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Dear Editor:

I read with interest your Editor's Comments of the Day for April 17 and your intention to offer fillable forms via your Website. From our own recent experience, I would like to suggest that you and any prospective users of these fillable forms approach this subject with healthy skepticism. Even more skepticism is needed when thinking about electronically filable forms anytime in the near future.

As advertised on our own Website for almost a year, we too will be offering INS fillable forms on our Website -- probably starting in late May or early June of this year. Once we do, we invite other Websites to provide direct links from their Websites to these fillable INS forms and use our combined efforts to the advantage of our mutual customers -- we provide the latest versions of INS forms, you provide more customers, and together we provide more customer service.

Revamping Our Internet Forms is Almost Completed

When our own revamped Internet Website debuted on August 12, 1999, some proposed making all immigration forms available through the Internet. Shortly thereafter, we did make almost all of our forms available, most as .pdf images. Many of these were not necessarily Web-friendly - neither easy to download nor easy to use. This led us to completely reformat our forms to be more Web-friendly and to publish a new final rule that facilitates printing such forms from the Internet. We are now completing this process for all of our forms. When completed, each form is issued a new edition date.

An up-to-date Forms, Fees and Filing Locations Chart can be found on the INS Website at: http://www.ins.usdoj.gov/graphics/formsfee/forms/index.htm#chart.

More than 300,000 copies of INS forms are now being downloaded from the INS Website each month - making these forms available to customers both hassle free and free.

Increasing the Usefulness of Our Forms Entry Pages

Then we realized that while we were providing easier access to our forms per se, some customers were downloading our forms, following the Instructions to the letter, and finding that procedures or addresses or even filing fees had changed since the form was originally released. Making these changes on the forms themselves involves a lengthy rule making process and publication in the Federal Register.

This led us to begin offering additional and clarifying information about each form on the Forms Entry Pages (FEPs) that we force all customers to go through before they can download the form itself. Our hope - and expectation - is that customers will read the notices and warnings and explanations on the FEP before they download the form, fill it out and send it to INS. Because the FEPs are the only place to get such clarifications, we have repeatedly advised our friends offering access to INS forms from their own immigration Websites to include the links to our FEPs in their offerings. Some Websites do this (such as Shusterman.com, www.new2USA.com, www.immigration-law.com) while others (such as your Website, www.visalaw.com, unidosaqui.com's INS forms Website at http://www.unidosaqui.com/content/es004CD270.html, and others) do not. We continue to be concerned that this may lead some of our mutual customers to download forms but then file them improperly. Customers have only to visit the FEPs for INS forms I-131 and I-485 to see the valuable additional and clarifying information that we make available that is, unfortunately, not yet on the form or its instruction.

Moving Toward Fillable Forms Online

Now we, and other immigration-related Websites, are working to offer fillable INS forms on the Internet. So far, we have studied and flatly rejected two separate software technologies - including the current "industry-standard" of fillable pdf's using Adobe Acrobat 4.0.

Initially, we were seduced into thinking -- that because others offered forms using this technology -- that it was suitable to INS. We found that it was not. The fillable forms technologies that we assessed permit customers to make mistakes that would almost assuredly lead to rejection of the application. This led us to reject the use of Adobe Acrobat 4.0 for such forms, and therefore delayed our offering of fillable forms on our Website.

Happily, it appears that a newer version of Adobe Acrobat -- version 5.0 -- has fixed this problem. This version is only now being offered by Acrobat. We will test it and evaluate it, and if it lives up to our expectations and their promises, we hope to use it to offer the first of our INS forms in fillable mode by the end of May 2001.

We strongly caution people using other versions of fillable forms to ensure that the forms they fill out and then send to the INS are complete and that all information provided is clearly visible on the form.

Therefore, in making INS forms available to the public, we suggest that Websites link directly to the forms published on our Website - these are the most fool-proof versions of INS forms available. Let us help you and our mutual customers take fullest advantage of our work. The same recommendation goes for linking to our version of fillable forms -- rather than making one's own versions or linking to those on other Websites.

New "What's New?" Feature Added to INS Website

To assist our customers in identifying changes and updates made to INS forms or forms instructions, we recently added a new feature to our Website. Under the "What's New?" button, there is a link to "Updated INS Forms and Forms Information." On this page, we will record all changes being made to our forms or forms information (FEPs) from April 2001.

Electronic Filing of INS Forms: Not Anytime Soon

Finally, I would like to refer to your remark that "Maybe [INS'] recognition of the importance of the internet will spur them on in their efforts to implement electronic filing of forms." Again, the concept is desirable and the thought seductive. But the implementation is daunting and requires the complete reengineering of our forms and forms filing processes, including substantial modification and development to our information technology support systems. To do this would take a lot of time and a lot of money. Therefore, while offering electronically filable forms over the Internet is both desirable and in the long run inevitable, it is not something for tomorrow!

Non-techies -- and I count myself a charter member of this club -- may think of electronic filing in terms of being just another way to send a fax. To them, electronic filing means filling out the form, sending it electronically so that it is received and then printed out by the INS receiving office and put into the applicant's A-file looking just like any other application filled and filed the "old-fashioned way" and/or sent by fax. NOT SO!

Electronic filing means far more than submitting information on a form. The customer fills out what appears to be a "form" that identifies and organizes the information being collected. In fact, information from electronic filing is not collected on a form per se, but by a succession of automated systems and stored into a common database for subsequent retrieval by other automated processing systems -- and get this: it's all PAPERLESS!. This then is a whole new concept beyond merely electronically sending an image of the completed paper form to the INS. And to make this electronic filing really happen, entire INS business processes and processing systems would have to be developed or reengineered, and our customers (including their attorney representatives) would have to accept and adapt to paperless processing.

Like most service oriented government organizations, INS too is looking at the various possibilities of providing e-Government services to our customers. As a first step, we are in the early stages of a pilot system to accept data electronically over the Web from one specific type of customer. With this pilot we are learning, like many organizations, that such initiatives are expensive and require a substantial amount of strategic planning and major modification to existing electronic processes and technical support. Since INS administers so many diverse services to our customers, with each service needing to be uniquely reengineered to comply with the law and to improve the level of customer service, the task is enormous. Therefore, electronic filing of INS "forms" is still a long way off.

Conclusion: Cooperation, Not Competition, Better Serves More Customers

In this provision of the latest forms and most accurate forms information, we are not in competition with other Websites. We hope only to provide our customers with high quality forms and accurate, timely forms information. The INS Website seeks to provide the public with a "gold standard of INS public information." If we don't offer a service or some information, it means that we cannot offer it in the level of service we think necessary (as in publishing local office application processing times) or that we haven't got the technology to do it yet (such as finding the status of one's case/application online).

Therefore, there are some services and information that INS cannot (yet) provide on its Website, so other Websites serve very useful purposes in providing such additional and complementary information. As resources all around are limited, I would like to caution us all to try to make the best of them by not duplicating efforts and by ensuring that the services we all collectively provide are indeed the highest quality available and possible.

Gregg Beyer
INS Web Manager
INS Headquarters
425 I Street, NW, Suite 4034
Washington, DC 20536

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