Monday, November 9, 2015


Today’s Washington Post outlines the USCIS’ attempts to move out of the paper age and into the electronic age.  After 10 years and a $1 billion, the USCIS has one form on-line, the I-90, which is used to renew a Green Card.  For those unfamiliar with the Form I-90, it is comparable to a driver’s license renewal form.  Ninety-nine other forms remain only available via paper filing. 

The project was originally supposed to be completed by 2013 at a budget of a half-billion dollars.  The USCIS now expects the program to be on-line in 2019 at a cost of $3.1 billion, although if history is any guide it will be years beyond that at a even greater costs.

Part of the problem is the “gotcha” nature of the forms themselves, which is indicative of a tone-deaf USCIS.  The forms often ask irrelevant and unnecessary questions, aimed presumably at tripping up users. 

Instead of focusing on the e-filing initiative, the USCIS chooses to waste time and resources.  For instance, the Simeio Solutions decision in April adds tens of thousands of petitions to the USCIS without any legal necessity.  The entire goal of the decision seems to be to make life difficult for H-1B workers who switch job locations.  There is no evidence that any legitimate policy goal was achieved by the decision.  If anything the decision and the later multiple USCIS Memos that attempted to clarify the decision,  are contrary to President Obama’s attempts to modernize US immigration policy and align it with the real world.

A good program management team would start with the essential questions before building out questions that are not core to the adjudication of the process.  A good program management team would engage users of the forms – immigrants, companies, immigration attorneys. 

Until these stakeholders are regularly engaged, skeptics will continue to criticize.  Until the administration makes it a priority to hold USCIS officials accountable for aimless policy and bloated budgets, the USCIS will continue its bumbling nature.   

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