The E-filing Standards for Immigration Group (ESIG) meets with the U.S. Citizenship and Immigration Services (USCIS) on a quarterly basis to discuss current development at the USCIS. On April 15, Bob Meltzer, representing ESIG, and Tracy Renaud, Director of Services Modernization at USCIS, met via teleconference. The following is a condensed summary of the conversation.
Q: Have there been any changes in the office of Services Modernization since our last meeting?
A: Tracy Renaud has been promoted to Director of Services Modernization and Lori Pietropaoli has been named Deputy Director. The former Director, Patricia Cogswell, has been transferred to Chief Strategist of the USVISIT initiative.
Q: When we met in January, it was estimated that more e-filing applications would be available. What is the status of the remaining top priority electronic applications?
A: Six additional forms (I-129, I-131, I-140, I-539, I-821, I-907) will be available online in May. They will function similar to the current I-765 and I-90 applications by using an html interface, which transfers the data into the forms. The system intuitively determines if supplement forms are required and generates those forms. Forms that are not CIS forms, such as an ETA 9035 that accompanies the I-129 in an H-1B application, must be submitted as part of the supporting documentation package.
Q: Have there been any changes to the e-filing process or development process in the past 3 months?
A: The new forms will also include pin/password registration as a type of electronic signature for the petitioner and applicant (not the attorney). As USCIS is subject to Department of Homeland Security (DHS) requirements, passwords must contain characters, numbers and/or punctuation marks. Director Renaud acknowledged this may prove to be cumbersome for the user, but an easier solution is not available under DHS guidelines.
Q: In January, it was mentioned the CIS might ultimately favor Global XML. Although the FBI intends to implement the Global XML standard, there has been speculation Global XML is not practical for widespread adoption and XML would win out. Comments?
A: Currently there is no further information regarding which standard DHS or USCIS will be using. USCIS has a representative on all current DHS development teams and there is sufficient knowledge in our office regarding the adoption of any possible standard and no deadline has been set.
Q: What can attorneys and vendors do to obtain code from USCIS to facilitate data transfer directly into the CIS rather than just moving data to the html page?
A: There are currently no resources available for the development of batch data transfers. Due to the security standards set by the USCIS, even single submissions have security hurdles. However, it would make the most sense to start a pilot program where data could be transferred on a case-by-case basis, which is not out of the ordinary but is still outside of the parameters for which accreditation was granted. The Department could begin assessing the cost and level of effort associated with such a pilot program as early as this summer.
Q: Is there anything else ESIG can do in our effort in trying to work more closely with the USCIS?
A: We can continue to meet on a regular basis.