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Informal Proposals Shared with USCIS

The Office of the Citizenship and Immigration Services Ombudsman (CIS Ombudsman) often identifies emerging issues or trends through informal proposals, engaging in discussions with U.S. Citizenship and Immigration Services (USCIS) about how to address these problems. These informal proposals are shared with USCIS leaders and serve as a key step in our work to make recommendations to improve the administration of the U.S. immigration system. While USCIS is not statutorily required to respond to these informal proposals, it appears that they are often taken into consideration.

Our informal proposals are separate from our formal recommendations and Annual Report to Congress.

The list below highlights just some of the informal proposals developed by the CIS Ombudsman where USCIS has taken action. Our office does not seek to take credit for originating these ideas, but we create a powerful voice for achieving operational solutions to complex problems. We rely on our stakeholders to keep us informed about issues they are experiencing with USCIS.

We welcome your feedback on the informal proposals we have presented to USCIS to improve the efficiency, effectiveness, and/or integrity of the immigration process. Please take our CIS Ombudsman Informal Proposals Survey.

YearProposalAction Taken by USCISAdditional Information
2024Enable those individuals protected under Section 1367 of Title 8 of the U.S. Code (8 U.S.C 1367) to have access to less cumbersome processes to change their safe address.USCIS updated its procedures to enable certain protected individuals to request an address change through the Contact Center.See Change of Address Procedures for VAWA/T/U Cases and Form I-751 Abuse Waivers 
2024Ensure aging-out Special Immigrant Juvenile (SIJ) applicants can schedule an appointment with a USCIS field office to file Form I-360, Petition for Amerasian, Widow(er), or Special Immigrant, in person.USCIS updated its Policy Manual to allow petitioners for SIJ classification (or their representatives) to schedule an appointment with a USCIS field office during the two-week period before they turn 21 years of age to file Form I-360 in person.See Special Immigrant Juvenile Classification and Limited In-Person Filing
2024Revert to a previous policy regarding the routing of an approved Form I-130, Petition for Alien Relative, to ensure proper routing to the National Visa Center where needed without the filing of Form I-824, Application for Action on an Approved Application or Petition.USCIS updated its Policy Manual to permit discretion on routing to enable the adjudicator to read the petition in its entirety to route the approval.See USCIS Updates Guidance for Family-Based Immigrant Visas
2024Increase the use of receipt notices for certain extensions of employment authorization documents (EADs) to help employees maintain status and work authorization and assist employers in sustaining workforce capacity while allowing USCIS to prioritize limited resources.USCIS announced a temporary final rule to increase the automatic extension period for certain EADs from up to 180 days to up to 540 days.See USCIS Increases Automatic Extension of Certain Employment Authorization Documents to Improve Access to Work Permits
2023Issue clarifying guidance confirming that the time counted toward the 150-day waiting period to file Form I-765, Application for Employment Authorization, based on a pending asylum application does not stop for individuals whose removal proceedings were dismissed or terminated by the Executive Office for Immigration Review (EOIR).USCIS issued new instructions stating that if evidence establishes that an individual filed Form I-589, Application for Asylum and for Withholding of Removal, before the date when EOIR dismissed or terminated removal proceedings, the agency will issue a receipt notice with the original Form I-589 filing date. This is the date the agency will use for purposes of the one-year filing deadline and employment authorization eligibility based on a pending asylum application.See USCIS Issues New Instructions for Filing Asylum Applications with USCIS After EOIR Dismissal or Termination of Removal Proceedings
2023Increase the maximum individual daily credit card payments accepted by the Department of the Treasury to enable employers to avoid maxing out credit card payments on H-1B cap petitions.The Department of the Treasury approved a temporary increase in the daily credit card transaction limit from $24,999.99 to $39,999.99 per day for the FY 2024 H-1B cap season.See FY 2024 H-1B Cap Initial Registration Period Opens on March 1 
2022Ensure lawful permanent residents have evidence of immigration status during the entire time that USCIS is processing their Form I-90, Application to Replace Permanent Resident Card (Green Card), and reduce the need for in-person appointments for an Alien Documentation, Identification and Telecommunication (ADIT) stamp, also known as an I-551 stamp.USCIS is automatically extending the validity of Permanent Resident Cards (Green Cards) to 24 months for lawful permanent residents who properly file Form I-90 to renew an expiring or expired Green Card.See USCIS Extends Green Card Validity Extension to 24 Months for Green Card Renewals
2022Establish a process to better allow applicants to transfer the underlying basis of a pending employment-based adjustment of status application to a different employment-based immigrant category.USCIS established a new filing location that encouraged the use of Form I-485 Supplement J, Confirmation of Bona Fide Job Offer or Request for Job Portability Under INA Section 204(j), for submitting transfer requests between employment-based categories.See Green Card for Employment-Based Immigrants, Transfer of Underlying Basis
2022Provide for more convenient locations for interviews of Operation Allies Welcome (OAW) asylum applicants.USCIS established circuit-ride locations to conduct interviews for OAW asylum applicants.See OAW Circuit Ride Locations
2021Clarify that the agency will consider E and L dependent spouses to be employment-authorized incident to status.USCIS issued a policy announcement to clarify that it will consider E and L spouses to be employment authorized based on their valid E or L nonimmigrant status.See Employment Authorization for Certain H-4, E, and L Nonimmigrant Dependent Spouses; see also USCIS Updates Guidance on Employment Authorization for E and L Nonimmigrant Spouses

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Last Updated: 11/22/2024
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