Overview
Title
30-Day Notice of Proposed Information Collection: Affidavit of Relationship (AOR)
Agencies
ELI5 AI
The U.S. government wants people to help decide how a form that helps families live together as refugees should be used, and they want ideas on making the process easier and fairer. They're also trying to figure out who pays for certain DNA tests that show family ties and if their way of handling the forms needs to be simpler.
Summary AI
The Department of State is seeking public comments on the submission of the Affidavit of Relationship (AOR) to the Office of Management and Budget for approval. This form is part of the U.S. Refugee Admissions Program and helps certain family members of U.S. residents apply for refugee resettlement. The AOR is used to prove family ties and requires DNA testing to verify relationships, with costs covered by the government. The collection aims to ensure proper functioning and minimize the burden on respondents, and public comments will be accepted until January 15, 2025.
Abstract
The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.
Keywords AI
Sources
AnalysisAI
The document in question is a notice from the Department of State, published in the Federal Register, announcing a 30-day public comment period regarding the proposed collection of information for the Affidavit of Relationship (AOR). This form is crucial for the U.S. Refugee Admissions Program as it helps establish the eligibility of certain family members of U.S. residents for refugee resettlement.
General Summary
The Affidavit of Relationship (AOR) is utilized within the Priority-3 (P-3) Family Reunification category of the U.S. Refugee Admissions Program (USRAP). It is a formal document that helps U.S.-based family members—those who have entered the U.S. as refugees or who have been granted asylum—apply on behalf of their qualifying family members for possible resettlement. This process involves verifying family relationships through DNA testing, with costs of parent-child relationship tests covered by the government. However, the cost for DNA testing of derivative applicants does not fall under government expense.
Significant Issues and Concerns
Several concerns arise from the document, specifically regarding the methodology for assessing time and cost burdens. The document does not sufficiently detail how these burdens have been calculated, which could lead to inaccuracies. This lack of clarity may impede accurate understanding of the true impact on respondents.
Another significant area needing clarification concerns the DNA testing requirements. While the text states that DNA costs for verifying parent-child relationships are covered by the government, it ambiguously notes that testing for derivative applicants will not be government-funded. Clearer guidelines are essential to avoid confusion and potential financial burdens on applicants.
Additionally, the average estimated time of 90 minutes per response may be understated. Preparing and verifying the required documents can be complex, potentially taking longer than anticipated.
The document describes a somewhat convoluted process involving both electronic and manual submissions, which might be confusing and could lead to inefficiencies. A fully automated system could streamline the process, reduce the potential for errors, and enhance data security.
Lastly, the restriction that U.S.-based family members must have been refugees or granted asylum within the past five years could be too limiting. This constraint might exclude otherwise eligible family members and should be reconsidered.
Impact on the Public
Publicly, the document opens a channel for feedback, allowing stakeholders to voice their concerns or support for the process. The government’s willingness to cover DNA testing costs for parent-child verifications is a positive measure that reduces financial barriers for applicants in verifying familial relationships.
Impact on Specific Stakeholders
For U.S.-based residents seeking to reunify with family members abroad, this initiative can potentially ease their resettlement processes. Still, the existing ambiguities around eligibility and DNA testing costs could negatively impact those at the margins of eligibility, potentially deterring them from applying.
The complexity of the current submission process may also place an additional burden on resettlement agencies, tasked with assisting in the electronic and manual handling of documents. Simplifying this workflow could benefit both these agencies and the applicants themselves by reducing time and labor costs.
Overall, while the Department of State's plan in the docket reflects well on attempts to support refugee resettlement, addressing these concerns would ensure a more accurate, user-friendly, and inclusive process. Encouraging clear guidelines and streamlined submission procedures is crucial to enhancing the program's effectiveness and accessibility.
Issues
• The document does not specify the exact methodologies for calculating the time and cost burdens of the proposed information collection. This could lead to inaccuracies in estimating the true burden on respondents.
• Language pertaining to the DNA testing requirement for verifying family relationships is somewhat unclear. The document mentions that DNA testing costs will be borne by the U.S. government for parent-child relationships, but states that any derivative applicant's DNA testing will be at no expense to the U.S. government. Clarification is needed on who bears the cost for derivative applicant testing.
• The average time per response is listed as 90 minutes, which may be underestimated given the possible complexities involved in preparing the required documents and ensuring their accuracy.
• The process of manual uploading into the USRAP case management system, even after electronic submission, suggests potential inefficiency and the risk of errors in data transfer. Consideration for a fully automated electronic submission and processing system might better serve the efficiency and security of the process.
• The description of the data submission process could confuse some users, as it involves multiple steps and transfers between electronic and manual processes. Simplification or clearer explanation might enhance user understanding.
• The requirement that U.S.-based family members must have been admitted as refugees or granted asylum no more than five years prior to the filing of the AOR might unduly limit eligibility and should be examined for potential adjustments.