USCIS Stakeholder Meetings on Transformation Program to Electronic Account System
Did you know that USCIS has embarked on a long-term, comprehensive project to overhaul the way in which all paper-based applications and petitions are filed with the Agency? The plan is to establish a beneficiary-centric electronic account-based system where information entered online will be centrally stored in the individual’s account and be available for future benefit requests. In addition, immigration practitioners will eventually be able to securely submit benefit requests electronically from the comfort of their own case management system. Sound familiar? Although the concept of introducing a central electronic database (with published technical standards) is brand new to USCIS, practitioners who have been relying on an electronic Case Management System to process their cases and populate forms will be very familiar with the advantages of adopting an electronic database application. Automating case preparation, managing deadlines, and generating reports are just a few of the time-saving benefits available today. The USCIS Transformation Program (which has already been in the development phase for several years now) promises to revolutionize your practice, but what will it look like and when will it happen? Let’s a take a closer look at the latest news from Washington. In order to elicit customer feedback on this project from interested Community Based Organizations, attorneys and other client representatives, the USCIS Office of Transformation recently hosted a number of national Webinars as well as local roundtable discussions in Atlanta, Boston and San Francisco. I was fortunate to be invited to attend one of the local sessions in San Francisco at the end of September along with about 25 other immigration attorneys from around the San Francisco Bay Area. The interactive discussion was hosted by a representative of Deloitte Consulting which has been engaged to work closely with USCIS on the Transformation Project. We were shown a PowerPoint Presentation with several prototypes of what the new electronic account system might look like. Listed below are some of the highlights of the proposed features that were presented and discussed at the Roundtable:
- Paper forms will be converted to electronic applications submitted through a secure USCIS account interface
- The Foreign National or authorized representative will be able to create an electronic account for the beneficiary, individual or company petitioner which will allow the system to identify the user after entry of a secure User ID and Password and/or Token, and centrally store the data entered in the account so that all entered data is available to populate multiple forms filed either concurrently or in the future
- Rollout of electronic applications will be in phases starting with administrative requests like replacement of misplaced I-94’s and I-551’s, then NIV petitions followed by permanent resident petitions and AOS applications, and lastly applications for Naturalization.
- Potential for account holder to print out official USCIS documents like the I-797 Notice of Receipt or Notice of Approval from the System
- Additional Account Management functions being considered include:
- Ability for the account holder to check messages from USCIS
- View or reschedule an appointment with a local office or Application Support Center
- Update contact information
- Check case status of pending application(s)
- Authorize or terminate attorney or accredited representative
- Live Chat with a USCIS Representative and a general Help function
- “E-Wizard” which would walk the account holder through the eligibility and required steps to apply for a given benefit based on the account holder’s current status.
- Beneficiaries would still be able to file paper applications if they did not have access to a computer or were not comfortable filing electronically. If a paper application was filed, an “inferred” account would be created by USCIS for the beneficiary that would remain dormant until such time as the foreign national or his or her authorized representative activated it online.
Although the response from those participating in the Roundtable discussion was generally favorable towards the introduction of an electronic account based system, strong reservations were voiced regarding some aspects of the proposed design including the following issues which were raised:
- According to the prototype contemplated, only one attorney will be able to be associated with an Account at one time. This presents limitations if more than one attorney is representing an individual client or more commonly, if more than one law firm is representing a corporate client.
- Initially, accounts will only be available for beneficiaries, attorneys or accredited reps, but not for paralegals or petitioning company employees. Given that the majority of the work in completing USCIS applications for a client is often performed by one or multiple paralegals or case assistants, restricting account access to a single attorney may prevent staff responsible for preparing the applications from accessing the system unless they log in as the supervising attorney which would compromise security protocols.
- Concurrently filed petitions/applications might be problematic because if the I-140 is prepared in the company petitioner’s account and the I-485 is created in the beneficiary’s account, access to both accounts may be necessary to file both. Yet depending on who is accessing the beneficiary account, the petitioning employer may not want the beneficiary to have full access to all information available on the I-140, (e.g. company financials). The ability to set different user privilege levels would therefore appear to be a necessary feature, yet goes beyond the scope of the initial prototype.
- When an Account is created by the attorney representative after being authorized by the foreign national, full access to the account will be given to both the foreign national beneficiary and attorney representative. The foreign national could therefore be able to change data on the application prepared by the attorney or even submit the application before attorney has fully reviewed it. Again, assigning different levels of user privileges would be highly desirable so that the client could have Read Only privileges to be able to review the application, but not be able to change information without the consent of the attorney.
- It is contemplated that dependents of the primary beneficiary will have their own separate accounts and that derivative information will not be available from the primary beneficiary’s account. This would be a significant limitation in that a family would need to log into each family member’s account separately to check status or make an inquiry.
It was clear from the lively interactive discussion at the Roundtable that the Transformation Prototype is still in its formative phases of design and many details still need to be worked out as USCIS continues to elicit feedback from stakeholders. But as experienced practitioners know who already rely on a well-designed and established electronic case management system like LawLogix EDGE, there is no need to wait for the Transformation Project to be launched and undergo a period of growing pains to in order to able to enjoy many of the benefits of electronic case management and forms preparation. Having stood the test of time, systems like EDGE have already addressed and provided solutions to many of the issues and concerns expressed by participants at the Roundtable. Practitioners using EDGE enjoy secure online access for HRs, FNs, and external firms as well as E-filing with the DOL and DOS. And when the Transformation Project is implemented, rest assured that EDGE will continue to expand its offering of electronically submitted forms so that practitioners will be able to continue to prepare all USCIS forms in EDGE and seamlessly submit them through the new USCIS electronic interface. Want to learn more about electronic form preparation and submission from EDGE? Current EDGE clients can contact Customer Support here or by calling us at 602-357-4240 ext. 2 for complete details. New clients interested in learning more about the LawLogix EDGE system can contact us here or call 602-357-4240 ext. 1. Also, please visit our website atwww.lawlogix.com for general information.