Mr. Kim is an Advancing Justice client seeking to naturalize and become a U.S. citizen.

As a recipient of supplemental social income (SSI), Mr. Kim is currently eligible for the fee waiver to reduce the cost of his naturalization application fee. He provides proof of his SSI, and his fee is reduced from $725 to $0.

Under the proposed changes to the fee waiver eligibility criteria, Mr. Kim would not be able to provide his SSI statement to apply for the fee waiver because SSI is considered a “means tested benefit”. Instead, he would be required to provide a tax return transcript (different from a tax return) - which would mean contacting the IRS and waiting for his transcript in the mail. But because Mr. Kim is a senior and does not file federal tax returns, he would no longer qualify for the fee waiver under the new fee waiver eligibility criteria.

This would be the new reality for the almost 245,000 applicants who apply for the fee waiver each year in the US.

After being introduced fall 2018 and re-introduced in spring 2019, this USCIS proposal is open for a third round of comments. We only have 30 days - until July 5, 2019 - to fight back one last time. Send your letter to USCIS, rejecting their proposed fee waiver changes.

The changes to the fee waiver eligibility criteria will discourage low-income immigrants from applying for citizenship.

Currently, low-income immigrants who use a means-tested public benefit (such as food stamps or supplemental security income/SSI) need only show proof of their benefit in order to qualify for the fee waiver to reduce the cost of the citizenship application fee.

Under the proposed changes, applicants are required to provide new documents, such as a federal tax transcript from the IRS, in order to prove their eligibility for a fee waiver. It places an additional unjustified burden on applicants, particularly those who are limited-English proficient (LEP), elderly, or have limited access to a computer or internet.

This change contains no remedy for those who are not required to file income taxes (such as retirees, students, individuals on SSI) on how they could prove their low-income status to U.S. Citizenship and Immigration Services (USCIS).

This change will have a chilling effect on naturalization. It places a greater time and resource burden on individuals, thereby discouraging otherwise eligible individuals from applying for naturalization.

This change would price immigrants out of applying for citizenship.

In the last 20 years, the naturalization fee has increased by 600% and now costs $725 to apply. Of the approximately 750,000 applicants who naturalized in 2017, one in three applied for the fee waiver through proof of a means-tested public benefit. Without this fee waiver option, many may choose not to naturalize.

This change will create additional wait times to naturalize.

With the proposed changes to the fee waiver form, it will become harder for legal service providers to complete citizenship applications in the workshop setting due to needing multiple steps to obtain the forms that would be required under the rule change. Community organizations will be forced to change their service delivery models, effectively reducing the number of people they can serve, and increasing the time it takes to complete the naturalization process which already takes years, even with the help of lawyers.

Bottom line: The changes to the fee waiver eligibility criteria will hurt low-income immigrants the most, which is what the Trump Administration wants.

Send your comment before July 5, 2019, and tell USCIS to reject the proposed changes to the fee waiver eligibility criteria. Instead of gatekeeping low-income immigrants, they should be ensuring that U.S. citizenship is open to all people who qualify.

Note: Before submitting, please tailor this message, as only unique comments will be counted. We encourage you to share your feelings on why you reject this change and/or how it may have impacted you, your clients, your family members, or communities.