30-Day Comment Matrix

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Form G-1617-012 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2007-0023
30-day FRN Citation (federalregister.gov): 91 FR 57649
Publish Dates: September 10, 2026 – October 13, 2026
Comment ID
0106

Comment Summary
Commenter: Andrew Huff
Re: OMB Control Number 1615-0092; Docket ID USCIS-20070023; Agency Information Collection Activities; Revision of a
Currently Approved Collection: E-Verify Program (30-Day Notice,
91 FR 57649, September 10, 2026, FR Doc. 2026-18465).
I submit the attached comment in my individual capacity. I am an
epidemiologist and security engineer who has built and
evaluated federal surveillance and data systems; affiliation is for
identification only.
Summary of recommendations: (1) state in the Federal Register
notice itself a one-paragraph description of the revision, drawn
from the Summary of Changes posted to the docket on
September 10, 2026, since neither the 60-day nor the 30-day
notice describes what changed; (2) publish the six activity lines
for the approved and proposed collections side by side and state
which lines account for the 79,730-hour increase over the
approved ICR; (3) publish aggregate, de-identified program
statistics as the practical-utility evidence for the collection,
including tentative nonconfirmation rates, the share later
resolved as work authorized, final nonconfirmation rates among
workers later shown to be authorized, time to resolution, and
photo-matching error rates, disaggregated with confidence
intervals; aggregate rates are not personally identifiable
information, and the response matrix’s refusal on that ground
should be reconsidered; (4) for the new mandatory employee
telephone and email element on mismatch cases, state
retention, data flows, use limits, and the governing privacy
impact assessment; (5) for electronic reverification, state the
covered population, expected volume, the basis for the 0.06hour estimate, and a worker-side burden line or the reason none
is needed; (6) state the NIST SP 800-63 assurance levels applied
through Login.gov and confirm a migration path to FIPS 203, 204,
and 205 consistent with NIST IR 8547; (7) treat the figures in item
3 as the standing practical-utility evidence for this collection,
published annually.
The full comment, with the statutory standard, the burden
reconciliation, and proposed replacement language, is attached
as a PDF (7 pages).
Disclosure: I have no financial interest in any vendor or contract
involving this program, and I was not compensated for this
comment.
Andrew G. Huff, Ph.D., M.S.
Risk Factor Research, LLC, Michigan, USA
[email protected]

USCIS Response
Response:
1&2. USCIS follows the drafting and
publishing guidelines of the Office
of the Federal Register who
presents the requirements under
the PRA.
3) This information is reported to
Congress as requested per statutory
requirements. See Illegal
Immigration Reform and Immigrant
Responsibility Act of 1996 (IIRIRA).
Pub. L. 104-208, Div C, 110 Stat.
3009.
4) DHS appreciates your feedback
and suggestions and will consider
them. There is a forthcoming
privacy impact assessment which
will typically include the data
elements and records retention
schedule. USCIS has reviewed the
comment and will update, as
necessary, any privacy
documentation.
5) Electronic reverification is
intended to apply only to
employees whose employer uses EVerify. Further, there is no burden
on the employee, as only the
employer will use E-Verify to
perform the reverification based on
data the employer includes in the
Form I-9, as currently required
under federal law. The .06 hour
estimate is based on the estimated
time it will take employers to use EVerify in order to run a
reverification case. This was based
on user testing times.
6) The Login.gov integration uses
IAL2 and AAL2, as applicable to the
systems approved identity-proofing
and authentication requirements.
This migration must address both
cryptography used for new
credentials and sessions, and

https://cisgov.sharepoint.com/sites/ECNops/RCD/pra/Actions/G1617-012/30-Day%20Comments/USCIS-2007-00230106_attachment_1.pdf

0104

Commenter: WhoPoo App
Employers openly don't cooperate with EVerify and laugh about
it behind your backs. Please cancel the following programs to
balance the budget and help save social security and the EVerify
program: Many U.S. employers offer some form of tuition
reimbursement or educational sponsorship, with about 56%
providing tuition assistance for employee education according to
the Society for Human Resource Management. However, the
availability of employer tuition reimbursement for ESL degrees
specifically can vary widely. Companies may be more inclined to
invest in employees pursuing english as second language degrees
when language skills are essential to job performance,
particularly in fields like healthcare, education, or customer
service. Enhancing English communication abilities can improve
productivity, reduce errors, and support a diverse workforce,
which aligns with many organizational goals. Please terminate all
ESL support from employers so EVerify can be properly
implemented.
Next, please terminate ELA and IELCE. You will have to work with
the Department of Education to get this done, and it should've
been dissolved. The U.S. Federal Government provides
significant funding that supports the English language teaching
(ELT) profession and multilingual learners of English (MLEs). The
U.S. president has proposed a budget for fiscal year 2026 that
eliminates this funding and, more urgently, the funding for fiscal
year 2025 has yet to be released.
The U.S. Department of Education has, as of this publication, not
allocated the Congressionally appropriated funding for fiscal year
2025 for several programs, including the funds for English
language acquisition (ELA) PreK-12 Public Education and for the
Integrated English Language and Civics Education (IELCE) of adult
education—funds for the states' fiscal years that begin 1 July
2025. Please make this cut permanent.

cryptography protecting previously
created records. For example,
records subject to NARA-approved
retention and disposition
requirements, including agent and
employer records retained for 10
years before permanent purge, may
remain dependent on legacy
cryptographic keys for their full
retention period. Records created in
2026 and encrypted under a legacy
112 bit key may still need to be
decrypted, processed, and
permanently purged in 2036.
Deprecating the legacy algorithm or
key in 2035 without a legacy-data
migration plan could prevent the
system from performing required
disposition actions.
7) This comment is out of scope for
this information collection and did
not provide feedback on the nature
of the information collection.
Response: DHS appreciates your
feedback on the use of E-Verify.
The other comments were out of
scope for this information collection
and did not provide feedback on the
nature of the information collection.
This extension action is to keep this
information collection approved for
use under the Paperwork Reduction
Act.

St. Cloud (MN) reported in March 2003 that almost $200,000
was spent in a nine-month period on a variety of interpreter and
translation services. Many of these costs are not reimbursed by
insurance.
AP, Central Minnesota health workers face challenge of diversity,
July 1, 2003
Alameda County (CA) Medical Center has 18 full-time
interpreters on staff in addition to 19 on-call translators. The
county’s hospitals are relatively well staffed, even though
patients may have to wait a long time for the services. Providing
translation services costs the center more than $1 million a year.
That’s especially high in light of budget woes that forced the
closure last week of two of its clinics. Meanwhile, 22.4 percent of
the center’s patients have no insurance, 66.4 percent are on
Medi-Cal, Medicare or the county’s indigent program and less
than 5 percent have insurance. Medi-Cal reimburses Highland
$23.77 for a standard visit. The hospital pays its staff interpreters
$18 to $20 an hour. For other health care providers without staff
interpreters, translations services can be very expensive.
Contracting such services can range from $30 to $130 per hour.
Victoria Colliver, Videophones help hospital provide crucial
translation services, San Francisco Chronicle, July 5, 2003
Over the past five years, the number of Kentucky students
enrolled in English as a Second Language (ESL) classes has tripled.
Schools have responded by hiring bilingual staff, training
teachers in new instruction methods for other cultures, and
having teachers visit student’s homes. Kentucky is finding out
that multilingualism is expensive. Jefferson County Public
Schools – which provides 65 ESL teachers and dozens of bilingual
assistants, spends about $5 million a year on ESL students.
Bowling Green spends about $500,000 a year for its ESL
population on everything from bilingual dictionaries to bilingual
teachers. The state met some of its surging ESL demands with
federal emergency gra

0023

Commenter: Anonymous
The information collection notice contains fundamental
mathematical errors and structural data flaws. The sum of the
individual category hour burdens listed in Paragraph (5) totals
503,855.34 hours, yet Paragraph (6) reports a total annual
burden of 2,045,781 hours. This leaves 1,541,925.66 hours (over
75% of the claimed total) completely unaccounted for in the
record. USCIS must correct these mathematical discrepancies
and issue a corrected burden baseline prior to seeking OMB
clearance.
Under 5 CFR 1320.5(a)(1)(iv), an agency must provide a specific,
objectively supported estimate of burden hours. Multiplying the

Response:
USCIS inadvertently did not reflect
that the burden for the Queries and
Initial Cases line item was underreported. The correct value should
be 235,985 times an estimated
response rate of 55 responses per
year times .121 hours = 1,570,480
hours. Adding this to the other line
items totals 2,045,781.

reported number of annual respondents by the reported hours
per response for each of the six listed sub-collections yields the
following sub-totals:
- New Users Entry (Employer Enrollment): 66,330 respondents
multiplied by 2.26 hours equals 149,905.80 hours.
- New User Training: 66,330 respondents multiplied by 1.00 hour
equals 66,330.00 hours.
- Existing User Annual Training: 358,670 respondents multiplied
by 0.50 hours equals 179,335.00 hours.
- Terms of Service Training: 119,557 respondents multiplied by
0.55 hours equals 65,756.35 hours.
- Queries and Initial Cases: 235,985 respondents multiplied by
0.121 hours (approx. 7.26 minutes) equals 28,554.19 hours.
- Reverification: 232,900 respondents multiplied by 0.06 hours
(approx. 3.6 minutes) equals 13,974.00 hours.
Summation Analysis:
Calculated Total Burden (Sum of Sub-collections): 503,855.34
hours
Agency Stated Total Burden (Paragraph 6): 2,045,781 hours
Unexplained Discrepancy: 1,541,925.66 hours
The agency’s stated total burden is 4x over of the calculated sum
of its sub-categories. An agency action that relies on
contradictory internal math fails the basic standards of reasoned
administrative decision-making under the PRA.
USCIS should take the following corrective steps:
1 Re-calculate the burden estimates to reconcile the
1,541,925.66 hour gap between Paragraph (5) and Paragraph (6).
2 Clarify whether respondent counts for transaction-based
categories ("Queries" and "Reverification") represent unique
employer accounts or total annual transactions.
3 Publish a corrected notice in the Federal Register allowing the
public a meaningful opportunity to evaluate the updated
methodology.