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< Back to current issue of Immigration Daily < Back to current issue of Immigrant's Weekly

E-Filing Standards for Immigration Group (ESIG)

The following is a summary of the Annual ESIG meeting held in Philadelphia
on Wednesday, June 9, 2004, 7:00-8:30 PM:

I.	Bob Meltzer made some general opening remarks thanking those in
attendance and reviewing the agenda. As an update regarding the activities
of ESIG as well as an update of CIS E-Filing, since last year’s meeting Bob
reviewed the highlights from the three meetings between ESIG and CIS since
last year as follows:

a.	October 29, 2003 Meeting
(1)	Tracey Renaud and Patricia Cogswell expressed the view that it is
likely beneficial that CIS cooperate and work with ESIG and that in the final
analysis a linking up of the vendor systems to the CIS system would be
helpful to the government and to all stakeholders.
(2)	Ms. Cogswell stated that USCIS priorities for the coming fiscal year
will be the setting of an e-signature standard and the deployment of six
new forms (I-120, 140, 907, 539, 131, 829)
(3)	They have been looking into PKI (Public Key Infrastructure) as a
development for their e-signature solution (although this is not likely, as
PKI costs $25-$50 per certificate)
(4)	CIS wants their system to be as intuitive as possible where the client
need not determine where to file an application but the system will make
that determination based on certain information provided by the user such
as the home address
(5)	CIS recognizes that if users are required to reenter data, this would
be a problem adversely affecting widespread adoption
(6)	CIS has not made significant forward movement in dealing with "3rd
Party vendors" and the completion of the next 6 forms as the agency had hoped and
(7)	Although CIS will be developing a standards committee, the formation of
the committee is not something that is immediate
(8)	Although the chances are that XML will be the standard, CIS provides
absolutely no guarantee that the DHS will ultimately allow that standard
(9)	It is not CIS' intention to be unique, in terms of development, when
the agency may avail itself of proven applications and solutions available
elsewhere. CIS will look for commercial off-the-shelf systems whenever

b.	January 9, 2004 Meeting
(1)	The new online forms that were projected to be available and announced
in last years I-90/I-765 launch (I-129, I-131, I-140, I-539, I-821, I-907)
are in the testing stage now and should be available during the 2nd
Quarter, 2004. The acceptance of credit cards for payment was implemented in December
(Note: This was one of the items that was submitted by ESIG in response to
the legislation).
(2)	CIS speculates that it will adopt Global XML, rather than the
previously considered Legal XML (considered by us)!  The FBI has already adopted
Global XML; therefore, agencies that must share data with the FBI will likely
adopt XML to facilitate the sharing process.  Keep in mind that, although
probable, it is only speculative that CIS will be adopting Global XML in
the future (Caution: still no guarantees)!
(3)	CIS suggests that any vendor experiencing issues with a particular CIS
form should contact the appropriate contact person for that particular form
directly.  Contact information - including name, address, phone numbers and
e-mail address, may be found in the Federal Register.  Any new form and the
appropriate contact information will be listed in the Federal Register.
(Note: ESIG members with ideas for developing a system to inform the
membership of new form availability should post or contact Bob Meltzer)
(4)	At the present time CIS field offices (District/Sub-district) are not
working together or under direction from Headquarters but there is a
recognition and goal to work together in the future (i.e. Miami office has
developed an online appointment scheduling system).
(5)	There are efforts to replace their current automation in their own
Headquarters, Field and Regional offices. These efforts are still in the
Requests For Proposals stage to which large development and consulting
firms are responding. This is a massive, high priority project that will replace
the legacy system over the next few years.

c.	April 15, 2004 Meeting
(1)	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.
(2)	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.
(3)	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.
(4)	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.
(5)	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.

There was then a general discussion about the types of activities necessary
to move the ESIG mission forward which included usefulness of approaching
DHS directly in order to make it easier for the CIS to make “batch-filing”
a priority and also the value of working together with AILA in some capacity.

Sam Udani, Publisher, ILW.COM then addressed the meeting and offered
his assistance in contacting senior AILA members about the value of working
together with ESIG and also invited the group to submit any communications
regarding the group or its activities to ILW.COM for publishing.

II. 	Goals

	Goals as stated in the agenda are as follows:

1.	Continue to work closely with BCIS, particularly with the E-Filing
officials and contractors, to provide stakeholder input into BCIS E-Filing
decision-making and to promote technology growth within the BCIS to better
serve applicants for, and beneficiaries of, immigration benefits.
2.	DOL Liaison
3.	DOS Liaison
4.	Increase membership
5.	Increase activity of current membership

Items 2 and 3 were not addressed due to time constraints and were tabled.

Regarding membership, it was noted that the ESIG listserv now contains 82
members and continues to increase. It was discussed whether the group would
be better served with or without broader AILA membership participation and
agreed that, if there was interest within AILA to work together, an initial
step would be to increase membership.

Regarding increasing activity, it was agreed that there was no need to
increase activity on the listserv and that it was not uncommon for the
listserv to post communications only occasionally and that ESIG’s focus
should continue to be interaction and activities with the USCIS.

The group concluded that we would move forward with three action items at this time:

1)	Members would approach AILA leadership to suggest some arrangement to work 
with ESIG
2)	The drafting committee would create two position papers: one to be
distributed (or published) to lawyers stressing the need for increased
participation on this critical issue affecting the immigration bar; and the
other, outlining the need to begin development of e-filing between lawyers,
their technology systems, and the CIS and to keep the bar updated on CIS
current developments in e-filing and related support such as security
threats and OMB mandates
3)	Begin to develop our contact list from our members, as well as a strategy 
to approach DHS and CIS with the above position paper.

III. 	The 2004-2005 Organizational Structure was outlined as follows:

A.	Communications/Membership Committee
Robert Meltzer
Angelo Paparelli
Greg Siskind

B.	Drafting/Legal Committee

John Fay
Ron Gotcher
Robert Meltzer
Angelo Paparelli
Dan Siciliano
Greg Siskind
Greg Walther

C.	Technology Committee

Sam Abujawdeh
Fred Colman
Boris Kerbikov
Robert Meltzer
Chas Nol
Ken Ray
Jamie Trammell
Umesh Vaidyamath