Overview
Title
Agency Information Collection Activities; Extension, Without Change, of a Currently Approved Collection: Report of Immigration Medical Examination and Vaccination Record
Agencies
ELI5 AI
The Department of Homeland Security wants more time to ask people about a form they use to check if someone new to the country is healthy and has gotten their shots, and they are asking people to share their ideas on how to make this process better.
Summary AI
The Department of Homeland Security, through U.S. Citizenship and Immigration Services (USCIS), is extending a request for public comments on the ongoing collection of information regarding the Report of Immigration Medical Examination and Vaccination Record (Form I-693). This notice gives the public an additional 30 days to provide feedback. The purpose of this extension is to evaluate the necessity and effectiveness of the information collection process, as well as to suggest improvements. Those interested in submitting comments can do so via the Federal eRulemaking Portal by April 4, 2025.
Abstract
The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS) will be submitting the following information collection request to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995. The purpose of this notice is to allow an additional 30 days for public comments.
Keywords AI
Sources
AnalysisAI
The Department of Homeland Security (DHS), through the U.S. Citizenship and Immigration Services (USCIS), is seeking public input on their information collection process related to the Report of Immigration Medical Examination and Vaccination Record, also known as Form I-693. This notice extends the opportunity for public comments for an additional 30 days, allowing individuals and organizations until April 4, 2025, to submit their perspectives. This effort complies with the Paperwork Reduction Act of 1995, highlighting the agency's effort to ensure their data collection practices are necessary, efficient, and effective.
General Summary
This document offers a comprehensive view into the USCIS process of evaluating the collection of information from individuals undergoing immigration-related medical examinations. The form in question, I-693, plays a critical role in determining the eligibility for adjustment of status based on medical criteria. By keeping this notice open for an additional comment period, the agency aims to refine its practices in gathering this data, ensuring it serves its purpose efficiently.
Significant Issues and Concerns
The notice brings forth several issues worth discussing:
Cost Transparency: The estimated annual cost burden for this information collection amounts to $329,331,250. However, the document does not provide a detailed breakdown of this figure, making it challenging to assess whether the cost is reasonable or necessary.
Clarity in Instructions: The instruction for commenters to include the OMB Control Number 1615-0033 might be confusing for some. Without clear guidance, there is a risk that submissions could omit this critical piece of information, potentially sidelining them from consideration.
Time Burden Estimation: The document states an estimated burden of 3 hours per respondent without detailing how this estimate was reached or what efforts, if any, are being made to reduce this time commitment.
Accessibility Concerns: While comments must be submitted online, the document lacks provisions for individuals who may not have internet access. This oversight could exclude significant portions of the population from participating.
Bureaucratic Language: The expression "Extension, Without Change, of a Currently Approved Collection" might be enigmatic for the general public. Such jargon can make it challenging for average citizens to grasp the implications of the notice.
Technological Solutions: While the use of technological means to minimize the burden is mentioned, the specifics are vague. Concrete examples would help the public understand how the process might become more efficient.
Responsiveness to Public Comments: The notice references an earlier period that elicited nine public comments but fails to detail any resulting analysis or action. This lack of transparency might call into question the agency's responsiveness to public input.
Impact on the Public
Broadly, this document underscores government accountability and transparency in public processes that affect individual immigration journeys. For the general public, particularly individuals navigating the immigration system, it provides a chance to voice concerns or offer suggestions to improve bureaucratic procedures.
Impact on Stakeholders
The primary stakeholders, including immigrants, health professionals conducting medical examinations, and immigration attorneys, are directly impacted by this document. For immigrants, the clarity and efficiency of Form I-693 can significantly affect their residency process. Health professionals need to be aware of any changes to ensure compliance in documentation. Immigration attorneys will monitor this collection activity to better advise their clients and ensure the process remains fair and efficient.
Furthermore, efforts to refine this collection process can lead to smoother transitions for individuals seeking citizenship, reducing administrative burdens on both immigrants and agency staff. However, failure to address transparency and accessibility concerns could perpetuate existing challenges faced by these stakeholders.
Financial Assessment
The document under consideration involves the submission of an information collection request by the Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS) for review by the Office of Management and Budget (OMB). This commentary focuses on the financial aspects and implications noted within the document.
Summary of Financial References
The financial aspect highlighted in the document pertains to the estimated public burden associated with the collection of information required by the USCIS. Specifically, it mentions that the total annual cost burden associated with this collection is $329,331,250. This amount is derived from the burden placed on individuals or households who respond to the information collection requirements set out in the USCIS Form I-693, which involves the Report of Immigration Medical Examination and Vaccination Record.
Financial Implications and Related Issues
A significant issue related to the financial aspect is the lack of transparency regarding the breakdown or the calculation methodology used to arrive at the estimated cost of $329,331,250. For many stakeholders and members of the general public, understanding how these funds are allocated or why they're necessary is crucial for evaluating the justification of such spending. Without a clear explanation, it is challenging to assess whether the funds are being appropriately allocated and used efficiently.
Moreover, the document outlines that there is an estimated response time of 3 hours per individual respondent, with a total of 667,000 respondents. These numbers project a substantial annual hour burden of 2,001,000 hours. However, the lack of detail regarding how the 3-hour time estimate was determined further complicates understanding the necessity and accuracy of both the time and cost burdens.
The document further states that efforts should be made to "minimize the burden of the collection of information," including the use of electronic or technological methods. These efforts are related to cost efficiency but are not described in detail within the document, obscuring potential cost-saving mechanisms or efficiencies that could reduce the public burden.
In conclusion, while the document provides an estimated cost burden associated with the information collection, the absence of a detailed breakdown of these costs presents a barrier in evaluating the necessity and effectiveness of the financial allocations. Clearer communication and a more detailed explanation of the financial estimates would help ensure better understanding and public trust in these processes.
Issues
• The notice does not provide a detailed breakdown of how the estimated annual cost burden of $329,331,250 is calculated. This lack of transparency could make it difficult to evaluate whether the spending is justified.
• The instruction that comments must include the OMB Control Number 1615-0033 may not be clear to all readers, potentially leading to submissions that do not include this information.
• The notice does not provide a clear explanation of how the estimate of 3 hours per respondent was determined or whether there are any steps being taken to reduce this time.
• The contact information section specifies that phone calls will not be accepted for comments, yet does not offer an alternative for individuals who may not have access to the internet or require assistance.
• The phrase 'Extension, Without Change, of a Currently Approved Collection' may be unclear to the general public, as it uses bureaucratic language without explanation of its implications.
• The statement about minimizing the burden of the collection through technological means may be vague without examples of what forms of technology will be used to achieve this.
• While the document includes a section for public comments, there is no mention of any analysis or actions taken based on the nine public comments previously received, which could be a concern regarding the responsiveness of the agency.