USCIS is feeling extra experimental these days. From cutting of liaison inquiries to forcing InfoPass appointments to go through a phone call vetting system to conducting more and more interviews, USCIS customers and immigration attorneys hardly know what to expect when appearing for an interview.
One of the latest changes deals with how Naturalization interviews are conducted. Instead of one officer completing the entire process, applicants now go through a three step process. I want to believe that this system was designed in the hopes of creating a streamlined and efficient process, but that’s not what I’ve seen.
Step One - Update Information
Applicants meet an officer in the customer service area. There are 11 stations, each one about four feet apart. The set-up is a bit like at the bank – there’s no privacy, the person at the next station is conducting their business. This officer’s job is to update verify and update the information on the Naturalization application. They have applicants state their full name, current address, date of birth and Social Security Number. They also ask if anything has changed since filing – from residence to job to recent travel. Fingerprints and a new picture (for security purposes) are taken.
Step Two – Civics and English Exam
Applicants meet with a second officer who will conduct the Civics and English examination. Again, this is in the customer service area. The officer reads through the examination questions and the applicant provides the answer. The English exam is conducted on a tablet that is upright at each station. A sentence appears on the table screen and the applicant reads it aloud. Then a second screen appears and the client is asked to write a sentence using a stylus.
Step Three – “Interview”
Although clients are under oath and are talking with officers in Steps One and Two, the actual interview is conducted upstairs in a private office with another officer. This third officer goes through the entire application. They verify changes made in Step One, they collect new documents, and go through all of the “yes/no” questions. They’ll address any issue that may cause concern, maybe looking at bona fides of a marriage or reviewing criminal records. This third officer is the one who makes a decision to recommend the case for approval or not.
There are plenty of problems with this new process.
- Lack of privacy in Steps One and Two
All of your personal information is being shared out in a public space. Anyone in the waiting area could jot down everything they would need to steal your identity. Hopefully the people there are all good and decent human beings, but it’s unnerving to share all of this information in such a public and open space.
- Lack of space in Steps One and Two
The waiting room in the customer service area has around 30 seats, as compared with the waiting rooms on the second and third floor which have around 150 seats. There simply isn’t enough room in the customer service for an applicant, family, an interpreter and an attorney for each case. Sure, some cases may have only one person involved, but I have seen people forced to stand while waiting.
- Hard to hear in Steps One and Two
This is an open area and if you were hard of hearing or were limited in your English proficiency, hearing the officer in front of you will be difficult. There is a lot of extra noise in the customer service area and another interview could be going on less than four feet from you. Being able to hear and focus are paramount, yet this environment is far from ideal.
- Waiting Time
The process forces applicants to wait three times. First to be called for the updates, then for the exam, and finally for the interview. There can be gaps of anywhere between two minutes to two hours between the steps, with the largest gap often coming right before step three.
- Inability to Coordinate Attorneys
Because clients are spread out between two floors and in three different steps, it is extremely difficult for an attorney with several interviews scheduled at the same time to be present and represent clients in each step. USCIS is forcing clients to either sign a waiver saying they’ll move forward with the application without the attorney or request a reschedule of the interview. Attorneys are essentially forced to choose between clients on who they’ll be present with. In the past, USCIS would work with attorneys to ensure everyone who had represented by counsel could, indeed, be represented. They’ve stopped working with us.
USCIS has officers who want to do the right thing, who want to provide quality customer service. This process, though, is severely lacking. If USCIS wants to truly improve the Naturalization interview process they should look at the following:
- Do biometrics before the interview
- Have one officer conduct the entire interview – from conducting the English and Civics exam to taking new documents to updating the form to evaluating eligibility.
- Evaluate cases ahead of time. Officers (not the one making the decision to avoid any potential conflict of interest) could look at the file before the interview, note what information or documentation is missing, and contact the applicant with a case-specific list. USCIS provides every applicant with the same list, but an individual list would be helpful. This is particularly true on any cases involving a criminal issue. Clients don’t always remember arrests or the details, but USCIS knows this information. Why not tell people ahead of time that they need a certified disposition and probation competition letter regarding a June 15, 2003 arrest in Fulton County, GA for Theft by Shoplifting (for example)?
- Work with attorneys who provide at least two weeks’ notice on schedule conflicts. Applicants have a right to representation – they shouldn’t be punished at the last minute because their attorney has multiple interviews at the same time.
I don’t think this policy was meant to complicate the Naturalization process, but it’s clear that this new process isn’t helping with efficiency. It’s duplicative, it’s a waste of resources and time., it’s confusing. If USCIS wants to create a better process, there are certainly better ways to do it.