rather than the program's
services. USCIS is considering changes to the
grantee surveys (implementation question 9 and
outcome questions 5, 9 and 10).

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Form G-1608-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2024-0003
60-day FRN Citation (federalregister.gov): 89 FR 25892
Publish Dates: April 12, 2024 – June 11, 2024
3.f.

The agency could ensure against duplication and make its
evaluations more efficient by combining each
implementation- and outcome-focused pair of instruments
into a single survey or interview for either program
participants or staff.

USCIS will not make changes to this information
collection based on this comment. USCIS planned
the implementation to be followed by the outcome
evaluation to learn from the former findings and be
able to incorporate findings into the outcome
evaluation. A data collection instrument that
integrates both topics eliminates the benefit of the
staggered research planned by USCIS.

3.g.

Neither the era defined by the pandemic and lockdowns
nor grant periods stretching back four or more years in the
past are appropriate to assess program effectiveness.

USCIS will not make changes to this information
collection based on this comment. USCIS
understands the feedback and concerns raised by the
working group. However, due to programmatic,
budget and timing constraints, USCIS set the study
period as stated. The CIGP evaluation was designed
and completed in February 2022. Because grants are
implemented over two years, USCIS selected FYs
2018-2021 to access the most complete data on
program implementation and completion, as well as
naturalization outcomes. Additionally, the
evaluation will account for pandemic-related
contextual factors.

3.h.

We also can attest from experience that staff changes are
likely over several years in nonprofit education and legal
assistance work that tends to pay less than other private
sector and many public sector options.

USCIS will not make changes to this information
collection based on this comment. USCIS recognizes
staff turnover in nonprofit organizations could affect
the ability of grantees to respond, especially over the
extensive study period. The evaluation methods
account for imperfect and incomplete data. There
may also be issues with recall or knowledge about
the issues asked during the years under study.
However, the need for information on the factors
affecting program implementation and participant
outcomes supersedes these potential issues,
particularly when grantee reports do not provide a
consistent and detailed response to the questions
asked in the instruments.

3.i.

We see no indication that surveys or instruments will be
available in languages other than English. We are
concerned that the apparent lack of interpretation or
translation will pose a significant barrier to gathering
sufficiently numerous, representative responses from
former program participants.

USCIS will not make changes to this information
collection based on this comment. As noted above,
experienced interviewers help mitigate the potential
lack of English proficiency of the respondents.
Additionally, surveys will be translated to Spanish,
and, where needed, interviews will be conducted in
Spanish.

3.j.

Finally, many proposed survey and interview questions do
not investigate how grant program requirements support

USCIS welcomes the questions proposed by the
working group and will further review their level
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Form G-1608-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2024-0003
60-day FRN Citation (federalregister.gov): 89 FR 25892
Publish Dates: April 12, 2024 – June 11, 2024
or hinder grantees as much as they seek information about
program qualities independent of USCIS's influence on its
grantees and services and activities that USCIS does not
require grantees to provide.

and where best to place them in the instrument.
USCIS is considering changes to the participant
implementation interview (question 5) and grantee
outcome interview (question 7) instruments.

3.k.

We are particularly disappointed with the proposed
questions about aspects of programs upon which the
structure and mechanisms of the Citizenship and
Integration Grants program have had little or only indirect
influence, such as culturally appropriate engagement and
referrals to complementary support services. Some
questions ask about features—such as client satisfaction
surveys and staff training on equity and inclusion—that
USCIS has neither mandated of grantees nor highlighted in
any technical assistance offerings.

USCIS will not make changes to this information
collection based on this comment. The questions
were adapted from widely used cultural competency
measures. There is extensive literature on the
importance of cultural competency for promoting
immigrant and refugee adaptation, integration, and
naturalization. The goal of the survey questions and
measure, supplemented by interviews, is to identify
best practices, gaps, and contexts for the culturally
competent practices of grantee organizations that
relate to improved participant outreach, engagement,
and naturalization outcomes. Since most of the
grantees are immigrant and community-based
organizations, these organizations are likely to
conduct various culturally competent practices
already.

3.l.

Questions that merit revision include the following: Ask
past program participants how they would like to learn
about programs in the future. Since many or most past
program participants will be American citizens, the more
relevant question would be how they think programs can
best reach LPRs eligible for naturalization.

USCIS welcomes suggestions for revision. The
suggested revision to the question may better serve
grantees in their outreach to potential LPRs seeking
naturalization. So, USCIS is considering changes to
the participant implementation survey (questions 5
and 6).

3.m.

Questions that merit revision include those that: Ask past
program participants about their use of English, use of
their native language, and social and recreational
engagement in English and native languages.

USCIS will not make changes to this information
collection based on this comment. The literature
indicates that bicultural engagement is more
adaptive for immigrants than assimilation (high
acquisition of host culture and low retention of
heritage culture) or separation (high retention of
heritage culture and low acquisition of host culture.)
Greater engagement with host and heritage cultures
was reported to be related to higher adaptation,
integration, and naturalization. The survey questions
were adapted from a validated measure that assesses
both cultures' retention or acquisition of language
competence, identity, and behaviors. The survey
seeks to gather data on bicultural dimensions that
affect naturalization. In no instance is the level of
engagement in one or the other cultures meant to be
presented as a negative integration marker.

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Form G-1608-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2024-0003
60-day FRN Citation (federalregister.gov): 89 FR 25892
Publish Dates: April 12, 2024 – June 11, 2024
3.n.

Questions that merit revision include those that: Ask
program participants to provide sensitive information or
recall experiences that may cause fear.

USCIS will not make changes to this information
collection based on this comment. Empirical
evidence points to the detrimental effect of
discrimination on immigrant adaptation, integration,
and naturalization. However, there is also evidence
of defensive naturalization, in which experiences of
discrimination were related to an increase in ethnic
community engagement and organizing that
promoted naturalization to protect against
discrimination. As such, these questions have been
carefully selected for inclusion in the survey, and the
survey does not request one to describe the details of
the negative experiences with discrimination. The
results will affect the programmatic and outreach
activities to promote naturalization among
vulnerable populations and communities.

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