Integration with Third-Party Software: BCIS E-Filing
Walther Solutions has been engaged in a discussion with key BCIS officials since early April regarding the integration of e-filing with third party software. Because this information would be valuable to all attorneys using automated software, we are happy to share this information with Immigration Daily readers.
Prior to the April 29, 2003, BCIS Interim Final Rule amending the regulations defining a "signature," Walther Solutions asked BCIS Immigration Web Manager, Gregg Beyer, for information about the new filing system and specifically how it would integrate with third-party software: Will attorneys have to enter the information for each form by hand, or will they be able to integrate the e-file forms with their existing case management software for direct feed?
In a volume-oriented practice like immigration law, practitioners are completely dependent on case management software tools. Whether the tool is web-based or networked, off-the-shelf or developed in-house, these are decisions for each practitioner; whether we return to the challenge of "typing" each petition by hand, even online, to comply with the government filing regulations should not be a choice. Moving one step forward and two steps backward is not an option.
On April 21, 2003, the E-Filing Project Manager provided an official response noting that the e-filing of Forms I-90 and I-765 to commence May 29, 2003, does not offer any integration with external systems. However, the response noted that the BCIS is researching an electronic filing model for the future which will be based on a relationship with third party vendors, along the lines of electronic tax filings at the IRS.
Below we attach, in relevant part, correspondence between Walther Solutions and the BCIS.
(April 8, 2003, inquiry from Greg Walther.)
Date: 4/8/2003 4:11 PM
I hope all is well with you. This is Greg Walther, who, as you
probably remember, once worked for you as an asylum officer. I'm now President, CEO and any other title I can think of for Walther Solutions, Inc. We make the ARIA software (formerly Vamoose) which is used by most of the larger immigration law firms for case management and forms production.
I think the answer to your question regarding the sudden interest in the efiling is that it was mentioned by Bill Yates at an AILA Board of Governors meeting on March 29.  A number of my other customers have also been contacting me. They have a common question, which is how will the new electronic filing system integrate with their existing case management system?
Of course, our answer at this point has to be "We don't know," since at this point we do not know what form the electronic filing system will take. I would appreciate any information you could provide so that I can prepare the firms we work with. I'd be interested in knowing if the filing system will provide any interface for third-party software such as ours.
As I am sure you know, most immigration attorneys, especially those
who are part of larger business immigration practices, do not simply fill out forms one-by-one. Instead, they enter information into a database such as ARIA, which then produces the forms, as well as documents, reports and other required output. It would be highly inefficient if the attorneys had to go to a web-site and enter the information for each form by hand. What they want is a means for their system to feed data directly into the form.
(Actually, what is truly needed is a way for the law firm systems to provide data directly to the government systems, in a fashion that
accommodates the government's security concerns, of course. The existing forms are a vestige of a paper-based system which are not suited to electronic transfer of data and make the whole process unnecessarily complicated. But that is a discussion for the future -- we'll take the electronic forms for now.)
There are a number of mechanisms that could allow for an interface
-- a common approach is to define an XML schema and allow software to write to the schema.
E-filing is a very exciting and laudable development, and knowing your visionary tendencies it doesn't surprise me at all that you are leading the charge on this. However, in order for an electronic filing system to be adopted broadly by immigration firms there will need to be some way for it to integrate with broader case management systems. Otherwise, the firms will be taking a giant step back in their ability to efficiently prepare cases. I'm sure I am far from the first person to mention this, and I'm interested in knowing what your thoughts are on the matter.
I have been studying and actively engaged with these issues for many years now, both as the Senior Associate Attorney at one of the largest immigration firms in the country  and now as president of the leading immigration case management software company, and I'd be happy to provide any insights or help that I can from my private sector perspective.
(April 21, 2003, Reply from BCIS.)
Practitioners benefit from automated immigration tools with increased consistency and decreased editing time. The government benefits from these tools with increased accuracy in the forms it receives. The BCIS Interim Final Rule amending the definition of "signature" specifically permits electronic signature in an effort to comply with the Government Paperwork Elimination Act and study the feasibility of online filing.
The Bureau of Citizenship and Immigration Services is approaching electronic filing through two tracks. First, we are looking to provide a cost-free alternative for electronic filing through our web site. That is, that there is no additional charge for use of e-filing; normal filing fees still apply. This track is currently in progress. This e-filing solution is based on individual transactions, and does not offer any integration with external systems.
The second electronic filing track that we are researching is based around the establishment of a relationship between the government and third parties that wish to transmit files to us. This group could include frequent users who have an in-house database, such as law firms or high use companies, as well as vendors. We anticipate establishing a relationship and role for these external sources, similar to the one that Intuit plays for IRS with their Turbo Tax software.
As I'm sure you understand, while the technology is not a significant hurdle, this type of relationship does bring into consideration significant concerns about the security of the databases that will be the source of information transmitted to the Bureau. Final decisions on how and when this solution might be implemented are still pending. However, we are very aware that AILA and other entities that do business with us frequently have an interest in this type of transmission and it is always a consideration point during these discussions.
As we have more firm details on the viability of batch transmission for electronic filing (and perhaps an implementation schedule and method) we be sure that that information is disseminated.
E-Filing Project Manager, Tracy Renaud
It behooves every immigration attorney to participate in the online filing feasibility study by commenting on the Interim Final Rule to ensure that the BCIS indeed moves forward. Practitioners must make the BCIS understand the absolute necessity of establishing a practicable e-filing system that interfaces with third-party software. We must share with the BCIS our requirements for the system. Case management software is the most common tool relied upon by every immigration practice; it is as pervasive today as the yellow legal pad was yesteryear.
Comments are due June 30, 2003. Please direct your interim final rule comments to: Director, Regulations and Forms Services Division, Bureau of Citizenship and Immigration Services, 425 I Street, NW, Room 4034,
Washington, DC 20536
About The Author
Juli Gammon is Director, Customer Services for Walther Solutions, Inc., makers of the ARIAŽ client service system software. She has been an immigration attorney in San Francisco since 1996.
The ARIAŽ Client Service System integrates case management, assembly, and communication tools. ARIAŽ allows users to mold many of its key components to most effectively suite the needs of their firms practice. ARIAŽs unique structure also allows users to create relationship between client data records that realistically model actual relations between people, projects and organizations. Case assembly is easy with packages of documents and forms, predefined by the firm, automatically generating at the appropriate time. Various reporting and e-mail features make communication with clients effortless.
The ARIAŽ Client Service System resides securely on a network, inside firm firewalls, allowing firms to always be in control of their data. Users access client information directly from their network, rather than from a remote server via the Internet.
For more information, call 415-543-1849 or email: firstname.lastname@example.org.
The opinions expressed in this article do not necessarily reflect the opinion of ILW.COM.
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