The CIS Ombudsman's Listening Session: USCIS Application Program Interface

On January 12, 2022, the Department of Homeland Security’s (DHS) Office of the Citizenship and Immigration Services Ombudsman (CIS Ombudsman) hosted a listening session with stakeholders who develop and maintain immigration case management systems to discuss the potential for a U.S. Citizenship and Immigration Services (USCIS) application program interface (API).

During this session, CIS Ombudsman Phyllis A. Coven and Bill Stock, Chair of the American Immigration Lawyers Association's (AILA) Innovation and Technology Committee, engaged in a conversation with participants about topics such as API design and data standards, standardizing language, security protocols, barriers to volume filing, and ongoing engagement on the future of USCIS’ digital strategy. A total of 42 stakeholders participated in this listening session. Below is a sample of the feedback received:

• Stakeholders praised E-Verify, including the test environment and a separate web portal designed to help users resolve technical problems, as an effective API model.
• Attorneys shared that volume filers need access to a system that allows them to file and track multiple petitions concurrently and that can handle large file attachments.
• Participants recommended taking an iterative approach by starting with lower volume forms, which would allow users to adapt to the API and provide the opportunity for USCIS to troubleshoot issues as needed.
• The Standards Advancement for the Legal Industry Alliance and others emphasized the importance of naming conventions and offered to share standardization resources.
• Attendees suggested that lawyers could preregister with USCIS to obtain unique identifiers and then use DocuSign or other software solutions for digital signatures.
• Attorneys pointed to the H-1B lottery registration system as an example of a straightforward, stable system with a user-friendly interface and convenient registration experience that allows a client to approve multiple registrations simultaneously.
• Stakeholders recommended several ways to address overprocessing and size in an API without imposing call limitations, such as opening Slack or Discord server channels to allow users to seek real-time answers from developers. USCIS could also use these channels to post notifications, troubleshoot issues, and handle support tickets.
• Participants recommended that an API include a smart error system that identifies an error and the reason for it, as well as meaningful error handling and messages that enable providers to inform customers of data issues, rejections, and other issues with specificity, which would decrease users’ need for technical support from USCIS.
• Stakeholders recommended developing automated acceptance testing to allow third-party software vendors to validate API integration and troubleshoot issues and establishing API versioning rules and deadlines that provide ample time to upgrade to a new API version. They also cautioned that changing security settings can often render forms temporarily unusable to clients and would like to be notified as early as possible of form updates and other changes to an API.
• Participants noted that API development efforts should include family-based, naturalization, and humanitarian benefit types and that an API must be designed for both the private and nonprofit sectors, which tend to use different software.
• Stakeholders highlighted the importance of transparency, open communication, frequent releases, and a sandbox for testing new functionality, as well as listening sessions and opportunities for vendors to provide feedback on the initial release and updates.

Speakers

Phyllis A. Coven, CIS Ombudsman, DHS

Bertha Anderson, Chief of Public Engagement at the CIS Ombudsman, DHS

Bill Stock, Chair, AILA Committee on Innovation and Technology