The LIBRE Institute and Americans for Prosperity Foundation submitted a public comment opposing a proposal from the Department of Homeland Security to raise immigration and naturalization benefit request fees and improperly transfer part of the fee revenue to Immigration and Customs Enforcement .
This fee increase, along with other fee increases in the past 12 years, show that the U.S. Citizenship and Immigration Services’ supposed budget shortfall is not simply a fee revenue problem, but rather a spending and mismanagement problem. The rule should be rejected, as it fails to address the drivers of USCIS’ rising costs and lacks statutory authority to transfer revenue from USCIS to fund ICE enforcement activities.
From the public comment:
On behalf of Americans for Prosperity Foundation and The LIBRE Institute, I write in response to the Department of Homeland Security (“DHS”) proposed rule regarding the adjustment of immigration and naturalization benefit request fees. The effects of the proposed rule will add to the numerous existing barriers against those seeking to legally immigrate to the United States. Any revenue shortfall at U.S. Citizenship and Immigration Services (“USCIS”) should first be addressed by rescinding inefficient policies and practices that are unnecessarily prolonging processing times and driving up costs.
Furthermore, USCIS has not yet fully specified which expenses the proposed fee increases will cover. The rule also proposes to transfer revenue from USCIS to fund Immigration and Customs Enforcement (“ICE”) activities, despite lacking statutory authority to do so. Because exorbitant fee increases impose additional burdens on countless individuals, families, businesses, and others who rely on the U.S. immigration system, raising application fees should be an option of last resort. If raising fees is necessary after having addressed the various inefficiencies, then the revenue raised should be limited strictly to USCIS functions.
The full public comment can be downloaded here.