Think Immigration: Customer Service Chronicles: Tracking USCIS’s Implementation of AILA’s 2021 Recommendations

In February 2021, within the first month of the Biden Administration, AILA issued a policy brief that detailed 12 recommendations for U.S. Citizenship and Immigration Services (USCIS) and Congress to rebuild a transparent, efficient, and customer service-oriented agency. At the time, the agency had essentially walled itself off from its customers and shifted its focus away from its statutory customer service-based mission. The agency’s shift was made clear in February 2018 when the agency altered its mission statement to prioritize enforcement over customer service and the welcoming of immigrants. Under the Trump Administration, USCIS eliminated valuable channels of communication and meaningful engagement with stakeholders. It also significantly altered processes for scheduling local USCIS appointments and engaging on case-related issues, exacerbating its backlog and crisis-level processing delays.

As AILA staff, we hear from AILA members every day about the impact of these changes. Members share stories of individuals and families enduring hardship as their cases languish in limbo due to processing delays, receiving inadequate and sometimes laughably vague responses on important case-related issues, and dealing with frustrations caused by an opaque and needlessly bureaucratic customer service system that can sometimes feel like a maze. We’ve also directly experienced the impact of losing engagement at both a national and local level during the prior administration, as members and AILA staff searched for ways to make sense of agency policies that seemed irrational.

Recently, USCIS issued its FY 2023 Progress Report, detailing its achievements over the last fiscal year. The report highlights important steps forward in backlog reduction, addressing processing delays, and implementation of new customer service tools. Considering these achievements, and now in the final year of President Biden’s first term, we reflect on the status of our 2021 recommendations and the overall state of the USCIS customer service experience in a new policy brief.

Since February 2021, USCIS has, among other things, issued a new mission statement underscoring the importance of customer service, addressed criticism concerning engagements at a national and, in some cases, local level, implemented tools designed to simplify and streamline customer service requests, and taken steps to reduce its crisis-level processing delays and backlog while managing its increasing workload. These steps are indicative of an agency that is listening to concerned parties, like AILA, and working to address our concerns.

However, while we commend the agency and its staff for its work in this regard, there is a lot of room for improvement and continued advocacy. As AILA staff, we continue to receive feedback from members frustrated with the agency’s implementation of digital tools, processing delays, and engagement with USCIS.

As an example, according to USCIS’s FY 2023 progress report, the Enterprise Change of Address (E-COA) tool was used to facilitate more than 430,000 address changes from its launch through December 2023. This resulted in significantly fewer requests through the customer service phone line. Yet members have raised concerns about the lack of clarity as to whether the new address has in fact been changed in the system or why a request was rejected.

In another recent example, AILA members and countless customers were left confused and panicked after an intended myUSCIS system update led to an outage resulting in lockouts, error messages, and the disappearance of hundreds of cases. At the time of publishing, the agency is still working to resolve the issue. We appreciate the agency’s focus on technological enhancements and recognize that changes like these often result in initial challenges and confusion. In the spirit of customer service, USCIS staff has worked tirelessly to address related issues that AILA members have experienced during the transition to organizational accounts. As USCIS strives to implement new tools, it is crucial that the agency continues to consider and welcome feedback concerning how a potential change or update will impact customer experience.

Moving on from digital innovations, the agency has also taken several steps toward reducing the backlog of cases and improving processing times across the board. This is an issue of significant importance to AILA, our members, and their clients and we commend the agency for its achievements in FY 2023. According to the progress report, USCIS has nearly eliminated its naturalization backlog and lowered the median processing time for these applications to 6.1 months. In addition, USCIS has reduced median processing times for other high volume form types such as EAD work authorization applications. Despite these achievements, the overall backlog of USCIS cases continues to grow and processing times for many form types have either increased or remained at excessively high levels. An example of these increases can be seen when reviewing current delays for many family and humanitarian-based form types such as I-601A waivers, standalone I-130 petitions, and I-918 U petitions. We’ve heard firsthand from members about the profound emotional and financial impacts these delays can have on families awaiting reunification and individuals seeking relief on humanitarian grounds. Ensuring an efficient and fair process is one of the most basic duties that the agency has to its customers and it is clear that significant, continued effort is needed.

One area where we have seen movement has been engagements with USCIS. At the national level, USCIS has committed to meeting with AILA quarterly on various issues, in addition to quarterly asylum stakeholder meetings and biannual discussions with VAWA, U, and T organizations. The agency has also been active in offering public engagement sessions to provide updates on, among other things, new customer tools, and new enhancements, like the changes to the H-1B registration system. However, USCIS has not engaged on any meaningful level related to the EB-5 program, despite the passage of new laws that have significantly changed the program and numerous requests for engagement.

At the local level, USCIS has allowed local offices to reopen engagements and the Office of Community and Public Engagement (OCPE) has been active in hosting listening sessions. Despite this progress and the OCPE’s focus on facilitating a dialogue, AILA members have raised significant concerns about the existence and quality of engagements with local USCIS offices, and the ability to raise important policy or case-specific issues with local USCIS staff. While USCIS’s efforts are intended to foster open communication, more work is needed to ensure the agency is engaging in frequent, substantive, and transparent engagement with its customers.

Finally, it is worth noting that members of Congress also need to do more to perform much needed oversight and to ensure that USCIS has the needed resources to create a transparent and efficient customer service system. AILA continues to urge Congress to provide necessary oversight on the agency’s customer service offerings. However, considering the increase in the agency’s workload, especially its humanitarian workload, it is increasingly important that the agency is provided the necessary funding to reduce its backlog, manage its workload, and ensure fair and efficient customer service for all customers.

So, what's next? AILA is steadfast in our commitment to continue pressing USCIS to implement our 2021 recommendations, as well as the new recommendations we highlight in our policy brief concerning meaningful access for attorneys, and clarity and substantive assistance for all customers. Though it might be cliché, we understand that progress is not always linear.

After a review of the FY 2023 progress report and the agency’s progress since 2021, it is evident that strides have been made to enhance the customer experience. However, the kind of sustained progress we all seek from USCIS requires ongoing vigilance and advocacy.

As we continue and expand our push to enhance USCIS’s customer service system, we need our members’ help. Join us by taking action via the AILA Advocacy Center and provide the agency with feedback concerning your experience with the agency’s customer service tools and engagements. When you are done, share these stories and experiences on social media, using #HoldUSCISAccountable, and make it known that USCIS needs to keep up its work to enhance and improve its systems to ensure that all customers receive top-notch service.