Policy Briefs

Policy Brief: Breaking Down Walls - The Status of AILA’s Customer Service Recommendations

4/25/24 AILA Doc. No. 24030500. Adjustment of Status, Asylum, Business Immigration, Family Immigration

Contact Paul Stern, pstern@aila.org, Jonathan Valdez, jvaldez@aila.org, Sharvari Dalal- Dheini, SDalal-Dheini@aila.org

In a February 2021 policy brief, AILA discussed a well-documented shift in the prior four years that led the agency far from its statutory mission, hampering customers’ abilities to gather or provide necessary information and updates on their cases.

AILA made nine recommendations for USCIS to improve the quality and transparency of its customer service tools and services and three recommendations for Congress to ensure the agency is held accountable.

Recommendations for USCIS

  1. Reframing the USCIS Mission Statement
  2. Making the USCIS Contact Center More Accessible
  3. Resolving the Issues Plaguing the Scheduling of Local USCIS Appointments
  4. Offering Walk-in Availability at Local USCIS Offices
  5. Reducing the Crisis-Level Processing Delays
  6. Reducing Cost and Securing Funding Without Passing Costs on to Customers
  7. Reinstating Local and National Email Inquiry Boxes at Relevant Offices
  8. Offering Robust National and Local Engagements with Customers
  9. Reopening International USCIS Field and District Offices

Recommendations for Congress

  1. Request regular statistics on USCIS Customer Service Center services.
  2. Increase Congressional Oversight of USCIS’s Public Service Tools
  3. Support USCIS Accountability Legislation

Since then, the agency has made a concerted effort to return to its customer-oriented mission and address feedback provided by AILA in our policy brief and subsequent engagements, leading to proactive steps at a national, local, and even international level to improve the agency's offerings.

While AILA appreciates the demonstrative shift in importance placed on customer service at USCIS, as evidenced by its FY2023 USCIS Progress Report, significant work remains. Improving customer service is a key component of the USCIS FY2023-FY2026 strategic plan. For the agency to achieve its goals, Congress must ensure USCIS has the funding and support it needs. USCIS must continue to reduce barriers to its services and provide more substantive and efficient service for its customers.

AILA provides the following recommendations that follow up or expand upon our February 2021 policy brief:

  1. Congress must ensure that USCIS is sufficiently funded and staffed to address its backlog, reduce processing delays, and ensure efficient and substantive customer service. This funding is key for the agency to reduce its backlog, reduce crisis-level processing delays across all form types, and ensure prompt and effective service for customer service inquiries.
  2. USCIS should continue to take steps to reduce crisis-level processing delays for all form types and provide greater transparency into the agency’s processing times. Although USCIS has reduced its net backlog, USCIS processing times continue to increase for many form types, especially for humanitarian and family-based cases such as I-601As, I-130s, and I-918s. The agency must take all available administrative steps to improve processing times, including minimizing redundant and unnecessary RFEs, improving the clarity and specificity of language in RFE and rejection notices, and reducing the length of forms.
  3. USCIS should provide attorney access and greater clarity concerning the client-specific myProgress page on USCIS’s website, as well as online service and filing tools. Immigration attorneys are an integral part of the USCIS customer base and a key to efficiency in adjudication. We commend the agency’s recent launch of new organizational accounts that will allow multiple people within a company to collaborate and prepare H-1B registrations, H-1B petitions, and associated requests for premium processing. However, ongoing access-related issues remain for many law firm staff seeking to utilize the new accounts. We recommend that USCIS implement more flexible and customizable attorney accounts that enable legal teams, including associates and paralegals, to collaborate more effectively, and expedite the integration of API options for seamless e-filing. In addition, the agency must allow attorney access to the myProgress page on USCIS’s website to help set client expectations concerning the processing of their case. This would help to avoid the confusion and frustration experienced by both attorneys and clients when the myProgress page displays different processing times than what is publicly available. Doing so will also likely result in a lower number of case status inquiries from stakeholders.
  4. USCIS should re-evaluate and streamline the display of USCIS processing times data and simplify the process for making an inquiry on cases outside of normal processing times. USCIS’s current collection of processing times pages provides confusing and sometimes conflicting information. In line with AILA’s recommendations, USCIS should update these pages to provide greater clarity to its customers concerning the state of a case, and the time in which a follow-up is possible.
  5. USCIS should improve access to services and information through its Contact Center, service centers, and local offices. While USCIS has undoubtedly made improvements, the USCIS Contact Center phone line and local office scheduling systems continue to confuse and frustrate customers. The same is true for the inability to receive efficient and effective service for complex or urgent inquiries. In addition, concerns remain over the functionality and user-friendliness of the agency’s newest tools such as the text-ahead feature, electronic change of address, and most recently the new organizational accounts. AILA urges USCIS to continue improving its processes and to consider user-input at all stages of development to ensure ease of use. Finally, stakeholders for humanitarian-based cases can only communicate with USCIS through designated email inboxes that often provide a generic response or no response at all. USCIS must review its methods of communication and ensure efficient and substantive responses for all inquiries, and especially for inquiries involving complex, urgent, or humanitarian-based requests.

Status of Each Recommendation

AILA Recommendation Status Explanation

USCIS
Reframing the USCIS Mission Statement Completed On February 9, 2022, USCIS issued a new mission statement that is more in line with its statutory mission and indicative of the it's work as an agency that provides customer-based services.
Making the USCIS Contact Center More Accessible In progress Since 2021, USCIS has made the Contact Center more accessible for its customers. The agency has implemented or improved several tools as a part of its efforts. For example, USCIS has introduced a Text Ahead Feature, launched the Enterprise Change of Address (E-COA) tool, and also expanded its online e-request functions to include additional categories for inquiry. In addition, USCIS launched organizational accounts for H-1B petitions. Also, per the Ombudsman's report, the agency has begun to take several additional steps to promote efficient, substantive, and meaningful access for customers while also modernizing the customer service experience. For instance, according to USCIS's FY2023 progress report, the E-COA tool is set to reduce USCIS Contact Center calls by 31%, or 1.5 million inquiries annually. However, AILA has received reports of concerns over both the functioning and usability of many of the agency's newest additions. AILA will continue to engage with the agency on these concerns to ensure that current and future tools are more customer friendly when launched.
Resolving the Issues Plaguing the Scheduling of Local USCIS Appointments Completed USCIS has introduced an online appointment request form, enabling individuals, attorneys, and accredited representatives to request in-person appointments at local field offices without calling the USCIS Contact Center. This form is applicable to four specific case types: ADIT Stamps, Emergency Advance Parole, Immigration Judge Grants, and Other (mirroring InfoPass categories). According to USCIS, between August and September 2023, USCIS received more than 16,000 appointment requests through this new online tool. Additionally, USCIS launched an online rescheduling tool for biometrics appointments in June 2023, providing flexibility for benefit requestors and representatives to reschedule appointments before the scheduled date. In FY 2023, USCIS rescheduled over 33,000 biometric services appointments using the tool.
Offering Walk-in Availability at Local USCIS Offices In progress Although USCIS notes on its websites that Field Offices do not allow walk ins, certain field offices have piloted walk in programs reserved solely for emergencies.
Reducing the Crisis-Level Processing Delays In progress USCIS has taken some measures to reduce crisis-level processing delays, including increasing its staffing, authorizing overtime, expanding premium processing to new form types, and making use of hybird telework policies and offices like the HART Service Center to address longstanding processing delays for certain case types. The agency has also made use of funding provided by Congress. While these efforts deserve applause, processing times have remained the same or increased for many form types, while the overall number of pending cases continues to increase. This is particularly true for family and humanitarian case types such as I-130 petitions, I-601As, and I-918s.
Reducing Cost and Securing Funding Without Passing Costs on to Customers In progress Over the last three years, USCIS has expanded premium processing. In 2022, USCIS announced and began implementing a final rule that changed premium processing regulations to conform with the Emergency Stopgap USCIS Stabilization Act. In doing so, the agency announced intentions to expand premium processing to Form I-539 and I-765 applications, as well as additional classifications of I-140 petitions. In addition, the agency has made use of appropriated funding from FY2022 to authorize new staff and overtime to address its backlog. The agency continues to request additional funding from Congress to address its backlog. However, on January 31, 2024, the agency issued a final rule detailing a revised fee schedule that will significantly increase costs to many customers, without the promise of significant improvement on processing times. Continued advocacy is needed to ensure that the standard for the agency's services meets the heightened fee requirements.
Reinstating Local and National Email Inquiry Boxes at Relevant Offices In progress Currently, AILA maintains direct communication with USCIS through the designated USCIS Feedback email. USCIS actively engages with AILA on crucial issues and trends affecting members and their clients. In addition, USCIS has provided AILA with contact information for Community Relations Specialists nationwide. With this said, many local offices have not reinstated local email boxes. In addition, communication with USCIS via email is limited to national issues and trends.
Offering Robust National and Local Engagements with Customers. In progress In 2022, USCIS committed to quarterly meetings with AILA National fostering direct communication on high impact issues facing the AILA membership. In addition, USCIS has established the Office of Community and Public Engagement (OCPE) to enhance public and stakeholder involvement. OCPE also oversees consistent community engagement efforts in all local field offices. While the agency has allowed for a resumption of engagement at the local USCIS offices, members have reported different levels of engagement with both AILA and stakeholders generally across field offices, with some offices offering significantly little engagement compared to others.
Reopening International USCIS Field and District Offices In progress In 2019, USCIS indicated its intention to close many of its international offices. Out of 23 offices, the agency only continued operations at seven offices in Bejiing, China; Guangzhou, China; San Salvador, El Salvador; Guatemala City, Guatemala; New Delhi, India; Nairobi, Kenya; and Mexico City, Mexico. Since this time the agency has reopened just one office that was closed in 2019, in Havana, Cuba. In 2024, USCIS announced the opening of new international field offices in Doha, Qatar, and Ankara, Turkey. USCIS indicated in its FY2023 Progress Report that it will continue to explore locations where USCIS may open additional international field offices as part of its international expansion efforts. In addition, USCIS and other agency partners plan to increase refugee processing in the Western Hemisphere through the Safe Mobility Office initiative. USCIS is on track to admit between 35,000 and 50,000 refugees from the Western Hemisphere in FY2024.

Congress
Request regular statistics on USCIS Customer Service Center services. In progress Congress has included reporting requirements for USCIS in recent appropriations legislation. These requirements are primarily focused on backlog reduction, electronic processing, its budget and productivity, adjudication of certain form types like employment authorization cases, and asylum operations. Few of these requirements pertain to USCIS's customer service tools.
Increase Congressional Oversight of USCIS’s Public Service Tools. In progress There has not been significant public action taken by Congress in providing oversight of USCIS's public customer service tools. One of the requirements in the Case Backlog and Transparency Act of 2022 required USCIS to adopt an inquiry escalation process and to ensure substantive responses to customer inquiries. Outside of this, members of Congress have focused primarily on USCIS backlog reduction, and not customer service tools.
Support USCIS accountability legislation In progress While Congress has not passed stand alone legislation to hold USCIS accountable, bills like the Case Backlog and Transparency Act of 2022 have been proposed. In addition, Congress has included reporting requirements for USCIS in appropriations bills requiring statistics on its backlog and the agency's efforts to reduce it.

 

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